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Led by Robert Albaral in Dallas, Baker McKenzie LLP’s ‘outstanding’ practice has ‘extreme strength in depth’. The 70-strong team advises on all phases of international and domestic tax disputes. The ‘diligent’ Duane Webber in Washington DC is advising Altera Corporation on a high-profile challenge against the validity of a US Treasury regulation that required cost-sharing participants to share stock-based compensation. In Chicago, Thomas Linguanti and senior counsel Robert Cunningham led Medtronic in a $1.4bn transfer pricing dispute, and Andrew Crousore in Palo Alto successfully represented Nike in challenging Internal Revenue Service (IRS) deficiency notices regarding the allocation of taxes. The team represents a range of Fortune 500 companies, including names such as Starbucks, American Airlines, Pfizer and The Boeing Company. Palo Alto-based Scott Frewing has ‘a wealth of expertise’, Mark Roche in San Francisco is ‘excellent’ and Mark Oates and Susan Ryba in Chicago are also recommended. Colleen Romero in Chicago and Phillip Taylor in Washington DC were recently promoted to partner.

Caplin & Drysdale, Chartered’s ‘superb’ team advises on a range of criminal proceedings, offshore disputes and civil matters. The firm continues to represent hundreds of US citizens and residents in compliance issues arising from their failure to report foreign bank accounts, trusts and businesses. It is also advising the president and CEO of a company on an IRS criminal investigation into the failure to withhold and remit payroll taxes to the IRS. The ‘sharpScott Michel heads the group in Washington DC, where Christopher Rizek is ‘excellent’ and Niles Elber is also recommended. The ‘brilliantMark Allison leads the New York-based team, where Rachel Partain and Zhanna Ziering were recently promoted to the partnership.

Mayer Brown’s ‘superb’, 40-strong team is adept in high-profile tax litigation and is led by Joel Williamson and Thomas Kittle-Kamp in Chicago and Brian Kittle in New York. A team led by Kittle-Kamp is acting as co-counsel to Altera Corporation in its response to the IRS’s appeal of the US Tax Court’s decision invalidating some of the IRS’s transfer pricing regulations. Scott Stewart (Chicago) and Williamson represented Tyco International in the Tax Court in a dispute regarding the deductibility of interest paid by Tyco entities in the US to a related finance company in Switzerland. Boston Scientific, Tribune Media and Eaton Corporation are also clients. Chicago-based John Hildy and Palo Alto-based Larry Langdon are other key figures in the team. Jonathan Hunt in Chicago was promoted to partner. Chuck Hurley moved to Norton Rose Fulbright US LLP.

McDermott Will & Emery LLP’s ‘outstanding’, 40-partner practice is led by Dallas-based Todd Welty, who is ‘first class’. In addition, the team has feet on the ground in Chicago, New York and Houston, and specializes in tax controversy, administrative appeals and tax litigation. Welty successfully acted for the John M Alterman Trust in a transferee liability case involving the sale of a family business. Led by the ‘focusedRobin Greenhouse and others, the firm represented Illinois Tool Works in multimillion-dollar litigation regarding debt-equity issues and the substance of a repatriation transaction. In Chicago, Jane May is noted for state and local tax (SALT) matters, Roger Jones is ‘held in very high regard’, and Andrew Roberson is rated ‘excellent’. In April 2017, Mark Martin joined KPMG. Since publication, Jean Pawlow has moved to Latham & Watkins LLP.

The ‘exceptional’ department at Morgan, Lewis & Bockius LLP is led by Barton Bassett in Silicon Valley and Joshua Brady in Washington DC. The team is adept at handling complex disputes involving the IRS and state tax authorities, and is particularly noted for its transfer pricing expertise, in which Washington DC-based John Magee and Sanford Stark and Silicon Valley-based Bassett, Rod Donnelly, John Ryan and Bill Colgin are key figures. Magee and Stark are leading The Coca-Cola Company in a transfer pricing dispute, and are also acting for Amazon in multibillion-dollar transfer pricing litigation with the IRS. Alex Sadler, who recently joined from Ivins, Phillips & Barker, and the ‘formidable’ Sheri Dillon are also singled out for praise; both are based in Washington DC.

