Rising Stars

Firms To Watch: US taxes: contentious

The tax controversy team at Alston & Bird LLP is noted for its experience in administrative appeals, as well as appellate litigation and alternative dispute resolution, both through mediation and arbitration.
Chicago-based Moore Tax Law Group, led by respected practitioner Guinevere M. Moore, is highly recommended for its contentious tax practice.

US taxes: contentious in United States

Baker McKenzie LLP

Baker McKenzie LLP fields a large team of tax litigators with experience representing major international and domestic clients in the full range of tax controversies, with expertise at the audit, appeals, and trial court levels. Practice head George Clarke, based in Washington DC, acts on behalf of private individuals and multinational corporations, and has broad knowledge of civil and criminal tax litigation, including international and federal tax matters, as well as transfer pricing. Chicago-based Mark Oates focuses on international tax matters, covering tax treaty interpretation, subpart F, and foreign tax credit. Robert Albaral, of Dallas, who was formerly Chair of the North America Tax Dispute Resolution Committee for the firm, specializes in international tax disputes involving tax authorities. In DC, Duane Webber handles dispute resolution with the IRS and authorities in other jurisdictions. Salim Rahim, also in DC, has experience in transfer pricing matters, and is chair of the firm’s North America Tax Practice Group. The department’s SALT group is led by Maria Eberle, in New York, who advises businesses and individuals on all aspects of litigation matters. New York-based senior counsel Daniel Rosen is a key resource for large case tax litigation and administrative tax controversies, and has significant experience working as part of the IRS.

Practice head(s):

George Clarke

Other key lawyers:

Mark Oates; Duane Webber; Robert Albaral; Maria Eberle; Daniel Rosen; Scott Frewing; Salim Rahim; Lindsay LaCava; David Pope; Scott Brandman

Key clients


Best Buy Stores, L.P.

B&H Photo & Electronics

Federal Express

Meta, Inc. (formerly Facebook)



Schneider Electric

Target Corporation

Valvoline, Inc.


Work highlights

  • Representing Meta in Tax Court litigation regarding transfer pricing for 2010 transferred assets to Meta Ireland, and for additional disputed matters for 2011-2013.
  • Defending Amgen in its dispute with the IRS valued at over USD 10 billion.
  • Representing Federal Express in a refund case for USD 89.15 million.

Eversheds Sutherland

Eversheds Sutherland represents leading multinationals in tax litigation in a broad range of industry sectors, including technology, energy and natural resources, healthcare, and financial services. Robert Chase, who leads the tax group from Washington DC, has more than 20 years experience advising corporations in tax matters, including audits and litigation. Also based in DC are Jeffrey Friedman, a key name for SALT issues, and Daniel Schlueter, whose experience in tax dispute resolution extends to all levels of trial and appeal, in addition to a record of settling cases prior to, during, and after trial. Eric Tresh, in Atlanta, has expertise in SALT matters and specializes in regulated industries such as telecommunications, cable, and electric utilities. New York-based Sarah Paul focuses on federal tax cases, with a record of acting for international corporations and high-net-worth individuals.  Jonathan Sambur, a key name for cross-border tax disputes, joined the DC office from Mayer Brown in April 2021, while senior counsel E. Miller Williams, in Atlanta, was added from Alston & Bird LLP in September 2022. Associate Alla Raykin, also based in Atlanta, is a name to note.

Practice head(s):

Robert Chase

Other key lawyers:

Jeffrey Friedman; Jerome Libin; Eric Tresh; Sarah Paul; Alla Raykin; Maria Todorova; Daniel Schlueter; Todd Betor; David Blair; David Fischer; Dwight Mersereau


‘They have deep knowledge and understanding of our business and the industry we operate in, and the complex multi-state tax issues.’

‘They go the extra mile to deliver timely information and are extremely responsive. They are comprehensive in developing arguments and identifying information that supports our cases.’

Key clients




Charter Communications


Duke Energy

Work highlights

  • Achieved an important franchise tax dispute victory at the Texas Supreme Court for SiriusXM.
  • Won a significant case for Cox Communications at the Virginia Supreme Court, where the Court ruled that the federal Internet Tax Freedom Act pre-empted Fairfax County from imposing its Business Professional Occupation License Tax on Cox’s receipts from internet access.

Latham & Watkins LLP

Latham & Watkins LLP‘s team has expertise in a diverse range of high profile tax matters, including debt-equity and transfer pricing, employee benefits, tax-exempts, penalties and fraud. Practice head Miriam Fisher is well regarded for her record of representing taxpayers in high-stakes federal and state tax corporate controversies, with a history of acting for both multinationals and high net worth individuals. Fisher is based in Washington DC, alongside Jean Pawlow, who has significant experience in high profile tax controversy matters in the federal trial and appellate courts, in addition to alternative dispute resolution. Pawlow has broad sector expertise, and acts for clients in the pharmaceutical, retail, industrial and digital industries. Brian C. McManus, chair of the Boston tax department, specializes in IRS audits, appeals, and criminal investigations, and regularly handles disputes involving cross-border and offshore issues. Also key are Andrew Strelka, who rejoined in September 2021 from the Office of the White House, and Joshua Wu, who likewise returned to the firm in March 2021 from the Tax Division of the US Department of Justice. Strelka focuses on district tax court litigation, IRS appeals, summonses and enforcement, while Wu covers tax accounting disputes, IRS partnership audits, and offshore tax and reporting questions.

Practice head(s):

Miriam Fisher

Other key lawyers:

Jean Pawlow; Brian C. McManus; Andrew Strelka; Joshua Wu


‘They are capable of handling a broad range of issues, from high net worth individuals with FATCA problems to multinational transfer pricing disputes. They bring a collaborative mindset to every engagement, and often work successfully with other firms on major disputes.’

‘Miriam Fisher is one of the leading lights at the tax controversy bar, and has been for as long as I have known her (over a decade). She has an incredible legal mind and ability to convert hopeless causes into wins for her clients — often through out of court deals carefully wrought through relationship and trust building with the other side.’

‘Brian C. McManus began his career as Miriam’s protégé, but has moved well beyond that in the last 10 years. He handles the biggest and most complicated corporate tax controversies, and is Latham tax controversy’s most gifted trial lawyer, having tried cases in federal court, U.S. tax court, and before state tax appeals tribunals — all to successful verdicts.’

‘They operate at the highest levels in terms of technical capability, work ethic and client service.’

‘Brian C. McManus and his team always gives considered and sound advice. He has a wealth of knowledge and experience, which also reassures clients that they are supported in the best way.’

‘Latham has deep tax litigation expertise, with several experienced trial attorneys. The firm has a deeper bench than most firms, allowing it to easily handle complex matters.’

‘Miriam Fisher is an exceptional tax litigator. She couples deep trial experience with an in-depth knowledge of the tax law. Miriam is first-rate.’

Key clients

Microsoft Corporation

Robert “Hunter” Biden


Citigroup Inc.


