Samuel A. Lapin

Sam Lapin represents clients in federal tax matters, with an emphasis on federal tax controversy and litigation. He advises clients across many industries, including technology, manufacturing, telecommunications, financial services, information services, and energy. He has extensive experience achieving favorable resolutions for clients in Internal Revenue Service (IRS) examinations and before the IRS Independent Office of Appeals, including via dispute resolution programs such as Fast Track Appeals and Post-Appeals Mediation (PAM). Where necessary, Sam has represented clients in the U.S. Tax Court, the Court of Federal Claims (COFC), and federal circuit courts of appeal. 

Sam handles significant tax disputes concerning a wide range of domestic and international tax issues. He has been involved in several large matters involving the R&E credit, deductions for foreign-derived intangible income (FDII), basis adjustments to corporate stock, deferred compensation, the section 245A dividends received deduction, and partnership inside basis adjustments. Sam increasingly defends against IRS proposed adjustments based on the application of the economic substance and similar soft doctrines.

Beyond federal tax controversy, Sam advises on international tax planning, including on the documentation of new business arrangements and transfers of intangible property. He also assists in submitting comments to Treasury and the IRS regarding newly enacted legislation, proposed regulations, and other administrative guidance, including guidance for the advanced manufacturing investment (CHIPS) credit, proposed regulations under the BBA centralized partnership audit rules, and proposed changes to the Tax Court Rules of Practice and Procedure. 

Sam regularly speaks at conferences organized by the American Bar Association (ABA) Tax Section and the Tax Executives Institute (TEI) and has published articles in Tax Notes and Law360. He is particularly active in the ABA Tax Section, currently serving as Vice Chair of its Administrative Practice Committee and on the Tax Section's Appointments to the Tax Court Committee. In 2023, Sam received the Tax Section's prestigious John S. Nolan Fellowship for leadership in the tax bar. Sam is also on the board of the Theodore Tannenwald Jr. Foundation for Excellence in Tax Scholarship.

Before joining the firm, Sam clerked for Judge Cary Douglas Pugh on the U.S. Tax Court.