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Who Represents Who

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Baker McKenzie LLP advises multinational corporations and high-net-worth individuals at various stages of state, federal and state tax controversies, handling matters which involve transfer pricing, R&D credit, worthless stock deductions, tax penalties and tax fraud allegations. Palo Alto-based Andrew Crousore has been acting for Facebook in an audit and IRS summons regarding assets transferred to Facebook Ireland in 2010. Washington DC’s George Clarke has been assisting petroleum and petrochemical manufacturer Sunoco with its appeal to the Federal Circuit over a Court of Federal Claims decision denying Sunoco income tax refunds arising from its 2004-2009 tax years. The client portfolio also includes Nike and Summa International. Dallas-based practice chair Robert Albaral, Palo Alto’s Scott Frewing, Robert Walton and Patricia Rexford in Chicago and New York-based Daniel Rosen are other key contacts. Thomas Linguanti and Jenny Austin moved to Morgan, Lewis & Bockius LLP in August 2017.

At the ‘absolutely top-shelfCaplin & Drysdale, Chartered, ‘exceptional individual and outstanding tax lawyerScott Michel and New York-based Mark Allison specialize in civil and criminal tax controversies. Clark Armitage is well versed in transfer pricing and Michael Pfeifer is the key contact for expatriation planning. The practice has a client portfolio of multinational companies, financial institutions and high-net-worth families and individuals. Recent highlights include the conclusion of the team’s representation of all but two of seven separate Swiss financial institutions in the DOJ’s program to provide Swiss banks with a path to resolve potential criminal liabilities in the US. Of counsel Peter Barnes, Matthew Hicks, the ‘superbChristopher Rizek and the ‘top-flightNiles Elber are other names to note. New York’s Zhanna Ziering was promoted to partner in October 2016. Attorneys mentioned are based in Washington DC unless otherwise specified.

At the ‘terrificLatham & Watkins LLP, Washington DC-based Miriam Fisher has been advising Weyerhaeuser Company on litigation initiated in late 2016 in the US Tax Court contesting the IRS’s characterization of a 2008 joint venture transaction entered into by Plum Creek Timber (which was acquired by Weyerhaeuser in 2016) as a disguised sale. Boston’s ‘excellent’ and ‘smartBrian McManus has been defending Millennium Drilling in a jury trial in the District of Nevada against allegations of fraud related to oil and gas investments. The client base also includes NBC Universal/DreamWorks Animation and Musa Brothers. Jean Pawlow, who has deep financial industry and international tax controversy experience, joined from McDermott Will & Emery LLP in January 2018 and splits her time between Washington DC and Silicon Valley.

The ‘incredibly knowledgeable’ team at Mayer Brown includes Chicago-based Thomas Kittle-Kamp, who has been advising Altera on an IRS appeal seeking to overturn the Tax Court’s decision agreeing with the client that the IRS equity compensation regulation is invalid due to procedural and substantive faults under the Administrative Procedure Act. Joel Williamson and John Hildy (both located in Chicago) have been acting for Hyatt Hotels in a Tax Court case concerning the treatment of Hyatt’s customer loyalty program. New York-based Brian Kittle, a ‘clear star’, has been assisting Canada Imperial Bank of Commerce (CIBC) with a matter involving the deductibility of certain settlement expenses and the allocation of such expenses among CIBC’s various entities in Canada and the US. Palo Alto’s Larry Langdon and Washington DC’s Gary Wilcox are other notable names.

The ‘outstandingMcDermott Will & Emery LLP advises corporate clients, banks, insurers and financial other services companies on multi-state tax controversies. Recent highlights include assisting Illinois-based agricultural cooperative Growmark with two pending tax cases at the Tax Court challenging an IRS determination that the client owes millions in taxes, and advising Fortune 100 healthcare and medical insurance company Aetna on a dispute over whether Aetna’s HMO subsidiaries are insurance companies for New York City tax purposes and whether they are subject to the city’s corporate income tax. The client base also includes Apple, Caterpillar, Citibank and Walmart. Dallas-based practice head Todd Welty as well as counsel Roger Jones and Jane May in Chicago are recommended. Dallas-based Kristina Novak was made partner in January 2017. Jean Pawlow moved to Latham & Watkins LLP in January 2018.

