Lawrence B. Gibbs

Larry Gibbs works with his clients to solve some of their most demanding tax problems.  These tax problems may arise during the clients’ tax planning, in the course of their business transactions, when they wish to lobby tax legislation, while they are preparing their tax returns, when they are involved in Internal Revenue Service (IRS) audits, Appeals, rulings, or administrative controversies, or as they prepare for litigation.  For that reason, he often works with other Miller & Chevalier lawyers as well as the clients’ lawyers, accountants, and other professionals with experience in the particular area in which the problem arises in order to develop solutions.

Mr. Gibbs' clients include corporations of all sizes from start-ups to Fortune 10 companies, large Subchapter S corporations, partnerships, mutual funds, real estate mortgage investment conduits, limited liability companies, and other pass-through entities, tax-exempt organizations (including public charities, private foundations, and retirement plans), trusts, wealthy individuals and families, as well as states, territories, and quasi-government entities (domestic and foreign).  More >

Larry Gibbs works with his clients to solve some of their most demanding tax problems.  These tax problems may arise during the clients’ tax planning, in the course of their business transactions, when they wish to lobby tax legislation, while they are preparing their tax returns, when they are involved in Internal Revenue Service (IRS) audits, Appeals, rulings, or administrative controversies, or as they prepare for litigation.  For that reason, he often works with other Miller & Chevalier lawyers as well as the clients’ lawyers, accountants, and other professionals with experience in the particular area in which the problem arises in order to develop solutions.

Mr. Gibbs' clients include corporations of all sizes from start-ups to Fortune 10 companies, large Subchapter S corporations, partnerships, mutual funds, real estate mortgage investment conduits, limited liability companies, and other pass-through entities, tax-exempt organizations (including public charities, private foundations, and retirement plans), trusts, wealthy individuals and families, as well as states, territories, and quasi-government entities (domestic and foreign). 

Over the last twenty years since Mr. Gibbs left the position of IRS Commissioner, the tax problems of his clients have involved U.S. and foreign taxes, and in the United States, their problems have involved income, excise, ERISA, proposed sanctions against tax-exempt organizations and bond issuers, and even estate, gift and other transfer taxes.  To resolve his clients’ tax-related problems, he has dealt with all parts of the IRS, the IRS Office of Professional Responsibility, the U.S. Department of the Treasury, the U.S. Department of Justice, Congress, the Joint Committee on Taxation, other Executive and Congressional agencies, the U.S. Tax Court and other Federal Courts, and various state tax agencies, courts and legislatures.  In addition, he has dealt with foreign tax administrators and competent authorities in the United States and in other countries on behalf of clients.  When requested by clients, Mr. Gibbs has even dealt with the media on their matters.

A major portion of Mr. Gibbs' practice has involved counseling large corporations.  Increasingly, he is working with these companies to address not only their specific tax issues that arise during the planning, compliance, controversy, or litigation phases of the company’s tax function, but also to assist with the overall structure and ongoing operations of the tax function, as well as the company’s long-term tax and financial planning in light of potential changes in the tax laws.

Mr. Gibbs' practice is not based on “who he knows” in government.  Nor is it based solely on his knowledge of the practices and procedures at IRS or elsewhere.  His practice combines his generalist tax background and understanding of the tax law over the last forty-five years with the more specialized knowledge of other tax professionals with whom he works -- at Miller & Chevalier, his clients or elsewhere -- to develop solutions to clients’ problems.  He is not a “tax salesman” who deals in tax products or the services of others.  If he agrees to undertake a client’s problem, he commits to be integrally involved in developing and obtaining the solution.  During the process, he expects to be closely involved in the tax work of, the communication with, and the outcome for the client.

Mr. Gibbs frequently speaks and writes about various subjects involving federal taxation.  In January 2008, he was chosen to deliver the prestigious Griswold Lecture to the American College of Tax Counsel (ACTC).  He lectured on tax topics at the Salk Institute in 2007, the American Tax Policy Institute in 2006, the Tax Council in 2005, the Tax Executives Institute’s Annual Conference in 2005, and the University of London in 2004.  He is a frequent contributor to The Tax Executive published by TEI and Tax Notes published by Tax
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