Tax

• Represent the Coca-Cola Company and subsidiaries before U.S. Tax Court contesting IRS transfer pricing adjustments of $9.4 billion related to the licensing of intangible property to foreign affiliates.
• Represent ExxonMobil Corporation in a $1 billion income tax refund suit, related to handling of a deduction for federal fuel excise taxes involving a blend of ethanol and gasoline.
• Represent a Blue Cross and Blue Shield company before the U.S. Court of Federal Claims in a federal income tax refund suit valued at $185 million, involving a question of statutory interpretation under Section 833 of the Internal Revenue Code. The dispute poses an issue of first impression on which the IRS and taxpayers have disagreed for about a decade.
• Represent a subsidiary of Valero Energy in an excise tax refund suit in the Western District of Texas under section 6426(e) for the Alternative Fuel Mixture Credit. The company is disputing a Revenue Ruling issued by the IRS that mixing butane and other alternative fuels with gasoline does not qualify for the credit. Assisted six other taxpayers with similar claims.
• Represent a company undergoing an extensive examination by the IRS to determine if the insurance program that it established and manages meets the tax law requirements for insurance and whether penalties are appropriate. The program involves qualification of insurance companies under section 831(b), which has been the focus of IRS enforcement efforts in recent years.
• Represent an investment fund with several billion dollars of assets under management in connection with an IRS examination involving management fee waivers.
• Represent the trustee of a foreign trust in connection with an investigation by U.S. and foreign regulators related to purported tax evasion and money laundering. The matter involves the coordination of counsel and activities in multiple offshore jurisdictions and the U.S., litigation in several jurisdictions to obtain access to relevant documentation, and consideration of complex cross-border legal and privilege considerations.
• Assisted two large energy industry groups on issues stemming from the Tax Cuts and Jobs Act of 2017 (TCJA), resulting in investor-owned utilities being carved out of the interest deduction limitation rules and providing a methodology under which they were required to limit the pace at which they return about $100 billion of excess tax reserves resulting from the corporate rate reduction to customers.
• Represent several companies and trade associations before Treasury and the IRS to secure favorable administrative guidance under provisions in the TCJA, including the base erosion and anti-abuse tax (BEAT), the section 965 transition tax, the global intangible low-taxed income (GILTI) regime, the foreign tax credit branch limitation, and repeal of the Subpart F downward attribution rule. These representations involve meeting with senior Treasury and IRS officials, preparing written comments, and providing public hearing testimony.
• Advised a U.S.-based insurance company on the U.S. tax implications of a merger between one of its subsidiaries and a third party and assisted with obtaining a "substantial compliance" private letter ruling from the IRS. This matter presented complex tax issues whose favorable resolution was required for the closing of a sensitive business transaction and the firm was able to secure the ruling on an expedited basis.
• Represent a large multinational corporation in connection with a request for a quadrilateral advance pricing agreement (APA) involving a cross-border cost contribution agreement and four competent authorities.

Chambers USA

• Government Relations: Specialist Tax Firms (USA-Nationwide), 2019 - 2022
• Tax (District of Columbia), 2003 - 2022
• Tax: Controversy (USA-Nationwide), 2007 - 2022
• Tax: Corporate & Finance (USA-Nationwide), 2020 - 2022
• Tax Team of the Year, 2016

Legal 500

• Government: Government Relations (U.S.), 2015 - 2022
• Tax: Contentious (U.S.), 2007 - 2022
• Tax: International Tax (U.S.), 2013 - 2022
• Tax: Non-Contentious (U.S.), 2013 - 2022

International Tax Review

• World Tax (Washington, DC), 2012, 2014 - 2020
• World Transfer Pricing (National), 2014 - 2020
• "Americas Tax Awards": Americas Tax Policy Firm of the Year, 2012 - 2013, 2015 - 2016 
• "Americas Tax Awards": Washington, DC Tax Firm of the Year, 2013
• "Americas Tax Awards": Washington, DC Transfer Pricing Firm of the Year, 2012
• Tier 1 U.S. Firm, Tax Planning Survey, 2018

U.S. News - Best Lawyers® "Best Law Firms"

• Litigation - Tax (District of Columbia), 2011 - 2023
• Litigation - Tax (National), 2011 - 2023
• Tax Law (District of Columbia), 2010 - 2023
• Tax Law (National), 2010 - 2023