Morgan, Lewis & Bockius LLP is noted for disputes relating to transfer pricing, R&D tax credit and payroll tax. Washington DC-based John Magee, Sanford Stark and Saul Mezei are advising Coca Cola on a matter regarding a $9.4bn income adjustment relating to the company’s 2007-2009 transfer pricing, which has been designated for litigation by the IRS. Thomas Linguanti and Jenny Austin, who both joined the Chicago office from Baker McKenzie LLP in August 2017, have been acting for Medtronic in a $1.36bn transfer pricing dispute with the IRS, which appealed the Tax Court’s decision to slash the client’s tax deficiencies from $1.36bn to $14m in a transfer pricing matter involving its Puerto Rico operations. Litigating at the Tax Court on behalf of Steel Dynamics in a matter regarding R&D tax credit is another highlight.

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At Skadden, Arps, Slate, Meagher & Flom LLP, a team including practice head Raj Madan successfully represented Amazon at the Tax Court in a transfer pricing case involving e-commerce; Madan was also involved in representing Fidelity Investments in a dispute concerning a partnership that produced and sold refined coal. John Williams and David Foster advised Marvel Entertainment on an appeal from the US Tax Court to the US Court of Appeals regarding the application of the cancelation of debt rules for companies that file consolidated returns and have net operating losses. Of counsel Fred Goldberg is another distinguished team member. All attorneys mentioned are based in Washington DC.

The ‘top-flightChamberlain, Hrdlicka, White, Williams & Aughtry handles a wide range of tax controversy matters, from IRS audits and appeals to litigation and appeals in all federal forums, federal circuit appeals courts and the US Supreme Court. It provides specialist expertise in the areas of insurance, tax penalties, cryptocurrencies, R&D credit and employment, among other things. Houston’s ‘brilliant and gifted’ Juan Vasquez and ‘outstanding’ San Antonio-based Jaime Vasquez acted for global entertainment company Live Nation/Ticketmaster against the IRS in a Tax Court case regarding international withholding issues. Kimberly Clark and Saratoga Homes are other active clients. Among the strongly recommended professionals, Houston’s Larry Campagna is ‘an absolutely phenomenal tax lawyer’, San Antonio’s Charles Muller ‘has a tremendous understanding and sensitivity’ to clients’ needs, and Atlanta’s David Aughtry is ‘one of the best civil tax litigators in the country’.

Eversheds Sutherland is ‘superb’ and is commended for its ‘strategic advice, technical knowledge and team depth’. Washington DC-based practice head Jeffrey Friedman, Atlanta’s Eric Tresh and others have been assisting global telecoms conglomerate Comcast in a number of major tax controversies, including a dispute with the Mississippi Department of Revenue concerning the proper computation of the client’s capital value for corporate franchise tax purposes and a multi-year appeal involving numerous California tax issues, including ‘apportionability’ of income, combination and sourcing. The client base also includes Verizon and Microsoft. New York’s Marc Simonetti, Atlanta’s Maria Todorova, and of counsels Jerome Libin and Jerold Cohen, who are based in Washington DC and Atlanta respectively, are all recommended. Susan Seabrook joined the Washington DC office from Buchanan Ingersoll & Rooney in August 2017.

At Washington DC-based Miller & Chevalier Chartered, Kevin Kenworthy, Steven Dixon, Rocco Femia and Jarrett Jacinto, who was made partner in January 2018, have been acting for Coca-Cola before the Tax Court in transfer pricing litigation filed in response to an IRS determination that the client owes an additional $3bn in US income taxes for the years 2007-2009. Practice head George Hani is part of a team representing ExxonMobil in an income tax refund suit filed in the Northern District of Texas in which the IRS denied the client’s deduction for approximately $1bn of federal fuel excise taxes. James Gadwood joined as counsel from Sullivan & Cromwell LLP in September 2016.

