| Tom Cryan has extensive experience in the tax, executive compensation, fringe benefits, and employment tax areas. His practice involves consulting with clients, handling tax audits and controversies, and drafting various fringe benefit policies. Mr. Cryan has substantial experience drafting and amending compensation plans and arrangements to comply with Internal Revenue Code Section 162(m). In particular, he focuses on the employee benefits and information reporting area, concentrating on the income and employment tax treatment of settlement payments, statutory fringe benefits, nonqualified deferred compensation and travel benefits, and the deductibility to employers of benefits such as meals and corporate aircraft. Mr. Cryan has also assisted employers with the tax issues associated with wellness programs. In addition, he has substantial experience representing clients before the Internal Revenue Service (IRS) and U.S. Department of the Treasury in connection with policy initiatives. More > Tom Cryan has extensive experience in the tax, executive compensation, fringe benefits, and employment tax areas. His practice involves consulting with clients, handling tax audits and controversies, and drafting various fringe benefit policies. Mr. Cryan has substantial experience drafting and amending compensation plans and arrangements to comply with Internal Revenue Code Section 162(m). In particular, he focuses on the employee benefits and information reporting area, concentrating on the income and employment tax treatment of settlement payments, statutory fringe benefits, nonqualified deferred compensation and travel benefits, and the deductibility to employers of benefits such as meals and corporate aircraft. Mr. Cryan has also assisted employers with the tax issues associated with wellness programs. In addition, he has substantial experience representing clients before the Internal Revenue Service (IRS) and U.S. Department of the Treasury in connection with policy initiatives.
Prior to joining Miller & Chevalier, Mr. Cryan was of counsel in the North American Tax practice group of Baker & McKenzie LLP. He is a frequent speaker for both the American Bar Association and the Tax Executives Institute (TEI), and has co-authored several articles for both the American Bar Association and the Practicing Law Institute. Mr. Cryan was a member of the George Mason Law Review at the George Mason University School of Law. < Brief Bio
- Represented a Fortune 100 company at IRS Appeals on tax treatment of relocation reimbursements and use of corporate aircraft. IRS conceded the issues in full.
- Obtained more than a dozen Section 162(m) private letter rulings (PLRs) over the last 10 years.
- Assisted a large financial institution in internal restructuring in order to avoid the FICA re-start provisions (and therefore reduce the company’s out-of-pocket employment tax costs) while at the same time addressing the company’s concerns regarding its internal payroll tax administration.
- Represented a large manufacturing company in protesting a large employment tax deposit penalty. Penalty was abated at IRS Appeals.
- Assisted an employer with highly mobile workforce in designing internal procedures for the proper taxation of travel reimbursements and per diem payments.
Professional and Community Involvement Bar Admissions - District of Columbia
- Virginia
Clerkships
- Clerk, The Honorable Joel Gerber, United States Tax Court
Education - LL.M. (Taxation), Georgetown University Law Center, 1999
- J.D., George Mason University, magna cum laude, 1997
- B.A., Washington and Lee University, cum laude, 1994
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