Jaclyn Roeing
Counsel
Jaclyn Roeing concentrates her practice on tax controversy and litigation, representing multinationals and partnerships at various stages of tax disputes, such as audits, administrative appeals, and trial and appellate judicial proceedings. She advises taxpayers in audits before the Internal Revenue Service (IRS), matters before the IRS Independent Office of Appeals, and litigation in the U.S. Tax Court and federal district courts. Her experience covers a wide range of complex tax issues, including transfer pricing, international tax, excise taxes, economic substance, and the validity and interpretation of U.S. Department of the Treasury regulations and other agency guidance. Ms. Roeing is experienced in drafting pleadings and motions, coordinating discovery, responding to government inquiries, supporting expert witnesses, and developing litigation strategy.
Ms. Roeing dedicates a significant portion of her practice to pro bono work. She is a member of the Law Firm Antiracism Alliance, Tax Working Group and has advised non-profit organizations on the filing of tax returns and taxpayer privacy issues. She has also represented low-income individuals on administrative matters before the IRS and the New York Department of Taxation and Finance. Outside of the tax sector, Ms. Roeing helped secure a favorable settlement from the Virginia Department of Corrections in a challenge against the state's use of solitary confinement and its lack of support for prisoners with limited English proficiency.
Prior to joining Miller & Chevalier, Ms. Roeing was a tax associate at a multinational law firm. She began her legal career as a law clerk to the Honorable Michael K. O'Keefe of the DC Superior Court.
Representative Engagements
- Represent energy companies in refund litigation involving the Alternative Fuel Mixture Credit under Internal Revenue Code section 6426(e).
- Represent multinational company in its IRS audit regarding the treatment of intercompany debt and the arm's-length interest rate under Internal Revenue Code section 482.
- Represent pharmaceutical company in mutual agreement procedure (MAP) proceedings regarding foreign-initiated adjustments to fees for intercompany services.
Prior to joining Miller & Chevalier, Ms. Roeing's engagements included:
- Amgen Inc. v. Commissioner, Nos. 16017-21, 15631-22 (Tax Court). Represented taxpayer in its transfer pricing suit regarding the appropriate royalty rate for the license of intellectual property (IP) and manufacturing and distribution rights for biologic pharmaceuticals under Internal Revenue Code § 482. Trial scheduled November 2024.
- Medtronic, Inc. v. Commissioner, No. 6944-11 (Tax Court). Represented taxpayer during remand proceedings in its transfer pricing suit on the appropriate royalty for the license of IP and manufacturing and distribution rights for implantable medical devices under Internal Revenue Code § 482. Opinion issued May 2023. Appeal pending.
- Philadelphia Energy Solutions Refining and Marketing, LLC v. United States, No. 19-510T (Fed. Cl.). Represented taxpayer in refund suit involving the Alternative Fuel Mixture Credit under Internal Revenue Code section 6426(e), including presenting oral argument on the unconstitutionality of retroactive tax legislation.
- Represented renewable energy partnership in matter with the IRS Independent Office of Appeals regarding the valuation of energy property and the calculation of energy investment tax credits under Internal Revenue Code § 48.
- Represented taxpayers before the IRS Independent Office of Appeals regarding the deductions of settlements under Internal Revenue Code § 162, including the deduction of a settlement for claims under the False Claims Act.
Rankings and Recognition
- The Best Lawyers in America®: Tax Law (Ones to Watch), 2024
Affiliations
- Member, Tax Section, American Bar Association
- Member, Tax Community, DC Bar Association
Admissions
State Admissions
- District of Columbia
- New York
Court Admissions
- United States Tax Court
- United States District Court for the District of Columbia
- United States Court of Appeals for the Federal Circuit
- United States Court of Federal Claims
Clerkships
- Law Clerk to the Honorable Michael K. O’Keefe, Superior Court for the District of Columbia, 2015 - 2017
News and Events
Publications
Internal Publication
Monthly Tax Roundup (Volume 3, Issue 4)
Internal Publication