At Morrison & Foerster LLP, ‘best-of-class’ Craig Fields has been assisting Agilent Technologies in an ongoing matter in which the Colorado Court of Appeals has held that the Colorado Department of Revenue cannot force the client to file a combined tax return with its subsidiary, a holding company, that derived its income solely from investments in foreign entities. US science and technology conglomerate Du Pont is another key client. Mitchell Newmark, senior counsel Hollis Hyans and the ‘friendly, detailed, high-intellect and responsive’ associate Nicole Johnson are also recommended. Washington DC-based of counsel Edward Froelich specializes in federal contentious tax matters. Andres Vallejo moved to Reed Smith LLP in February 2017. Attorneys mentioned are based in New York unless otherwise indicated.

Houston-based Baker Botts L.L.P. represents clients from the energy and technology sectors in tax disputes at the state and federal level, including estate, gift and generation-skipping transfer tax controversies against the IRS. Practice head Richard Husseini has been assisting MoneyGram with its appeal of a 2016 Tax Court decision stating that the client was not a bank for the purposes of Section 581 and 582 of the US Tax Code. Renn Neilson has been assisting Archrock in more than 700 property tax lawsuits pending in over 120 Texas counties; the lawsuits concern various districts’ refusal to treat Archrock’s natural gas compressors as ‘dealer’s heavy equipment inventory’ under the Texas Tax Code. John Porter and Keri Brown are other key contacts.

The ‘very bright’ tax controversy team at Fenwick & West LLP successfully represented French pharmaceutical company Sanofi, which also has headquarters in the US, in a court case focusing on the client’s UK-based worldwide joint venture with Merck and the applicability of UK and French treaties within the US in the context of such a joint venture. Analog Device and VF Corporation are other key clients. The ‘extremely intelligent and responsiveDavid Forst is highly recommended. Jim Fuller and Larissa Neumann are other names to note. All attorneys mentioned are based in Mountain View.

The ‘excellentKirkland & Ellis LLP assists clients at all stages of the tax controversy process, from pre-audit planning to audit through administrative appeals and post-appeals mediation. Chicago-based Todd Maynes and Natalie Keller have been acting for WR Grace in bankruptcy court litigation seeking a refund from the IRS of excess interest collected on an income tax deficiency. Rachel Cantor and JoAnne Nagjee, who are also located in Chicago, are other key contacts.

Norton Rose Fulbright US LLP advises clients on multi-jurisdictional competent authority disputes, audits, IRS appeals, summons enforcements and state and local property tax controversies. Robert Morris and Stephen Kuntz have been acting for global oilfield service company Baker Hughes in a Federal district court refund action related to the IRS’s disallowance of a $52m bad debt deduction in Houston. Morris and of counsel Charles Hall have been defending Bluescape Resources at the Tax Court against IRS determinations, which have disallowed around $800m in deductions and costs. The client portfolio also includes Vega Energy and Diamond Offshore Drilling. Jasper Taylor is another name to note. All attorneys mentioned are based in Houston. Since publication, Rob Kovacev had joined from Steptoe & Johnson LLP.

Reed Smith LLP acted for a client against the New York State Department of Taxation and Finance in relation to the proper classification and sourcing of electronic service receipts for the purposes of New York corporation tax. Another highlight has been advising a client on a dispute with the Utah State Tax Commission involving the proper methodology for attributing loans issued by the client to Utah. The names to note are practice head Lee Zoeller, Frank Gallo, Andres Vallejo (who joined in San Francisco from Morrison & Foerster LLP in February 2017), and Kenneth Levine, who was promoted to partner in January 2018. Attorneys mentioned are based in Philadelphia unless otherwise specified.

At Steptoe & Johnson LLP, Washington DC’s Walker Johnson has been defending pharmaceutical company Perrigo against IRS assertions that transfer pricing adjustments are necessary with regard to inter-company transfers of some of the client’s over-the-counter generic drugs. In the Phoenix office, Pat Derdenger has been assisting US electricity generator Calpine with a challenge to the property taxes imposed by the state of Arizona and Mohave County on the client’s South Point Energy Center. Delaware Gas & Electric is another key client. Other key contacts include practice heads Lisa Zarlenga and Robert Rizzi as well as Brad Anwyll, all of whom are based in Washington DC.

