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DLA Piper LLP (US)

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Ellis Reemer

Work +1 212 335 4980
DLA Piper LLP (US)

Work Department

Tax; Corporate; International Trade, Regulatory and Government Affairs; White Collar and Corporate Crimes; Litigation, Arbitration and Investigations; Tax Controversy and Disputes; International Tax Counsel; Transfer Pricing


Partner; Head of the Tax Controversy Practice


Ellis Reemer represents clients in all aspects of sophisticated, challenging tax disputes, at the federal, state and local levels.

Ellis has more than 35 years of experience, first as a Senior Trial Attorney with the IRS Chief Counsel's office and then in private practice. His clients seek his advice and representation with respect to their most important and complex tax controversies and criminal tax matters.

In federal civil tax controversy matters, Ellis represents clients in IRS audits, in protests to the IRS Appeals Office, and in tax litigation in the United States Tax Court, the United States District Court, the United States Court of Federal Claims and United States Courts of Appeal.

In federal criminal tax matters, Ellis represents clients in all aspects of IRS criminal tax investigations as well as in grand jury investigations.

International tax enforcement is a priority for the Department of Justice and the IRS. Ellis represents clients seeking to become compliant with US (as well as state) tax laws regarding international tax issues, including representing clients participating in Voluntary Disclosure Initiatives relating to previously undisclosed foreign financial accounts and in civil tax audits and criminal tax investigations related to these matters.

Where tax liabilities have been assessed but unpaid, Ellis represents clients before the IRS Collection Division and IRS Appeals in negotiating installment payment agreements and offers in compromise, in collection due process hearings, and in resolving lien priority and levy disputes.

In state and local civil tax controversy matters, Ellis represents clients in tax disputes with state and local taxing jurisdictions throughout the US, with particular emphasis on tax controversies and tax litigations with the New York State Department of Taxation and Finance and the New York City Department of Finance. In those matters, he represents clients in audits involving income, franchise, sales and use taxes, as well as in audits involving residency and allocation issues. Ellis also represents clients in conciliation conferences with the Bureau of Conciliation and Mediation Services and in administrative hearings and appeals before the New York State Tax Appeals Tribunal and New York City Tax Appeals Tribunal. Ellis also represents clients in state and local tax collection matters including negotiating installment payment agreements and offers in compromise.

In state and local criminal tax matters, Ellis represents clients in criminal tax investigations being conducted by state and local taxing authorities, with an emphasis on investigations by the New York State Department of Taxation and Finance, the New York Attorney General and the New York District Attorney.

Ellis regularly represents accounting firms and their clients and is frequently consulted by other practitioners, among them transactional tax lawyers, bankruptcy lawyers, estate and gift tax attorneys, and matrimonial specialists.


LL.M., New York University; J.D., St. John's University; B.A., Hunter College

United States: Tax

US taxes: contentious

Within: US taxes: contentious

DLA Piper LLP (US) provides clients with the full range of assistance in tax controversy matters, acting in tax disputes at the federal, state and local levels. The firm increasingly acts in matters surrounding the validity of regulations post the 2017 tax reform and represents the targets or potential targets of whistleblower claims. Practice heads Sang Kim in San Francisco and the 'knowledgeable' Ellis Reemer in New York are the key names. The 'extremely talented' Diana Erbsen in New York is recommended.

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Legal Developments by:
DLA Piper LLP (US)

  • Sentencing guidelines for corporate manslaughter

    In February 2010 the Sentencing Guidelines Council (the SGC) issued definitive guidelines to courts on imposing appropriate sentences for corporate manslaughter and health and safety offences causing death. The SGC states that fines imposed on companies found guilty of corporate manslaughter should not fall below £500,000, while fines in respect of health and safety offences that are a significant cause of death should be at least £100,000. Crucially, the SGC declined to provide for a fixed link between the imposed fine and the turnover or profitability of the offending company.

    - DLA Piper UK LLP

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