| George Clarke is a tax litigator who defends entities and individuals in civil and criminal tax matters in federal court. He has been lead or second chair on cases in the district courts, the Tax Court, the Court of Federal Claims, and several circuit courts. Mr. Clarke has handled major economic substance, transfer pricing, foreign tax credit, criminal tax, TEFRA, period of limitations, and other similar matters for large corporations and high-net-worth individuals. Other elements of his practice include the defense of non-tax federal criminal matters, including allegations of impropriety under the Foreign Corrupt Practices Act (FCPA) and other criminal laws of the United States. More > George Clarke is a tax litigator who defends entities and individuals in civil and criminal tax matters in federal court. He has been lead or second chair on cases in the district courts, the Tax Court, the Court of Federal Claims, and several circuit courts. Mr. Clarke has handled major economic substance, transfer pricing, foreign tax credit, criminal tax, TEFRA, period of limitations, and other similar matters for large corporations and high-net-worth individuals. Other elements of his practice include the defense of non-tax federal criminal matters, including allegations of impropriety under the Foreign Corrupt Practices Act (FCPA) and other criminal laws of the United States.
Mr. Clarke devotes a substantial portion of his time each year to pro bono representation. Most visibly, this work includes the representation of men unlawfully detained by the United States in Guantanamo Bay, Cuba. Based on his advocacy, two of those men were declared to be non-enemy combatants and were temporarily resettled in the island nation of Palau. His pro bono work also includes the representation of criminal defendants who do not have the wherewithal to adequately represent themselves.
Mr. Clarke has published numerous articles in publications such as The International Lawyer, The Tax Executive, The Bureau of National Affairs, and World Corporate Finance Review. He is a regular contributor to the Forbes IRS Watch Blog and the Miller & Chevalier Tax Appellate Blog. In addition, he is a contributing author to The Transfer Pricing Answer Book 2012.
Mr. Clarke is a Certified Public Accountant (inactive) and, prior to becoming a lawyer, served as an enlisted infantryman in the United States Marine Corps. < Brief Bio
- Shell v. United States, Docket No. 2011-1531 (Federal Circuit) (pending – period of limitations issues).
- BCP Trading and Investments, LLC, Docket Nos. 10200-08 and 10201-08 (Tax Court) (pending – economic substance, TEFRA, and period of limitations issues).
- Negotiated a non-prosecution agreement for a foreign banker in a major criminal tax prosecution.
- Al Bihani v. Obama, 2010 U.S. Dist. LEXIS 107590 (D.D.C. Sept. 22, 2010 and October 7, 2010) and Al Bihani v. Obama, 2010 U.S. App. LEXIS 2600 (D.C. Circuit February 10, 2011) (certiorari pending – war on terror and military law issues).
- Estate of James B. Rehrig and Mary Y. Rehrig, et. al v. Commissioner, Docket No. 10067-10 (pre-trial settlement in favor of taxpayer – economic substance, S corporation, and ESOP issues).
Government Experience
- U.S. Marine, 1988 - 1992 (active)
Rankings and Recognition
- Legal 500: Tax: Tax Controversy, 2009 - 2011
Professional and Community Involvement Bar Admissions - District of Columbia
- Virginia
Court Admissions - United States Supreme Court
- United States Court of Appeals for the District of Columbia Circuit
- United States Court of Appeals for the Federal Circuit
- United States Court of Appeals for the Fourth Circuit
- United States District Court for the District of Columbia
- United States District Court for the District of Maryland
- United States District Court for the Eastern District of Virginia
- United States Tax Court
Education - J.D., Georgetown University Law Center, magna cum laude, 2003
- B.S., Edgewood College, magna cum laude, 1998
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