Gibson, Dunn & Crutcher LLP has a sophisticated tax controversy practice handling disputes from IRS examinations and administrative appeals through trial and appellate litigation. The team represents clients across the technology, pharmaceutical and medical device, e-commerce, telecommunications, industrials, and financial services sectors. Sanford Stark leads the Washington DC-based practice and focuses on high-value transfer pricing disputes, foreign tax credit litigation, economic substance challenges, and method of accounting controversies. Saul Mezei advises on transfer pricing, treaty-based disputes, employment tax matters, and nonprofit status controversies at the federal level. Terrell Ussing handles complex domestic and cross-border tax disputes, including valuation and fair market value challenges and business expense deduction cases. Michael Desmond departed the team in February 2025.
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Accolades
Client satisfaction: Lawyer & team quality
Client satisfaction: Billing & efficiency
Client satisfaction: Sector knowledge
Client satisfaction: NPS ®
Key clients
- 3M Company
- The Coca-Cola Company
- Energy Transfer
- KPC Global Medical Center
- Movate / Cybernet
Work highlights
Represented 3M as appellate counsel in its appeal from an adverse decision of the United States Tax Court. The U.S. Court of Appeals for the Eighth Circuit reversed the Tax Court and, in a landmark ruling, became the first appellate court to effectively invalidate a Treasury regulation under 26 U.S.C. § 482.
Represented The Coca-Cola Company in a high-profile docketed transfer pricing case involving approximately $10 billion in income adjustments. The central issue in the case involves transfer pricing, and additional issues include the eligibility to claim Foreign Tax Credits and the effect of foreign legal restrictions on the pricing of controlled transactions. The case is currently pending in the U.S. Court of Appeals for the Eleventh Circuit.
Represented Western Digital Corporation in one of the largest docketed tax cases. The case involved transfer pricing and Subpart F issues, two docketed cases that were consolidated, and more than $3.5 billion in income adjustments plus penalties. The case settled on favorable terms shortly before trial.
Lawyers
Leading partners
The strongest partners in their field, leading on market-leading deals and endorsed by peers and clients alike.
Next Generation Partners
Junior partners with significant recognition from clients and peers in the market and key roles on multiple matters.
Practice head
Sanford Stark
Other key lawyers
Saul Mezei; Terrell Ussing