Thompson & Knight LLP regularly works on IRS audits, protest letters and position papers contesting tax adjustments and penalties, administrative proceedings, assessment appeals, federal and state tax refund and deficiency litigation, disputes on foreign companies and their US affiliates, as well as estate and gift tax controversies. Mary McNulty has been representing Peregrine Group in a Tax Court suit concerning the client’s request for a refund resulting from an adjustment to the basis of property contributed to and sold by the group’s partnership. Alongside senior counsel Emily Parker, McNulty has also been acting as Energy Future’s special counsel at the District of Delaware’s bankruptcy court regarding various matters, including the resolution of certain historical and ongoing IRS controversies. Associate Lee Meyercord is another name to note.

The ‘great value’ team at Winston & Strawn LLP is headed by Lawrence Hill, who joined from Shearman & Sterling LLP in February 2017 together with of counsel Richard Nessler. The two lawyers have been acting for HSBC witnesses in relation to three criminal trials involving unreported bank accounts, unreported income and/or failure to file foreign bank account reports (FBARs), and have assisted an international conglomerate with an IRS examination and IRS appeal of a so-called ‘inversion case’ involving an almost full IRS concession of a multibillion-dollar adjustment. The client base also includes Quest Diagnostics, Deutsche Bank and Elan Pharmaceuticals. San Francisco-based head of state and local tax Charles Moll, Edmund Cohen and Deborah Goldstein are other names to note. Attorneys mentioned are based in New York unless otherwise specified.

At Cooley LLP, Kathleen Pakenham and senior counsel Stephen Gardner negotiated a favorable settlement for dental, medical and veterinary products distributor Henry Schein in a transfer pricing dispute following an IRS determination stating that the client had underreported its 2009-2011 income by more than $120m and establishing penalties of over $16m. The team also acted for RERI Holdings I before the Tax Court to challenge the IRS’s disallowance of a $33m deduction based on a novel interpretation of valuation tables. American Express and Shell are other active clients. Adriana Lofaro Wirtz was made partner in January 2018. All attorneys mentioned are based in New York.

DLA Piper LLP (US)’s recent highlights include acting for the estate of Gerard Basquiat, father of contemporary artist Jean Michel Basquiat, with regard to several issues, including valuation and the applicability of blockage and fractional-share discounts. Ellis Reemer is ‘shrewd, savvy and able to drill down to the essential issues in every case’, and Diana Erbsen, who re-joined the practice in April 2017 from her post as deputy assistant attorney general for appellate and review at the Tax Division of the DOJ, is ‘a brilliant tax attorney and outstanding advocate’. Kathryn Keneally moved to Jones Day in June 2017.

Dentons handles the full spectrum of IRS actions, including appeals, post-appeals, mediations and fast-tracked matters, and represents clients in a wide range of tax-related civil and criminal disputes before the Tax Court, the US Court of Federal Claims and federal district courts. James Mastracchio, who chairs the practice with Jeffry Erney, advised a prominent Caribbean financial institution on a cross-border investigation between the US and Caribbean regions. Managing associate Sanpreet Dhaliwal is another name to note. Named attorneys are based in Washington DC.

Vinson & Elkins LLP provides ‘excellent coverage and consistent delivery of high-quality commercial tax advice’. Areas of expertise include the Internal Revenue Code, state and local tax laws, international tax and tax treaties, financial products, accounting methods, partnerships, and tax credits. The ‘technically skillful and robustGeorge Gerachis and David Cole, who are based in Houston, successfully represented Energy Transfer Equity in a dispute in which the Delaware Supreme Court upheld the Delaware Chancery Court’s post-trial opinion confirming the client’s right to terminate a proposed $38bn merger with the lawsuit’s initiator, The Williams Companies, due to the failure of a precedent condition. SoCal SportsNet, Anadarko Petroleum and Core Laboratories are other notable clients.

