Tax

Miller & Chevalier was founded in 1920 as the first federal tax practice in the United States. For nearly 90 years, the firm has successfully represented the most sophisticated corporate clients in all facets of federal income taxation. Miller & Chevalier’s Tax department serves clients headquartered in every corner of the U.S. and throughout the world and over the past several years has represented more than one third of the Fortune 100 and one quarter of the Global 100. Our clients come to us to solve the thorniest of tax issues, and we have litigated many of the most significant tax cases on record.

We resolve issues in Washington at their ultimate source because of the experience and knowledge that we have gained over the years from working in the government, working cooperatively with the government, and challenging the government when required to represent our clients effectively. Our Tax department includes many lawyers with experience at the Internal Revenue Service (IRS), U.S. Department of the Treasury, U.S. Department of Justice, the United States Tax Court, and on Capitol Hill. With its office centrally located next door to the Department of the Treasury and blocks away from the IRS and Capitol Hill, the firm routinely helps its clients navigate Washington bureaucracy and successfully resolve issues before they develop into costly legal problems.

Our tax controversy practice solves clients’ most difficult problems within the IRS administrative process and in the courts. Moreover, the firm’s tax planning and consulting practice regularly handles all of the U.S. federal tax aspects of complex, multi-billion dollar, multinational transactions. Whether in controversy or consulting, our tax lawyers have a broad range of technical experience and industry background, spanning financial products and structured finance, international tax, tax accounting, corporate tax, partnership tax, S corporations, transfer pricing, criminal tax, tax policy, tax credits and incentives, taxation of natural resources, and withholding tax issues. We apply these technical skills in multiple venues: corporate boardrooms, Treasury conference rooms, the halls of Congress, the IRS National Office, the IRS Office of Professional Responsibility, IRS Appeals and Examination offices throughout the country, and in the United States Tax Court, the United States Court of Federal Claims, multiple United States Federal District Courts and Courts of Appeal, and the United States Supreme Court.

Government Experience
  • Commissioner, Internal Revenue Service
  • Acting Chief Counsel, Internal Revenue Service
  • Deputy Chief Counsel, Internal Revenue Service
  • Deputy Chief Counsel (Operations), Internal Revenue Service
  • Assistant Commissioner (Technical), Internal Revenue Service
  • Assistant to the Commissioner, Internal Revenue Service
  • Deputy Associate Chief Counsel (Litigation), Internal Revenue Service
  • Associate Chief Counsel (Income Tax & Accounting), Internal Revenue Service
  • Special Assistant for Fringe Benefits, Office of Associate Chief Counsel (Employee Benefits & Exempt Organizations), Internal Revenue Service
  • Senior Attorney Advisor, Office of Associate Chief Counsel (Income Tax & Accounting), Internal Revenue Service
  • Senior Attorney Advisor, Office of Associate Chief Counsel (Employee Benefits & Exempt Organizations), Internal Revenue Service
  • Attorney Advisor, Legislation & Regulations Division, Office of Chief Counsel, Internal Revenue Service
  • Senior Attorney Advisor, Office of Associate Chief Counsel (Income Tax & Accounting), Internal Revenue Service
  • Honors Attorney, Office of Associate Chief Counsel (International), Internal Revenue Service
  • Tax Legislative Counsel, U.S. Department of the Treasury
  • Deputy Tax Legislative Counsel, U.S. Department of the Treasury
  • Associate International Tax Counsel, U.S. Department of the Treasury
  • Honors Attorney, Office of the International Tax Counsel, U.S. Department of the Treasury
  • Tax Assistant, Office of the Solicitor General, U.S. Department of Justice
  • Trial Attorney, Tax Division, U.S. Department of Justice
  • Majority Tax Counsel, Committee on Ways & Means, U.S. House of Representatives
  • Assistant Chief of Staff, Joint Committee on Taxation, U.S. Congress
  • Assistant Legislative Counsel, Joint Committee on Taxation, U.S. Congress
  • Legislation Attorney, Joint Committee on Taxation, U.S. Congress
Rankings and Recognition
  • Chambers USA: Tax: Controversy (National), 2007 - 2010
  • Chambers USA: Tax (District of Columbia), 2003 - 2010
Clerkships