Occidental Petroleum


Webb Creek Management Group

Work highlights

  • Defending Netflix in numerous putative class action lawsuits brought by a number of cities in the US, alleging that Netflix and other streaming service providers owe franchise fees when their subscribers access video content over Internet connections located in the public rights-of-way.
  • Representing Occidental in a significant US Tax Court litigation relating to the largest environmental remediation settlement in history.
  • Representing Robert “Hunter” Biden, son of US President Joseph Biden, in connection with a DOJ investigation.

Mayer Brown

Mayer Brown‘s ‘exceptional’ tax controversy practice is a leading name for high-profile and high-stakes tax disputes, with significant experience acting before the US Tax Court and other federal and state courts for major domestic and multinational clients. The department includes SALT expertise across all 50 states, and international controversy capabilities across Europe, Asia and Brazil. Chicago-based Thomas Kittle-Kamp, who has deep trial experience in transfer pricing, leasing, partnership, and corporate reorganization cases, co-leads the department alongside Brian Kittle, praised for his ‘unmatched experience, technical expertise, and strategic thinking.‘ Core team members include Chicago-based tax attorney and litigator Joel Williamson, Larry Langdon, a leading name for alternative dispute resolution methods, who works from Palo Alto, and Leah Robinson who leads the firm’s SALT group from New York. John Hildy, in Chicago, has expertise in transfer pricing cases, while Gary Wilcox, of Washington DC, covers controversies arising from complex corporate transactions. Also key are Shawn O’Brien, in Houston, who has a particular focus on the energy industry, and Jenny Austin, of Chicago, who is active in federal tax controversy and litigation in a range of industries, including pharmaceutical, retail, and technology.

Practice head(s):

Brian Kittle; Tom Kittle-Kamp

Other key lawyers:

Joel Williamson; Larry Langdon; John Hildy; Leah Robinson; Paul DiSangro; Gary Wilcox; Shawn O’Brien; Jenny Austin


‘The Mayer Brown tax practice is exceptional. They are technically sound and innovative in developing solutions.’

‘Brian Kittle brings unmatched experience, technical expertise, and strategic thinking to put his clients in the best position. Brian sincerely channels energy to developing trusted relationships.’

‘Jenny Austin – very knowledgeable, can cover a range of tax topics and also willing to bring in other partners if more subject matter expertise is needed. Also, covers tax in an approachable way.’

Key clients

Abbott Laboratories

Eaton Corporation

FMR LLC (Fidelity)

General Mills

Hyatt Corporation

Occidental Petroleum Corporation

Prudential Tribune

Stanley, Black & Decker

Tribune Media Company/Nexstar

Yum! Brands

Work highlights

  • Achieved an extremely rare Bench Opinion for Fidelity in August 2019, and, following this, secured an additional win on appeal on August 5 2022.
  • Achieved a significant appellate win for Eaton Inc. The 6th Circuit affirmed the Tax Court’s opinion that held the IRS abused its discretion in cancelling two Advanced Pricing Agreements.
  • Represented Hyatt Hotels Corporation during a three-week trial in the US Tax Court. The case presents novel issues of first impression related to the tax treatment of customer loyalty programs.

McDermott Will & Emery LLP

McDermott Will & Emery LLP acts in IRS audits, administrative appeals, and trial and appellate litigation for high profile multinational clients, including numerous Fortune 100 companies. The department has strength in SALT matters and transfer pricing disputes, with key expertise in tax disputes in the digital market. Jane Wells May leads the department from Chicago. May focuses on SALT matters for major corporations in the manufacturing, retail, healthcare and energy industries, while Johnson has a practice focused on complex tax disputes, and has experience representing taxpayers in all stages of civil and criminal tax proceedings. Also based in Chicago is Catherine Battin, a SALT specialist with a history of defending internet sellers. Stephen Kranz, in Washington DC, is a key name for matters related to digital taxation, and has expertise in state tax reform. The San Francisco office houses Charles Moll, who is particularly active on SALT matters before the California tax authorities, and Troy Van Dongen, who is active nationwide, and has a background in property taxation. Boston-based Richard Call handles SALT litigation before administrative and judicial bodies.

Practice head(s):

Jane Wells May 

Key clients

Digital Goods and Services Coalition


Federal Realty Investment Trust

GBX Associates



Qatalyst Partners

State Tax After Reform and Recession (STARR) Partnership

The National Association of Manufacturers

US Chamber of Commerce

Morgan, Lewis & Bockius LLP

Morgan, Lewis & Bockius LLP has expertise in many specialty areas, including transfer pricing, benefits and payroll tax, and R&D credits, and is frequently active in litigation for multinationals, foundations, and high-net-worth individuals. The group has particular strength in complex cross-border matters, due to the firm’s extensive international network of offices. Barton Bassett, who splits his time between Silicon Valley and San Francisco, leads the tax litigation practice on the West Coast with Rod Donnelly, in Silicon Valley. Bassett and Donnelly share a focus on the outbound and inbound operations of domestic and foreign multinationals, and cover issues such as transfer pricing matters, Subpart F, and foreign tax credits. Alex Sadler, a leading name in R&D tax credit controversy and litigation, is based in Washington DC, alongside international tax specialist Scott Farmer, federal tax expert Sheri Dillon, and Doug Norton, who made partner in October 2022. Thomas Linguanti, who leads the Chicago practice, covers audits, alternative dispute resolution proceedings, and trial and appellate litigation. John Magee and William Nelson retired in December 2021.

Practice head(s):

Barton Bassett

Other key lawyers:

Alex Sadler; Thomas Linguanti; Michael Kummer; Douglas Norton; Scott Farmer; Rod Donnelly; Sheri Dillon

Key clients

Perrigo Company

George Weiss Associates LLC (GWA)

Western Digital


Best Buy Co., Inc.


Work highlights

Skadden, Arps, Slate, Meagher & Flom LLP

Skadden, Arps, Slate, Meagher & Flom LLP acts for corporations, partnerships, estates, individuals, and government entities facing the full spectrum of tax disputes. The department covers international, federal, and SALT matters, with expertise in audits, administrative appeals, mediation and arbitration, and tax litigation. Raj Madan leads the firm’s tax group in Washington DC, and is well respected for his tax controversy practice, leveraging experience at the federal district and tax courts, as well as all stages of IRS administrative practice. Also in DC are Royce Tidwell, who covers transfer pricing and foreign tax credits, highly experienced counsel Fred Goldberg, and Armando Gomez.  Emily Lam handles complex audits and appeals, and leads the Palo Alto office, which includes Nathaniel Carden and Christopher Murphy, both of whom have expertise in transfer pricing. The team grew in 2022 with the addition of Kat Gregor, who joined the Boston office from Ropes & Gray LLP, and brings experience advising high net-worth-individuals and major corporate clients. Nathan Wacker, in DC, who made partner in 2022, is also a key name. David Foster moved to Kirkland & Ellis LLP in February 2023.