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Based across several of its key US offices, Skadden, Arps, Slate, Meagher & Flom LLP’s team has a ‘fantastic reputation for tax controversy and litigation work’. Raj Madan (Washington DC), Nathaniel Carden (Chicago) and Emily Lam (Palo Alto) continue to advise Amazon on its high-profile transfer pricing dispute with the IRS. Madan is also advising Deutsche Bank Securities on an ongoing dispute involving a case brought by the Department of Justice (DOJ) in the Southern District of New York, seeking to collect a third party’s tax debt. Eaton Corporation, Ingersoll Rand and Marvel Entertainment are also clients. Among the ‘first-rate’ team, Washington DC-based Fred Goldberg, John Williams and Chris Bowers are also singled out for praise. Eric Sensenbrenner in Washington DC and Stuart Finkelstein in New York co-head the global tax group. Kenneth Gideon sadly passed away.

Based across the firm’s Atlanta, Houston, Philadelphia and San Antonio offices, Chamberlain, Hrdlicka, White, Williams & Aughtry is ‘an excellent tax litigation firm’ with ‘great trial lawyers’ and ‘top-quality individuals’. The 18-partner team represents taxpayers in all phases of the controversy and litigation process before the federal, state and local tax authorities. Larry Campagna is ‘one of the finest tax controversy lawyers in the country’ and advised US Exploration and Geo Fluorite Partners on a US Tax Court matter involving $100m of tax, penalty and interest. Kimberly-Clark Corporation, Live Nation Entertainment and UPS are also on the firm’s client roster. The ‘fantastic’ David Aughtry in Atlanta, George Connelly in Houston, and Philip Karter in Philadelphia jointly head the team. Former trial attorney at the DOJ’s Tax Division Kevin Sweeney joined as senior counsel in 2016, and Jaime Vasquez was promoted to partner.

The ‘astuteMiriam Fisher in Washington DC, who has a ‘fantastic reputation’, heads the ‘experienced’ and ‘top-quality’ team at Latham & Watkins LLP, which is active across administrative proceedings and litigation, and has extensive experience in the US tax courts. DreamWorks Animation and its subsidiaries retained the team for a Court of Federal Claims matter regarding transition rules following the repeal of the extraterritorial income regime. The team is also advising Vento on a case which examines the nature of a ‘partner’ for federal tax purposes, and is acting for the Estate of Siegal in several pending tax cases involving oil and gas investment transactions. Brian McManus is ‘very able’ and is based across the firm’s Washington DC and Boston offices. Gerald Kafka has retired. Since publication, Jean Pawlow has joined the Washington DC office from McDermott Will & Emery LLP.

Washington DC-based firm Miller & Chevalier Chartered has an ‘excellent reputation’ and is particularly noted for its litigation prowess. Headline work for the ‘strong and very able team’ included representing The Coca-Cola Company in a case contesting multibillion-dollar IRS transfer pricing adjustments, and advising Starr International Company on a district court refund suit involving the determination of benefits under the US-Switzerland tax treaty. The team also acts for Washington Mutual in a number of disputes involving loss deductions for abandoned intangible assets. Among the team, Kevin Kenworthy is a ‘very experienced’ tax litigator, and Maria Jones and Steven Dixon are also noted. George Hani chairs the tax department. Counsel James Gadwood joined from Sullivan & Cromwell LLP in 2016. Since publication, Kevin Downing has left the firm.

Eversheds Sutherland (US) LLP has a ‘renowned practice’ with expertise spanning international, federal, state and local tax law. The team represents Comcast in various tax controversy issues, including in litigation linked to the costs-of-performance apportionment method and disallowance of interest deductions, and a dispute defeating a state’s attempt to impose a tax on Comcast’s intangible property. Cox Enterprises retained the team for several matters, including two successful corporation franchise tax settlements. Jerome Libin and Mark Smith in Washington DC co-head the team. Atlanta-based lawyers Thomas Cullinan, Eric Tresh and Jerold Cohen, who has a ‘longstanding reputation’, are also noted. Bradley Seltzer joined from Deloitte Tax in 2016.