The ‘excellentAkerman LLP has been assisting Citibank with four litigation matters before the Illinois Department of Revenue concerning refunds of sales tax attributable to sales made in Illinois that resulted in bad debts on private label credit cards. Other key clients include Global Mail/DHL eCommerce and Expedia. Practice heads Peter Larsen and Michael Bowen, David Otero and Chicago-based David Blum are ‘highly intelligent lawyers skilled at litigation strategy’. Attorneys mentioned are based in Jacksonville, Florida, unless otherwise indicated.

Davis Polk & Wardwell LLP’s team advises on, among other things, partnership taxation, securities issuances, international taxation, inter-company pricing, withholding taxes, foreign tax credit issues and deductibility of takeover and divestiture expenses. Mario Verdolini, who divides his time between New York and Washington DC, successfully acted for Citibank before the New York Supreme Court, obtaining the dismissal of a qui tam lawsuit filed against the client for an alleged violation of the New York False Claims Act, with the plaintiff in the case asking for $2.4bn in damages. PepsiCo and General Electric are other notable clients.

Greenberg Traurig, LLP is known for its expertise in eggshell audits, employment tax examinations and appeals, offshore voluntary disclosures, tax fraud and tax compliance matters, as well as tax disputes at the domestic and international level. The practice is headed by New York-based Barbara Kaplan. New York’s Scott Fink and San Francisco-based Bradley Marsh and Michelle Ferreira are other key contacts.

Hogan Lovells US LLP acts for domestic and international clients in tax audits and appeals before the IRS, as well as in mediation and litigation, focusing on transfer pricing disputes, restructurings and private letter rulings. The client portfolio includes Translational Research Institute, Rural Telephone Finance Corporation and Open Networking Foundation. Team head Siobhan Rausch, Todd Miller and Christine Lane, who are all based in Washington DC, are the names to note.

Pillsbury Winthrop Shaw Pittman LLP’s practice is led by Michael Kosnitzky, who joined the Miami office from Boies Schiller Flexner LLP alongside Keith Blum in February 2017. The team has been assisting privately held organics management company Harvest Power with a tax controversy matter in Orange County, Florida concerning the limited application in Florida counties of a special assessment rule for pollution control devices to calculate the annual ad valorem tax on tangible personal property. Other key clients include City National Bank of Florida, Cosmetic Dermatology and Lymphoma Research Foundation.

Tax controversy matters handled by Shearman & Sterling LLP include tax treatment of financial products, international corporate reorganizations and cross-border financings, tax accounting methods, transfer pricings and interest computations. Kristen Garry, Robert Rudnick and Nathan Tasso, who was made partner in January 2018, successfully acted for the estate of Monster.com’s founder Andrew McKelvey in a case before the Tax Court involving the extension of two variable prepaid forward contracts, which was followed by an IRS deficiency determination. The team has also been assisting an affiliate of Susquehanna International at the Tax Court, which has potential tax liabilities of nearly $300m. Thomas Johnston is also recommended. Lawrence Hill and of counsel Richard Nessler moved to Winston & Strawn LLP in February 2017.

Sullivan & Cromwell LLP’s team is led by New York’s Ronald Creamer. Washington DC-based of counsel Donald Korb, who has significant experience in tax fraud and tax penalty cases, has been assisting venture capital firm Foundry Group with an IRS audit related to management fee waivers. Other highlights include acting for Fiat Chrysler Automobile in an ongoing EU investigation regarding a transfer pricing arrangement with Luxembourg, which has been declared by the European Commission to be unlawful state aid. Tamares Real Estate and GS Group are other notable clients. Counsel James Gadwood moved to Miller & Chevalier Chartered in September 2016.

At White & Case LLP, Washington DC-based tax global head Kim Boylan has been representing Swiss bank DZ Privatbank before the DOJ in the framework of the department’s program for non-prosecution or non-target letters for Swiss banks. Calpine, Pfizer and The Walt Disney Company are other active clients. New York’s William Dantzler and Washington DC’s Brian Gleicher, who specializes in transfer pricing, are also recommended.

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