Other key lawyers:

Raj Madan; Royce Tidwell; Armando Gomez; David Foster; Christopher Murphy; Emily Lam; Nathaniel Carden; Fred Goldberg; Kathleen Gregor; Nathan Wacker

Work highlights

Baker Botts L.L.P.

Baker Botts L.L.P. fields a long-established federal tax controversy and litigation team, with strength in the energy, technology, and financial service industries, and a large SALT practice, which is active in state audits, appeals, and litigation. Clients are particularly complimentary of the firm’s aptitude for estate and gift tax controversies, and praise the group’s ‘depth and breadth of expertise.’ State and local tax chair Renn Neilson, based in Houston, covers property, income, and sales tax controversies. Also based in Houston are senior partner John Porter and the ‘fantastic’ Keri Brown, who frequently work closely together on estate and gift tax controversies. Jon Feldhammer works from the San Francisco office, and is active on tax controversies before the IRS, California Franchise Tax Board, and other state agencies. Senior associate Ben Geslison, of the Houston office, focuses on SALT matters. William Gorrod left the firm in February 2024.

Practice head(s):

Renn Neilson

Other key lawyers:

John Porter; Keri Brown; Jon Feldhammer; Ben Geslison


‘They are unique in their skill set–there are many tax attorneys and there are many litigators–there are very few who focus on tax litigation and invest the resources Baker Botts does.’

‘Keri Brown is fantastic–she is practical and very honest with clients–she does not give false hope but knows when and how to give clients the backbone they need to see a good case through. John Porter is simply a legend in the field.’

‘Baker Botts has long been a leader in dealing with complex issues involving family limited partnerships(FLP), estate, and gift tax controversies. They are notable for the depth and breadth of expertise, addressing a diversity of view points, and effectively engaging with clients, co-counsels, and opposing parties.’

‘Keri Brown, partner, has been most excellent providing advice, contending with a diverse set of parties, some very difficult, and very successfully helping to resolve controversies involving a complex set of issues. In consultation, mediation, and negotiations, she is exceptional in collaboratively engaging with others, always composed, professional, and personable.’

Key clients

Archrock Services, L.P.

Cheniere Energy, Inc.

Chesapeake Energy Corporation

Howard Energy Partners

Lockheed Martin Corporation

Lorraine Bean and Northern Trust Co.

Midcoast Energy, LLC

MoneyGram International, Inc.

QEP Energy Company

Sunnova Energy Corporation

Texas Instruments Incorporated

USA Compression Partners LLC

Work highlights

  • Assisting Corpus Christi Liquefaction LLC, a subsidiary of client Cheniere Energy, Inc., with a long-running sales-tax audit of their under-construction multibillion-dollar LNG processing plant.
  • Representing Archrock Services, L.P. in a multi-year sales tax audit, protest, and redetermination in Oklahoma in which the Oklahoma Tax Commission has made a significant policy shift, reinterpreting what have long been treated as non-taxable services, as taxable equipment rentals.
  • Representing Midcoast Energy LLC in more than 40 property-tax valuation suits against county appraisal districts across Texas for the 2019, 2020, and 2021 tax years dealing with inflated appraisals by those counties of pipeline assets purchased in 2018.

Caplin & Drysdale, Chartered

Boutique tax firm Caplin & Drysdale, Chartered is a leading name for the representation of businesses and private individuals in both civil and criminal tax matters, with experience handling domestic and international disputes. The department has notable expertise representing clients with unreported offshore assets, with clients from the US and overseas. Scott Michel, who has over 40 years’ experience representing high-net-worth individuals and corporate clients in major criminal tax matters, co-leads the group alongside Christopher Rizek, whose areas of expertise include captive insurance issues, conservation easements, and estate and gift taxes. Niles Elber covers both civil and criminal tax controversies, and has a long history in offshore compliance matters, a focus shared by Mark Matthews, who has experience in active criminal tax investigations, civil audits, and voluntary disclosures. Also key are Charles Ruchelman, who specializes in corporate income tax and transfer pricing disputes, and Victor A. Jaramillo, who has expertise in international disputes. All lawyers named are based in Washington DC.

Practice head(s):

Scott Michel; Christopher Rizek

Other key lawyers:

Niles Elber; Mark Matthews; Charles Ruchelman; Mark Allison; Victor Jaramillo


‘I have worked with Scott Michel and Niles Elber for many years where there is US tax exposure. They are knowledgeable, accessible and have a deep understanding of the US tax bureaucracy. They also relate well to my clients who are extremely vulnerable.’

Work highlights

Chamberlain Hrdlicka

Chamberlain Hrdlicka represents clients in tax disputes before federal, state, and local tax authorities at all levels. The group is particularly active in litigation, including appeals before the US Supreme Court. The team is led from Houston by co-heads Juan F. Vasquez, Jr., who represents Fortune 500 companies, multinationals and high-net-worth individuals, and Lawrence Sherlock, who has more than 30 years’ experience negotiating and litigating federal tax disputes. Other prominent team members include ‘great counselor’ Larry Campagna, also based in Houston, and Jaime Vasquez, of San Antonio, who covers disputes relating to income, employment, sales, and franchise tax. David Aughtry, in Atlanta, specializes in federal criminal and civil tax disputes, while ‘outstanding attorneyKevin Sweeney, who works from Philadelphia, has expertise in high-stakes IRS audits. Philip Karter handles federal income tax, excise tax, and estate and gift tax, working from Philadelphia alongside SALT national practice co-chair Jennifer Karpchuk.

Practice head(s):

Juan F. Vasquez Jr.; Larry Sherlock

Other key lawyers:

David Aughtry; Philip Karter; Larry Campagna; Jaime Vasquez; Jennifer Karpchuk; Kevin Sweeney


‘Their expertise in tax controversy is incredible. They are leaders in the field.’

‘Kevin Sweeney is an outstanding attorney and a pleasure to work with.’

‘Very efficient, good mix of personnel who complement each others’ talents.’

‘Kevin Sweeney — Understands the government’s approach and is always thinking about how to neutralize it.

‘Larry Campagna — Great counselor, wonderful at communicating the case to his clients and helping them understand their options.’

‘Fantastic group of attorneys.’

‘I work with Larry Campagna and Kevin Sweeney who are both excellent tax controversy attorneys. Larry’s depth and breadth of knowledge is admirable and he has excellent client bedside manner. Kevin brings his experience as the prosecutor to the table which makes him a fantastic asset on any criminal matter.’