The ‘client-friendlyBaker Botts L.L.P. has a ‘very effective’ tax controversy and litigation practice that acts for various entities in the energy and technology fields in complex disputes, regularly working on federal as well as SALT matters. It also represents taxpayers in estate, gift and transfer tax controversies with the IRS. The team presented the oral argument in MoneyGram’s appeal to the Fifth Circuit regarding a Tax Court decision that it was not a bank for the purposes of sections 581 and 582 of the US Tax Code. Group head Richard Husseini is based in Houston and has ‘excellent understanding of the appeals process’. Also based in Houston is the noted Renn Neilson.

Fenwick & West LLP’s ‘impressive’ California-based team often acts for corporates in tax litigation, representing clients in the US Tax Court, the Court of Federal Claims, and various courts of appeals. The firm is also noted for its ‘strong’ transfer pricing expertise. The ‘first-rate’ David Forst is the firm’s tax chair and the ‘experienced’ Kenneth Clark leads the tax litigation practice, where notable individuals also include Jim Fuller, Jennifer Fuller, Andrew Kim and Larissa Neumann, who has a ‘growing reputation’. Consulting attorney Ron Schrotenboer is also recommended.

Kirkland & Ellis LLP’s ‘extensive’ tax controversy practice is particularly noted for its transfer pricing prowess. The firm has extensive experience in the airline industry and is representing Delta Air Lines in a dispute with the Regional Transportation Authority regarding sales and use taxes on jet fuel. The team is also is the lead tax adviser in numerous major bankruptcies and restructurings. Clients include Energy Future Holdings, Corus Bankshares, GFGI Liquidation Trust and BPCP Dispatch Holdings. Chicago-based partners Natalie Keller, Todd Maynes and JoAnne Nagjee are the key names.

Morrison & Foerster LLP’s ‘outstanding’, dedicated SALT practice is based out of New York and California, but has a nationwide reach. New York-based Mitchell Newmark and Craig Fields (a ‘very accomplished litigator’) led Lorillard Licensing Company in the New Jersey Supreme Court, which upheld the Appellate Division’s decision that New Jersey may not apply dual nexus standards for throwout purposes. Netflix, Agilent Technologies and Astoria Financial Corporation are also clients. New York-based Hollis Hyans and San Francisco-based Andres Vallejo are also recommended. The firm’s federal tax practice handles cases before the IRS, the Tax Court, the Federal Claims Court, and other federal trial and appellate courts, where of counsel Edward Froelich in Washington DC is recommended. In New York, senior counsel Paul Frankel is also singled out for praise. Gregory Roberts joined Reed Smith LLP in 2017.

Norton Rose Fulbright US LLP provides ‘an excellent client experience’ and the team has an ‘encyclopedic understanding of the law’. It advises on multi-jurisdictional competent authority disputes, audits, IRS appeals, summons enforcement, and state and local property tax disputes. The team represented the Allbritton family estate in a tax refund suit against the IRS regarding the valuation of art, and is also acting for Bluescape Resources in an IRS dispute. Diamond Offshore Drilling, Noble Corporation and Baker Hughes are also on the firm’s client roster. In Houston, Charles Hall is ‘very experienced’, Jasper Taylor is ‘clear, concise’ and ‘extremely organized’, and Robert Morris is ‘fantastic’. Chuck Hurley recently joined the firm’s Washington DC office from Mayer Brown.

