Morgan, Lewis & Bockius LLP acts for major domestic and multinational companies in high-stakes federal and international tax disputes. The team is well versed in APAs, MAP proceedings, fast-track settlement, and other IRS and cross-border dispute resolution mechanisms. The practice is jointly led by San Francisco-based Barton Bassett, who focuses on international tax planning and structuring, and Chicago-based Thomas Linguanti, who advises across IRS examinations, administrative appeals and litigation, alongside Boston-based Daniel Nelson and Megan Bell in New York. Washington DC-based Alex Sadler is a key contact for federal tax controversy, corporate tax planning and transfer pricing.
Legal 500 Editorial commentary
Testimonials
Collated independently by Legal 500 research team.
- ‘Jamie Steele is one of the best attorneys I have worked with in my 40-plus-year career. Jamie’s listening skills and thoughtful advice are extraordinary.’
- ‘The practice is highly experienced, knowledgeable, practical, and responsive.’
Key clients
- Perrigo Company
- TruConnect Communications
- United Global Foods, Inc.
- YA Global Investments, LP
- Innovation Ventures, LLC
Work highlights
Represented Perrigo in a refund action against the United States before the Western District of Michigan involving transfer pricing, economic substance, section 482, and patent prosecution cost issues. The court ruled for Perrigo on all issues, making only modest adjustments to its transfer pricing model.
Representing YA Global Investments in a Third Circuit appeal concerning whether non-US investors were engaged in a US trade or business. The case raises issues relating to financial products, dealer/trader/investor distinctions, tax agency principles, and limitation periods.
Representing Innovation Ventures in Tax Court litigation involving entities associated with 5-Hour Energy. The dispute concerns partnership interest transactions, basis adjustments, deductions, a charitable contribution involving partnership interests, and a proposed 40% valuation penalty, with $516m in basis adjustments and related deductions at issue.
Lawyers
Hall of Fame
The lawyers at the very top of the profession, widely known and respected by peers and clients for their longstanding involvement in market-leading work.
Leading partners
The strongest partners in their field, leading on market-leading deals and endorsed by peers and clients alike.
Tom Linguanti
Practice head
Barton Bassett; Daniel Nelson; Megan Bell; Thomas Linguanti
Other key lawyers
Adam Sadler; James Steele; Rob Donnelly