Work highlights

DLA Piper LLP (US)

DLA Piper LLP (US) is active at the international, federal, and state & local levels, with expertise in a diverse range of tax mandates, including international transfer pricing disputes, audit defense, and criminal tax matters. Ellis Reemer, who has expertise in both civil and criminal tax disputes, co-leads the team from New York with Diana Erbsen, whose practice is focused on federal and SALT tax controversies and criminal tax matters. In Los Angeles, Michael Patton has significant knowledge of international transfer pricing, with a record of assisting multinational corporations in complex disputes. Tamara Shepard, located in Boston, specializes in handling appeals, and has experience handling issues arising from inbound investment activities for non-US businesses. Other core team members include Joseph Myszka, who works between Silicon Valley and Sacramento, and covers international tax disputes, and the New York-based Naftali Dembitzer, who handles contentious and non-contentious tax matters at the federal and state level. Associate Victoria Gu, in Silicon Valley, is likewise a key name.

Practice head(s):

Ellis Reemer; Diana Erbsen

Other key lawyers:

Michael Patton; Tamara Shepard; Joseph Myszka; Naftalie Dembitzer; Victoria Gu


‘DLA Piper team works effectively and keeps deadlines.’

‘Michael Patton, who leads our engagement team, combines huge technical knowledge with an ability to explain difficult issues in a simple way. He always follows up quickly and provides regular status updates.’

My DLA service team was small, but efficient and mighty. They mastered my company’s facts, including the confused computations of an earlier advisor, and marshaled those facts against the legal rules exceptionally well.’

‘Tamara was not only able to handle the “trees” of the case but also saw the “forest.” In addition, she had the emotional intelligence to manage the strengths and weaknesses of the company’s personnel and build relationships with the ITS team that generated good will and negotiating equity that she used to the benefit of our company.’

‘I have been working with Ellis Reemer and Diana Erbson. Ellis’ lifetime experience in contentious tax matters is invaluable in terms of developing strategy. Diana Erbson’s service with the Internal Revenue Service has provided an invaluable insight into certain policy considerations and procedural action.’

‘I worked with Naftali Dembitzer on a transfer tax audit defense matter. He understood our team’s sensitivity to keeping costs down and we worked together with that in mind. I learned a lot from Naftali about best practices and negotiating tactics and he helped our team achieve a great result.’

‘The practice team, led by Naftali Dembitzer, was highly attentive in every element of our dealings with the tax authorities, and made us feel very confident that our matter with the authorities would be resolved in an efficient and timely manner.’

‘Mr. Dembitzer was particularly helpful in handling our matter. He has a very client-centric approach and, although he is a partner of the firm, he gave us comfort in knowing that he was very much in control of the development of our case, giving it his personal attention as it developed.’

Key clients

YA Global Investments, LP and Yorkville Advisors, LLC

Synopsys, Inc.

Domino’s Pizza

Yamaha Motor Corp.

Conair LLC

Work highlights

  • Representing YA Global, an investment fund focused alternative financing, in an ongoing case where the IRS has claimed that the offshore investors in the Fund had income effectively connected with a US trade or business.
  • Defended Domino’s pizza, a franchisor and a group of its franchisees, in a New York State sales/use tax audit that raised numerous legal issues and dramatically reduced a significant proposed assessment to an immaterial amount of sales/use tax liability.
  • Representing Synopsys, a leading supplier of electronic design automation solutions, in multiple rounds of litigation in Hungary regarding issues arising from its cost sharing arrangements.

Gibson, Dunn & Crutcher

Gibson, Dunn & Crutcher LLP represents clients in a broad range of high-profile tax disputes, including audits, trial court proceedings, and judicial appeals, with additional expertise in alternate dispute resolution methods. Transfer pricing expert Sanford Stark, based in Washington DC, co-leads the practice group with federal tax specialist Michael Desmond, who works from both the DC and San Francisco offices. Stark joined the firm from Morgan, Lewis & Bockius LLP in November 2021, while Desmond joined in May of the same year, and was previously Chief Counsel of the IRS. Other recent additions to the team include Saul Mezei, whose practice covers a broad range of civil tax issues, and Terrell Ussing, who is active for both large multinationals and high-net worth individuals. Both Mezei and Ussing joined the DC office from Morgan, Lewis & Bockius LLP in November 2021. Of counsel Anne Devereaux, who joined the firm in July 2022, was previously deputy associate chief counsel within the IRS.

Practice head(s):

Michael Desmond; Sanford Stark

Other key lawyers:

Saul Mezei; Terrell Ussing; Jeff Trinklein; Anne Devereaux

Key clients

Western Digital Corporation

The Coca-Cola Company

United Therapeutics Corporation

Maxim Healthcare Services

KPC Global Medical Centers

Work highlights

Kirkland & Ellis LLP

Kirkland & Ellis LLP fields a ‘knowledgeable, responsive, and highly effective’ team with experience at every stage of the tax controversy process. The group places emphasis on diverse tax expertise, and as such covers an extensive range of disputes, including transfer pricing disputes, offshore banking issues, and complex audits for prominent clients in the private equity space. Richard Husseini, based in Houston, co-leads the department alongside Natalie Keller, in Chicago. Husseini has experience representing public and private companies and high net worth individuals before the IRS, courts, and other regulatory bodies, while Keller covers audits, appeals, and litigation, with strength in transfer pricing issues. The department has seen recent growth, with David Foster joining the Washington DC office from Skadden, Arps, Slate, Meagher & Flom LLP in February 2023, and David Cole entering the Houston team from Vinson & Elkins LLP in October 2022. Of counsel JoAnne Nagjee, in Chicago, is a name to note.

Practice head(s):

Richard Husseini; Natalie Keller

Other key lawyers:

David Cole; David Foster; JoAnne Nagjee


Knowledgeable, responsive, and highly effective.’

Key clients

HcPerf Holdings BV, owned by Lime Rock

Woodside Partners LP

PCMG Trading Partners XII LP

Kalkhoven/Pettit Trading Partners LP

Kalkhoven/Pettit #2 Trading Partners LP

Work highlights

Miller & Chevalier Chartered

Miller & Chevalier Chartered, based in Washington DC, represents prominent clients in the full range of federal tax disputes, with an aptitude for both litigation and alternative dispute resolution methods. The department is active for major names in the oil and gas, aviation, and pharmaceutical industries, including Shell, British Airways, and United Airlines. George Hani, whose focus is tax accounting issues, co-leads the group alongside litigator Kevin Kenworthy, who has experience in transfer pricing, foreign tax credits, and natural resource issues. Maria O’Toole Jones has significant experience in disputes relating to the taxation of insurance companies, while Alan Horowitz focuses on appellate litigation, and is primarily active in the Supreme Court and federal courts of appeals. Also key are Patricia Sweeney, who has more than 35 years’ experience practicing federal taxation law, federal excise tax expert Adam Feinberg, and James Gadwood, whose broad practice includes representing clients in connection with IRS examinations, and private letter rulings. International tax specialist Lisandra Ortiz is also a name to note.

Practice head(s):

George Hani; Kevin Kenworthy

Other key lawyers:

Maria O’Toole Jones; Lisandra Ortiz; Adam Feinberg; James Gadwood; Robert Kovacev

Key clients

Delek U.S. Holdings, Inc.