Reed Smith LLP has ‘vast’ state tax controversy expertise and is also noted for its experience in federal matters. The 13-partner team spans seven US offices and recently obtained a multimillion-dollar cash refund for Dick’s Sporting Goods after a sales tax dispute. The team also assisted the Unclaimed Property Professionals Organization with urging the Supreme Court to hear a dispute between Delaware, Pennsylvania and Wisconsin regarding unclaimed property law. FedEx Corporation, General Motors Corporation and Wells Fargo Bank are also clients. In Philadelphia, Lee Zoeller heads the team, where Frank Gallo and Kyle Sollie are recommended for state tax matters. Gregory Roberts recently joined the New York office from Morrison & Foerster LLP.

Steptoe & Johnson LLP’s ‘excellent’ department is led by Robert Rizzi and Lisa Zarlenga from Washington DC. The team advises on contentious state and federal matters and recently achieved a victory for Delphi Automotive in securing an IRS Office of Appeals determination that Delphi is a UK company, reversing a prior IRS determination that Delphi should be treated as a US company; the firm acted as co-counsel alongside Sidley Austin LLP. The team is also advising Gannett Corporation in a case involving a matter of first impression in Arizona, addressing the scope and application of Arizona’s sales tax deduction for sales of machinery and equipment used directly in manufacturing. Key individuals Greg Kidder, Phil West, Rob Kovacev and Walker Johnson are also based in Washington DC, while Pat Derdenger is based in Phoenix.

Thompson & Knight LLP’s experience spans IRS audits, administrative proceedings, assessment appeals, federal and state tax refund and deficiency litigation, as well as disputes concerning foreign companies. The team is noted for its strong footing in the petroleum, hard minerals and natural resources sectors and acts as special counsel to Energy Future Holdings in a range of tax-related matters. It also advises Texaco on two cases docketed in the Court of Federal Claims. Dallas-based Mary McNulty (who is ‘very highly regarded’) and Emily Parker are key figures in the practice.

Cooley LLP’s ‘well-respected’ contentious tax practice handles federal, state and international tax disputes, and is led by senior counsel Stephen Gardner from New York. The team has litigated in the US Tax Court, the Court of Federal Claims and in other federal and state jurisdictions, and has handled tax appeals in federal circuit courts. Tax co-chair Kathleen Pakenham is ‘brilliant’. Todd Gluth in San Diego is also recommended.

The timing and quality is outstanding’ at Covington + Burling LLP, where the tax controversy practice is led by Washington DC-based Daniel Luchsinger. The team is advising Boston Bruins on a matter before the US Tax Court involving the deductibility of meal expenses and acted for Shea Homes before the Ninth Circuit regarding the government’s appeal of Shea Homes’ victory before the Tax Court. Bacardi, Bristol-Myers Squibb, Coty and IBM are also clients. In Washington DC, Lee Kelley, Emin Toro, Jeremy Spector, and Sean Akins, who was recently promoted to partner, are recommended. Starling Marshall, a former trial attorney in the US DOJ’s Tax Division, joined the New York office as special counsel.

DLA Piper LLP (US) delivers ‘an excellent service’ and represents clients in federal, state, local, civil and criminal tax audits, appeals and litigation. It also advises multinational companies on international tax audit issues. Michael Patton in Los Angeles is noted for his transfer pricing expertise and led the US sub and Swiss parent of a transportation and logistics company in its US-Switzerland advance pricing agreement renewal, involving commodity trading. The Bill, Hillary and Chelsea Clinton Foundation is also a client. In New York, Ellis Reemer is praised by clients. Since publication, Kathryn Keneally has moved to Jones Day .’

The Washington DC-based team at Dentons represents clients in all phases of civil and criminal tax controversy against the IRS. The team successfully represented Cayman National Corporation and its subsidiaries in a DOJ tax investigation. James Mastracchio co-chairs the department alongside Jeffry Erney, who joined the team from Baker & Hostetler LLP in February 2016.

Sidley Austin LLP’s ‘very responsive, highly knowledgeable and practical’ department represents clients in federal and state tax disputes nationwide, and is also recognized for its cross-border expertise. In addition, the team handles internal investigations involving tax issues. Alongside co-counsel Steptoe & Johnson LLP, the team successfully advised UK-domiciled Delphi Automotive in connection with the IRS assertion that it should be treated as a US domestic entity. It is also representing Citigroup in state court litigation regarding Louisiana franchise tax apportionment methodology. Matthew Lerner in Washington DC, and senior counsel Jay Zimbler in Chicago head the team.

