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David B. Cubeta

Dave Cubeta represents large multinational corporate clients in resolving potential Internal Revenue Service (IRS) controversies in audit, negotiating settlements of issues at Appeals, resolving issues in litigation, planning transactions and in advancing tax policy initiatives. Mr. Cubeta’s work, while including a variety of taxpayer industries and subject matters, has often focused on natural resource taxation, joint ventures and the tax treatment of complex financial products and financial transactions. He has extensive experience in financial derivatives taxation, having taught the subject for over 20 years to Masters of Law program students at Georgetown University Law Center.  More >

Representative Engagements|View All

  • Successfully defended the timing and character of gains and losses from hedging programs established by several companies including finance companies and natural resource companies.
     
  • Successfully represented a client to sustain the availability of several billion dollars of energy tax credits from the production of solid synthetic fuel from coal.
     
  • Represented a client in structuring a joint venture and related arrangements for the construction of an LNG export facility.
     
  • Represented a multinational natural resource company restructuring its foreign operations. 
     
  • Represented a multinational manufacturing company in reorganizing its operations in bankruptcy and then obtained confirmation of the effectiveness of the plan through the IRS's Pre-Filing Agreement process.
Government Experience
  • Office of Chief Counsel, Legislation and Regulations Division, Internal Revenue Service, 1977 - 1981
Corporate Experience
Rankings and Recognition
  • Legal 500:  Tax:  Domestic Tax, 2015
  • The Best Lawyers in America®:  Litigation & Controversy - Tax and Tax Law, 2009 - 2017
  • Silver Vicennial Medal from Georgetown University, 2012
Professional and Community Involvement
  • Adjunct Professor, Georgetown University Law Center
  • Member, American Bar Association
  • Member, Section of Energy and Environmental Taxation Committee, American Bar Association
  • Member, Financial Transactions Committee, American Bar Association
  • Member, Planning Committee, Parker Fielder Oil and Gas Tax Conference
Bar Admissions
  • District of Columbia
  • New York
Court Admissions
  • United States Tax Court
  • United States Court of Federal Claims
  • United States Federal Circuit Court of Appeals
  • United States Supreme Court
Clerkships
Foreign Languages
Education
  • J.D., Albany Law School, cum laude, 1977
  • B.A., Colgate University, 1974