British Airways PLC

Equilon Enterprises LLC

Exxon Mobil Corporation

Highmark Blue Cross and Blue Shield

Motiva Enterprises, LLC

Padre Time LLC

Shell Oil Company

United Airlines, Inc.

Valero Energy Corporation

Work highlights

Steptoe LLP

Steptoe LLP represents clients in a wide variety of federal and international tax issues, including transfer pricing, foreign tax credits, and insurance taxation. The department is active in a range of industries, including technology, financial services, and manufacturing, and has key strength in the coal sector. Philip West, based in Washington DC, co-chairs the practice alongside Beth Tractenberg, in New York. West has particular strength in international tax controversies, while Tractenberg specializes in representing private clients. Also in New York are Lawrence Hill, who covers domestic and cross-border civil tax disputes, white-collar investigations, and criminal tax cases, and Richard Nessler, whose focus is representing clients in internal and governmental investigations, and federal tax controversy matters. Key names in DC include Steven Dixon, who litigates federal tax cases in a range of industries including energy, consumer goods, technology and defense, and Matthew Frank, who is a noted authority on transfer pricing. Associate Caitlin Tharp, also of DC, is a key name.

Practice head(s):

Phil West; Beth Tractenberg

Other key lawyers:

Amanda Pedvin Varma; Steven Dixon; Lawrence Hill; Matthew Frank; Richard Nessler; Caitlin Tharp

Key clients

Cross-Refined Coal

Constellis Group


Dillon Trust Co.

American College of Tax Counsel

Work highlights

  • Represented Cross-Refined Coal in a case of first impression in the US Tax Court involving the validity of refined coal tax credits claimed under section 45 of the IRC, and achieved an almost unprecedented bench opinion holding completely in favour of the client.
  • Representing GBX Group in a tax refund suit in the Southern District of Ohio, regarding the assertion of a penalty under section 6707A of the Internal Revenue Code against 35 N. Fourth Street, Ltd.
  • Acting as counsel to the American College of Tax Counsel on a U.S. Supreme Court Amicus Brief in support of Petitioner, in a landmark case involving the attorney-client privilege as it pertains to advice provided by tax lawyers.

Akerman LLP

Akerman LLP represents national and multistate clients in SALT and federal tax disputes throughout the United States, with expertise across a broad range of industries, including the financial, automotive, and technology sectors. The team is also active on emerging tax issues in relation to digital marketplaces and goods. Peter Larsen, who has a background in high stakes tax disputes, and specializes in new technologies and telecoms, co-leads the group from Jacksonville, alongside former state tax auditor, David Blum, who is based in Chicago. Michael Bowen, in Jacksonville, is chair of the firm’s national SALT practice, and acts nationwide on major tax litigation cases. Other prominent names include Stefi George, who works from New York on a broad range of tax controversy and litigation matters, and Miami-based SALT controversy expert, Lorie Fale.

Practice head(s):

Peter Larsen; David C. Blum

Other key lawyers:

Michael J. Bowen; Lorie Fale; Stefi George


‘Akerman LLP is unique because they are able to offer detailed and thorough legal information on automotive leasing and bad debt refunds for automotive consumer loans. It is a specialized area and the information they provide is detailed and extremely helpful.’

‘Akerman LLP associates are very helpful and provide answers either same day or next depending on the time of request.’

‘The team has been a terrific partner for our needs. They have full-service capabilities across the firm that seamlessly are able to engage with our needs. They are incredibly attentive, quick and proactive in helping to meet our legal needs. They are especially collaborative with our in-house team, including other accountants and staff.’

Key clients

Deutsche Post DHL Group

Brookdale Senior Living

Macy’s Retail Holdings, Inc.

Ally Financial (formerly General Motors Acceptance Corporation)

Home Depot USA, Inc.

Capital One



Skechers USA, Inc.,

Element Fleet Management Corp.

Work highlights

  • Represented Brookdale Senior Living (NYSE: BKD) in a case of first impression involving a novel tax stance that the State of Illinois hoped would generate additional millions of dollars in tax revenue.
  • Represented Verizon in litigation with the Florida Department of Revenue and recently received a favorable trial court decision in the case.
  • Represented VASHI LLP before the Massachusetts Supreme Judicial Court and received a landmark favorable ruling that reversed a lower court and held that VASHI did not owe millions of dollars in taxes to the Commonwealth of Massachusetts.

Davis Polk & Wardwell LLP

Davis Polk & Wardwell LLP fields an experienced tax controversy team, active for prominent clients in a broad range of areas, including financial services, pharmaceuticals, and technology. The group is active before federal and state courts and agencies, and has aptitude for alternate dispute resolution methods. Team lead Mario Verdolini, based in New York, has more than 30 years’ experience in the practice area, with a record of litigation, administrative proceedings, appeals, and risk management. Also in New York are Greg Manafort, a key name for criminal tax matters, and counsel Christopher Baratta, who has expertise in transfer pricing.

Practice head(s):

Mario Verdolini

Other key lawyers:

Greg Andres; Christopher Baratta

Key clients

Bats Global Markets



General Electric

National Westminster Bank

Holland & Knight LLP

Holland & Knight LLP represents clients in tax disputes at IRS administrative, federal, and state levels, with additional experience in appeals. The firm’s already substantial offering grew further in 2021 with a merger with Texas firm Thompson & Knight, which expanded the bench of tax attorneys by more than 30%. Among the new additions was Dallas-based co-head Mary McNulty, who has expertise in the oil and gas industry, and regularly represents major clients from this sector in federal tax disputes. McNulty co-leads alongside William Sharp, who works from the Atlanta, Tampa, and San Francisco offices, and advises companies, family offices, and high-net-worth individuals. In Dallas are Abbey Garber, a key name for partnership audits and IRS appeals, and Lee Meyercord, who has experience in property tax disputes and partnership tax issues. Andrea Darling de Cortés, in Tampa, handles international tax disputes.

Practice head(s):

Mary McNulty; Bill Sharp

Other key lawyers:

Abbey Garber; James Dawson; Amish Shah; Lee Meyercord; Andrea Darling De Cortés


‘They are undoubtedly a first-rate and leading team in the US.’

‘Bill Sharp – an incredible work ethic and leads from the front in showing the younger generation how it’s done. Bill is technically strong and also a wonderful strategist. He has seen it all before and is like a fine wine – he just gets better the more experienced he becomes!’

‘Andrea Darling De Cortés – an absolute pleasure to work with. Technically superb and is able to cut through the law and explain matters clearly and take a commercial approach – a first-rate advisor for any US tax contentious matters – clients are already a step ahead by having Andrea on their side!’

Key clients

ExxonMobil Corporation

American Airlines Inc.

Mitsubishi Power Americas Inc.