The ‘very responsive’ group at Sullivan & Cromwell LLP houses ‘expert and experienced partners’ and also draws on the wider experience of its litigation group. The team is involved in all levels of dispute resolution, from the audit level and IRS appeals to court litigation, and is acting for Ferrari and Fiat Chrysler Automobiles in an ongoing EU state aid investigation. EFH Official Committee, Foundry Group and GS Group are also clients. The group is led by Washington DC-based of counsel Donald Korb, who has ‘longstanding experience’, and New York-based Ronald Creamer. James Gadwood recently joined Miller & Chevalier Chartered.

Winston & Strawn LLP’s expertise spans federal, state and local tax matters. The team advises Elan Pharmaceuticals in various states in several cases of first impression involving a number of high-profile biotech industry issues, and acts for Schlumberger Technology in an income tax appeal before the Alaska Supreme Court. Chicago partners Lou Weber (chair of the tax practice) and Jim Lynch both have market-leading practices in tax controversy and planning. The ‘exceptionalCharles Moll in San Francisco leads the SALT practice. Amit Kalra joined Sheppard, Mullin, Richter & Hampton LLP in April 2017.

Based across its New York and Washington DC offices, the ‘well-versed’ team at Davis Polk & Wardwell LLP handles a range of tax controversy matters, including litigation, administrative proceedings, alternative dispute resolution and risk management, and its client-base includes names such as PepsiCo. Department head Mario Verdolini has a ‘fantastic reputation for contentious tax matters’.

Greenberg Traurig, LLP’s nine-strong tax audits and litigation department is well versed in federal, state and local tax disputes. The team delivers advice on sensitive audits, tax compliance and reporting, compromising tax debts, reporting positions, employment tax issues and contested tax refunds. In New York, the ‘well-respectedBarbara Kaplan heads the team, and Charles Simmons and Scott Fink are also recommended.

Hogan Lovells US LLP handles contentious matters before the IRS, the state tax authorities and various courts. It also acts for domestic and international clients in tax audits and appeals. The firm has particular expertise in tax-exempt organizations. Clients include Open Networking Foundation, Rural Telephone Finance Corporation and Aflac. Team head Siobhan Rausch is based in Washington DC, where Christine Lane was recently promoted to partner and Todd Miller is also recommended. In New York, Howard Topaz and Scott Friedman are other noteworthy names.

Pillsbury Winthrop Shaw Pittman LLP successfully represented a high-net-worth individual in a major California personal income tax case at the California State Board of Equalization and advised two major multinational corporations in a long-running California corporate income tax dispute with the Franchise Tax Board. Amazon, Apple and BNP Paribas are also clients. In San Francisco, Jeffrey Vesely is head of the SALT group, while William Bonano heads the firm’s federal tax controversy and tax policy practice. James Chudy in New York heads the global tax team. Eileen O’Connor left to establish her own firm.

Vinson & Elkins LLP’s tax controversy practice is led by Houston-based George Gerachis and the team has a firm footing advising energy sector clients, as well as clients involved in technology, transport, financial services and other areas. Its expertise spans matters including international tax, state and local tax, the Internal Revenue Code, tax treaties, accounting methods, partnerships, tax credits and valuation issues. In recent work, the firm advised Energy Transfer Partners in a case in Delaware Chancery Court over its merger agreement with the Williams Companies.

The ‘talented’ transfer pricing and tax controversy practice at White & Case LLP is primarily focused on domestic and international civil tax disputes, but also covers criminal tax matters. The team regularly appears before the IRS on behalf of taxpayers in a broad array of disputes. In Washington DC, Kim Boylan is global tax head and Brian Gleicher is noted for transfer pricing and tax treaty issues.

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