
DLA Piper LLP (US) sees continued expansion in the breadth of its tax controversy offering, with the team active in all aspects of sophisticated, challenging tax disputes, at the international, federal, state, and local levels. The firm has a strong SALT capability, headed up by Naftali Dembitzer and David Pope in New York, along with Hugh Goodwin in Palo Alto. The broader tax practice is led from New York office by Diana Erbsen and Ellis Reemer, who both have experience in senior leadership positions in the DOJ’s Tax Division and the IRS Advisory Council, as well as in the IRS Office of Chief Counsel. Henry Cheng in San Francisco is a prominent tax litigator, with recent work encompassing a complex bankruptcy dispute for medical technology company UpHealth Holdings, a significant Tax Court win concerning death benefit proceeds from life insurance policies, and a major cross-border transfer pricing dispute. Victoria Gu in Palo Alto is also a key contributor to the practice. In 2024, the firm hired transfer pricing expert Steve Dixon in Washington DC from Steptoe LLP.
Legal 500 Editorial commentary
Key clients
- YA Global Investments LP
- UpHealth Holdings
- The Brink's Company
- Gigamon, Inc.
- Triangle Peak Partners, LP
- Hilton Domestic Operating Company, Inc. [Hilton Hotels]
- Synopsys, Inc.
- FTI Consulting
- Yamaha Corporation
Work highlights
- Led the filing of a motion on YA Global’s behalf for reconsideration, while awaiting the Tax Court’s second opinion 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.
- Representing Thrasys, a CA-based medical information management company, in a Tax Court litigation with the IRS.
Lawyers
Leading partners
The strongest partners in their field, leading on market-leading deals and endorsed by peers and clients alike.

Leading associates
Leading associates with regular involvement in their team's key work, and recognition from peers or clients as being ones to watch.
Practice head
Ellis Reemer; Diana Erbsen
Other key lawyers
Henry Cheng; Steve Dixon; Victoria Gu; Naftali Dembitzer; Hugh Goodwin; David Pope