Partnership for Conservation

Work highlights

  • Representing ExxonMobil in a $1.5 billion case that is one of the most significant tax appeals currently pending in the United States.
  • Representing American Airlines Inc. in a case challenging the failure of the Illinois Department of Revenue to exclude from the Illinois Retailer’s Occupation Tax sales of aviation fuel that were purchased for the purpose of temporarily storing the fuel in Illinois prior to its transportation and consumption thereafter solely outside of Illinois.
  • Representing Mitsubishi Power Americas in a case that examined whether a research tax credit could be claimed where a sales contract allocated the consideration to stock but the parties had elected to treat the transaction as an asset sale under Internal Revenue Code Section 338(h)(10).

Kostelanetz LLP

Boutique civil and criminal tax controversy firm Kostelanetz LLP fields a ‘deep bench of highly regarded and talented attorneys‘ who represent prominent clients in a broad range of disputes. The group covers audits, administrative appeals, and litigation, and has notable expertise in estate and gift tax controversies. Bryan Skarlatos, based in New York, who has more than 35 years’ experience representing corporations and individuals in sensitive and high-stakes tax disputes, co-leads the group with Caroline Ciraolo in Washington DC, whose focus is complex civil tax controversies. Also based in New York are Megan Brackney, who covers both criminal and civil tax controversies, Christopher Ferguson, who represents clients in federal and state courts, and tax litigator Sharon McCarthy. Jay Nanavati, who is a founding partner of the DC office, is also a key name.

Practice head(s):

Bryan Skarlatos; Caroline Ciraolo

Other key lawyers:

Jay Nanavati; Sharon McCarthy; Megan Brackney; Christopher Ferguson


‘In our view, a most recommendable boutique firm. Fully satisfied!’

‘Kostelanetz LLP is a leader in tax controversy and tax litigation. They have a deep bench of highly regarded and talented attorneys.’

‘Bryan Skarlatos is a calming presence for clients who are faced with criminal tax charges. Caroline Ciraolo is a wealth of knowledge and power who fiercely advocates for her clients. Megan Brackney is an incredibly effective advocate.’

Key clients

First Hawaiian Bank

Joseph Insinga

American College of Tax Counsel

Richard Garriott de Cayeux

Fuerst Ittleman David & Joseph, P.L.

Work highlights

  • Serving as counsel of record in three amicus briefs filed on behalf of the American College of Tax Counsel in two conflicting cases involving non-wilful failure to file Reports of Foreign Bank and Financial Accounts (FBARs).
  • Representing Joseph Insinga, (and his estate) who was a whistleblower alleging unreported income and substantial tax liabilities with respect to large multinational corporations and involving the use of offshore multipurpose entities.
  • Representing First Hawaiian Bank, an institutional fiduciary of a trust with assets of approximately $200 million. Kostelanetz serves as tax counsel advising on tax-related fiduciary obligations, applicable periods of limitations, potential tax liabilities and penalties, and the impact of the Federal Priority Act, 31 U.S.C. 3713.

Norton Rose Fulbright

Norton Rose Fulbright advises clients on audits, IRS appeals, competent authority disputes, and SALT litigation. The team is covers advance pricing disputes and transfer pricing, in addition to experience handling a range of novel issues and cases of first impression. Robert Morris, who leads the team from Houston, has expertise in IRS examinations, appeals, and litigation in the US tax and federal district courts. Stephen A Kuntz, also in Houston, represents clients before federal and state courts, with a history of acting on behalf of owners and operators of refineries, chemical plants, and other industrial properties.

Practice head(s):

Robert Morris

Other key lawyers:

Stephen Kuntz


‘Team is very experienced with our industry, oil and gas exploration, and has numerous contacts from which they can draw upon other experiences. Very deep bench.’

‘The persons we work with are creative, flexible and can pivot quickly if the strategy can or should be adjusted for a better outcome. Robert Morris has lead the team from the beginning and has been very effective in bringing necessary resources to bear when needed.’

Key clients

Diamond Offshore Drilling, Inc.

Noble Drilling

HP Inc.

Bluescape Resources Company

Adams Challenge

Dentsply Sirona

Transocean Offshore Drilling

Work highlights

  • Advising the shareholder families in the bankruptcy cases of Purdue Pharma, In re Purdue Pharma, L.P., with respect to tax matters affecting the settlement framework among Purdue and its shareholders and the creditors for a proposed consensual plan in bankruptcy.
  • Representing Bluescape Resources Company LLC, an energy investment company, in US Tax Court challenging the IRS’s disallowance of US$850 million of deductions and losses, plus penalties; including challenging the validity of certain treasury regulations.

Winston & Strawn LLP

Winston & Strawn LLP represents clients in the full spectrum of tax controversy, with experience acting at all levels, from trials in the tax courts and district courts, to the US Courts of Appeals and Supreme Court. The team is led by civil and criminal tax enforcement expert and Susan Seabrook, who covers global tax controversy. Mastracchio works from Washington DC and New York, whereas Seabrook is based solely in DC. Other key names in DC include associate Karl Kurzatkowski, formerly of insurance company Allied World, and associate Zachary Weit, who was previously a judicial law clerk to a Judge of the US Tax Court.

Practice head(s):

James Mastracchio; Susan Seabrook

Other key lawyers:

Zach Weit; Karl Kurzatkowski

Key clients

Norwich Commercial Group, Inc.

Government of the U.S. Virgin Islands

Work highlights

  • Representing an individual in connection with a tax dispute in the 11th Circuit Court of Appeals.
  • Obtained 100% IRS concession for our client, a global insurance company, in connection with IRS proposed adjustments to cross-border transaction exceeding $600,000,000.
  • Representing our client, Norwich Commercial Group, Inc., in connection with U.S. Tax Court litigation adverse to the Commissioner of the IRS.


BakerHostetler’s full-service tax practice covers the full spectrum of tax controversy, including IRS appeals, tax audits, and litigation. The team has strong coverage of SALT issues, a key offering for foreign clients unfamiliar with tax requirements across US states. Jeffrey Paravano, in Washington DC, acts as firm-wide chair of the tax group, covers a broad range of tax controversies and litigation, and is particularly active on multi-jurisdictional matters. Also based in DC are firm chair Paul M. Schmidt, a key name for IRS audits and appeals, Alexander Reid, a specialist in federal tax matters, and Nicholas Mowbray, who made counsel in January 2022. SALT expert Edward Bernert works from Ohio alongside associate David Ebersole.

Practice head(s):

Jeffrey Paravano

Other key lawyers:

Nicholas Mowbray; Edward Bernert; Paul Schmidt; Michelle Hervey; Elizabeth Smith; Alexander Reid; David Ebersole

Key clients

Pacific Gas & Electric (PG&E)

The Sherwin-Williams Company

Progressive Insurance Company

310 Retail LLC

Harbor Lofts

The E.W. Scripps Company

Battery Council International and Association of Battery Recyclers

US Chamber of Commerce

American Red Cross

Fanatics, Inc.


John F. Kennedy Center for the Performing Arts

Work highlights

Blank Rome LLP

Blank Rome LLP is a prominent name for SALT matters nationwide, and regularly represents high-net-worth-individuals and Fortune 50 companies in a broad range of audits, appeals, and litigation. Craig Fields, based in New York, leads the firm’s SALT group, in addition to co-leading the tax, benefits, and private client group. Also based in New York are Nicole Johnson, a SALT specialist who joined from Morrison Foerster in February 2020, and Mitchell Newmark who has experience litigating state and local tax matters before judicial courts and administrative tribunals nationwide. Eugene Gibilaro, who made partner in January 2023, is a name to note.

Practice head(s):

Craig Fields

Other key lawyers:

Nicole Johnson; Mitchell Newmark; Irwin Slomka; Eugene Gibilaro

Key clients

MidState Arc, Inc.

R.J. Reynolds Tobacco Company

Lorillard Tobacco Company

Reynolds Brands Inc.

Vodafone Americas Inc.

Santa Fe Natural Tobacco Company

Work highlights

  • Appealed property tax assessments on behalf of non-profit organization MidState Arc.
  • Appealed denied refund claims filed by Lonillard Tobacco Company between 2002 and 2010.
  • Resolved a series of related tax litigations in New Jersey Tax Court for Vodafone Americas Inc by obtaining a refund of $47 million in addition to previous the return of a denied overpayment of over $30 million paid to the company shortly after we filed the appeals.


Dentons acts on behalf of clients in all phases of tax controversy, with experience facing the IRS and state and local tax departments across the country. The department has expertise in the retail, manufacturing, and energy industries, and handles both criminal and civil disputes. Louisville-based Mark Loyd has experience in state, local, and federal tax issues, with a history in litigation, audit management, administrative protest, and other forms of alternative dispute resolution. Loyd co-leads the department alongside Gregory Rhodes, who works from Birmingham, and who has particular strength in matters related to conservation easements. Other key names include Michelle Levin, of Huntsville, who specializes in federal income tax controversies, and Bailey Roese, located in Louisville, who covers a broad range of tax disputes.

Practice head(s):

Mark Loyd; Gregory Rhodes

Other key lawyers:

Michelle Levin; Bailey Roese

Key clients

Oakbrook Land Holdings, LLC

Ohio Chamber of Commerce

Walgreen Co.

David and Tammy Hewitt

Ventas, Inc.


Kentucky Association of Manufacturers

Good Times USA LLC

Warren Sapp

Pine Mountain Preserve LLP

Work highlights

  • Represented Oakbrook Land Holdings, LLC in a Supreme Court petition filed in October 2022, regarding the question of a regulation’s validity and application of the Administrative Procedure Act to IRS rules.
  • Acted as lead counsel for Wagreens in regard to constitutional questions regarding whether the fair cash value of properties leased by Walgreens should be determined using local market conditions and market rent or above-market contract rent and national sales.
  • Acted for David and Tammy Hewitt in a case which set precedent requiring the Tax Court to reconsider its orders on dozens of motions for partial summary judgment and to deviate from its prior precedent in dozens of additional pending motions.

Jones Day

Jones Day‘s New York based tax controversy team is highly active in both civil and criminal tax disputes, with a varied client list of high-net-worth individuals and multinational corporations. The group has experience at the federal, state and local levels, and works alongside the firm’s global network of tax litigators to provide comprehensive international support. Former Assistant Attorney General of the US DOJ Tax Division, Kathy Keneally, co-leads the department alongside the ‘thoughtful and strategicFrank Jackson, who covers federal and state controversies and litigation. Associate Michael Scarduzio has experience in SALT controversy and criminal tax matters.

Practice head(s):

Kathy Keneally; Frank Jackson

Other key lawyers:

Michael Scarduzio


‘This team brings a unique perspective, with a former Assistant Attorney General of the U.S. Department of Justice (DOJ) Tax Division and a former senior IRS attorney at the helm.’

‘Frank Jackson is one of the most thoughtful and strategic attorneys I’ve ever worked with. He takes the time to really dive into the challenges, makes every effort to see all perspectives, and provide solutions that ultimately save clients time and money.’

‘Exceptionally high quality and personable service. You know this is “your team” to work through any issue of any size.’

‘Kathy Keneally and Frank Jackson are a pleasure to work with – always responsive, always prepared, always engaged.’

Key clients

Robert T. Brockman

Work highlights

  • Representing a high-profile tech CEO in an indictment by the Department of Justice concerning activities in connection with an offshore trust structure.
  • Representing a prominent corporate and securities advisor indicted by DOJ and charged in a 135-count indictment.

Shearman & Sterling LLP

Shearman & Sterling LLP has particular strength in international and cross-border matters, and advises US and foreign clients in a range of areas such as transfer pricing disputes, tax accounting methods, and tax treatment of financial products. The team, based in Washington DC, includes tax litigator Kristen Garry, who has experience handling IRS audits and administrative appeals, and of counsel Robert Rudnick, whose specialty is tax controversy at the administrative level. Richard Gagnon has experience representing prominent clients in federal courts, and in administrative proceedings before the IRS and DOJ.

Practice head(s):

Larry Crouch

Other key lawyers:

Kristen Garry; Robert Rudnick; Richard Gagnon

Key clients

Estate of Andrew J. McKelvey, the founder of Monster.com

Work highlights

  • Secured a major victory, in a case of first impression, in the U.S. Tax Court on behalf of the Estate of Andrew J. McKelvey, the founder of the job search website Monster.com.

Vinson & Elkins LLP

Vinson & Elkins LLP is active in a variety of industries including financial services, technology, real estate, and energy, and acts on behalf of prominent multinational clients. Houston-based co-head George Gerachis has significant experience handling appeals, and representing clients in Tax and Federal District Courts. The group has undergone significant expansion, with Kathleen Pakenham and Adriana Wirtz joining the New York office from Cooley LLP in January 2023. Pakenham, who is a seasoned litigator, has been added as a new co-head of the team, and brings expertise in federal tax matters. Also key is Gary Huffman, in Washington DC, who specializes in the financial, and oil and gas industries.

Practice head(s):

George Gerachis; Katheen Pakenham

Other key lawyers:

Gary Huffman; Adriana Wirtz

Key clients

Energy Transfer LP

HollyFrontier Corporation

KOK Sheridan Way Investments, LLC

Work highlights

  • Representing Energy Transfer LP (ETE) in litigation involving claims by The Williams Companies for billions of dollars in damages and a $410 million termination fee.
  • Filed a lawsuit in Federal District Court, Northern District of Texas on behalf of HollyFrontier (nowHFSinclair) in which HollyFrontier seeks a $47.6 millionincome tax refund.
  • Represented KOK Sheridan Way Investments in a TEFRA partnership case docketed in Tax Court involving complex procedural and jurisdictional issues.

Asbury Law Firm

Asbury Law Firm, based in Atlanta, is a tax controversy boutique with expertise representing corporations and high-net-worth individuals. The firm has particular strength in the defense of syndicated conservation easements and taxpayers facing IRS penalty assessments. Founding partner Anson Asbury leads the team. Asbury has expertise in a broad range of tax litigation matters, including disputes involving tax credits, passive activity losses, penalties, and promoter investigations. Senior counsel Mark Mesler joined the group in July 2022 from Ernst & Young, where he lead the tax controversy practice for the central and southeast US. Brian Gardner represents corporations, partnerships, and high net worth clients, and has experience in all phases of federal tax litigation.

Practice head(s):

Anson Asbury

Other key lawyers:

Mark Mesler; Brian Gardner


‘Asbury Law Firm has emerged as a leader in tax controversy and litigation in Georgia. They are as creative in their legal arguments as they are tough in the courtroom.’

‘Anson Asbury is an excellent leader who has generated excellent results for his clients. Brian Gardner is an emerging leader who is a strong mentor to the young attorneys in the firm.’

Key clients

Pickens Decorative Stone, LLC

David, Jean, and Jessica Walters

Coursey Lake, LLC

Plum 129 Investments, LLC

Hanger Highway 81 Henry 89, LLC

Alicia Coarsey, Tax Xpress of Tifton, LLC

Work highlights

  • Defended Pickens Decorative Stone against motion for partial summary judgment filed by IRS to disallow $25 million charitable deduction in full.
  • Represented taxpayers David, Jean, and Jessica Walters before the tax court in relation to the disallowance of real estate losses as hobby losses under Section 183.
  • Defended taxpayer (Coursey Lake, LLC) against motion for partial summary judgment on qualified appraisal issue.

Morrison Foerster

Morrison Foerster represents clients in audits, appeals, and other dispute resolution proceedings before the IRS and state tax authorities. Team lead Anthony Carbone, based in New York, chairs the Federal Tax practice, and advises a range of domestic and international clients. Of counsel Rebecca Ulich-Balinskas, also in New York, handles SALT controversies at the audit, administrative and judicial levels. Other key names include counsel Edward Froelich, of Washington DC, who has experience in complex corporate refund cases, and Bernie Pistillo, in San Francisco, who specializes in international tax controversy.

Practice head(s):

Anthony Carbone

Other key lawyers:

Rebecca Ulich-Balinskas; Edward Froelich; Bernie Pistillo


‘Has the talent and is available. Very easy to work with – we use a number of their offices’

‘The senior attorneys are talented and available and very easy to work with. Other firms have good skills but are not as available or as easy to work with.’

Work highlights

Pillsbury Winthrop Shaw Pittman LLP

Pillsbury Winthrop Shaw Pittman LLP is well regarded for its work in SALT litigation, and represents prominent clients such as Chevron and Walt Disney in disputes and controversies nationwide. Team lead Jeffrey Vesely and Carley Roberts are based in Northern California, and both have significant expertise in SALT litigation. Robert Merten, in Sacramento, has expertise in income and franchise tax, sales and use tax, and property and transfer tax, while Marc Simonetti, in New York, advises clients across the country in audits and litigation.

Practice head(s):

Jeffrey Vesely

Other key lawyers:

Carley Roberts; Robert Merten; Marc Simonetti


‘Decades of experience in the key attorneys, providing a depth of knowledge and creativity that is necessary to handle complicated state tax matters.’

Key clients

1Life Healthcare Inc.

LendingTree, LLC

Procacci Brothers Sales Corporation

Walt Disney Company, The

Kimberly-Clark Corporation

Moody’s Investors Service Inc.

Fortune 100 Pharmaceutical Company

California Taxpayers Association

Chevron Corporation

Bardia Housman

Work highlights

  • Defeated the New York State Department of Taxation and Finance’s attempt to impose sales tax on 1Life Healthcare Inc.
  • Represented Lending Tree, a leading online lending marketplace operator, to victory before the NYS Division of Tax Appeals in a dispute over whether the operator’s services are subject to sales tax as information services.
  • Represented an Australian couple in a personal income tax case before the California Office of Tax Appeal (OTA) in a case involving a proposed assessment of tax, interest and penalties of more than $3 million related to complex residency and check the box elections.

Sullivan & Worcester LLP

Sullivan & Worcester LLP manages tax controversies at all stages, including audits, administrative appeals, and trial and appellate litigation. The group acts for businesses and individuals in disputes with the IRS and state and local tax authorities, in particular the Massachusetts Department of Revenue. Richard Jones leads the tax group within the firm, and has expertise in SALT litigation. David Nagle, co-managing partner and head of tax controversies and litigation, is active in a broad range of SALT controversy, while Daniel Ryan covers federal and state disputes. Associate Caroline Kupiec is a key name.

Practice head(s):

Richard Jones

Other key lawyers:

David Nagle; Daniel Ryan; Caroline Kupiec


‘This team is the best in the business for Massachusetts tax controversies.’

‘Richard Jones is an excellent litigator. He is our “go to” for Massachusetts litigation.’

Key clients

Akamai Technologies, Inc.

State Street Corporation

Medtronic Microsoft Licensing GP

Hologic, Inc.

TTI, Inc.

American College of Tax Counsel

Tenet Healthcare

Work highlights

  • Represented Oracle in Oracle v. Commissioner of Revenue.
  • Represented Akamai in litigation before the Massachusetts Appellate Tax Board.
  • Represented State Street Bank & Trust Company, together with many of its software vendors, in 21 litigation actions before the Massachusetts Appellate Tax Board seeking tax refunds in the aggregate amount of approximately $7.2m.

White & Case LLP

White & Case LLP leverages its global network of offices to bring clients expertise in both domestic and international tax controversies. The team has particular strength in alternative dispute resolution techniques, and has a record of resolving cases with the IRS during examination or at the Appeals level. Kim Marie Boylan, who is based in Washington DC, acts as head of the tax controversy practice, and was previously head of the firm’s global tax group. Boylan has expertise in litigation and mediation, in addition to the IRS’ administrative appeals procedures and other alternative dispute resolution processes. Brian Gleicher, also of Washington DC, leads on transfer pricing, and is active both within the US and internationally representing multinational clients. Associate Sean Lyons is a name to note.

Practice head(s):

Kim Marie Boylan; Brian Gleicher

Other key lawyers:

Sean Lyons


‘The W&C legal team does a great job of bringing the right mix of partners/experts and associate staff to resolve issues in an efficient manner.’

‘Kim Marie Boylan brings an invaluable mix of technical expertise and practical advice to find appropriate solutions to contentious tax controversies.’

‘It does not matter what the subject matter of the issue is. White and Case quickly dissects the issue, understands the strengths and weaknesses of the company’s position, brings the necessary resources to the table, and drives the issue to favorable resolution.’

‘Brian Gleicher is intelligent, experienced, strategic, and driven. He has used these skills over the last 15 years to drive excellent resolution of tax issues for my company. He is excellent at quickly dissecting issues and communicating the strengths and weakness of tax positions.’

Work highlights

  • Representing Thomas and Beth Montgomery in an action against the Internal Revenue Service seeking to obtain records under the Freedom of Information Act.