Miller & Chevalier has the nation's leading tax accounting practice. Our team includes the most widely cited authority on tax accounting and others with substantial experience in successfully litigating or resolving tax accounting issues on behalf of large corporate taxpayers.

Our tax accounting lawyers advise taxpayers on the full range of tax accounting issues, including LIFO and other inventory accounting methods, Section 199 deductions, capitalization, the deferral of advance payments, installment obligations, depreciation and amortization, accounting for environmental costs, income and expense accruals, the economic performance rules, and the clear-reflection-of-income standard.

Our tax accounting team has decades of experience helping clients plan for audits and managing the audit process across the entire range of accounting methods issues. Our reputation with the IRS and Treasury Department is unparalleled and our lawyers have one of the nation's longest and most impressive track records obtaining positive results for our clients in resolving tax accounting controversies successfully. When it is the client’s objective, we can resolve issues without litigation, at the earliest opportunity, and under the best possible conditions for our clients. But when litigation is called for, Miller & Chevalier is among the best. Our lawyers have been counsel of record in some of the most prominent tax decisions in the tax accounting area.

Recent examples of tax accounting issues our team has tackled include:

  • The exclusion from income of amounts unlikely to be collected;
  • Successfully working with IRS and Treasury to address our clients' needs in the "domestic production deduction" regulations;
  • The application of the inventory accounting rules governing rebates and customer allowances of all types; and
  • Applying the casualty loss rules to massive destruction and other unique circumstances.
  • Commissioner, Internal Revenue Service
  • General Counsel, U.S. Nuclear Regulatory Commission
  • Assistant Commissioner (Technical), Internal Revenue Service
  • Tax Assistant to the Solicitor General, U.S. Department of Justice
  • Assistant to the Solicitor General, U.S. Department of Justice
  • Acting Chief Counsel, Internal Revenue Service
  • Deputy Chief Counsel, Internal Revenue Service
  • Counselor to the IRS Commissioner, Internal Revenue Service
  • Majority Tax Counsel, U.S. House of Representatives Committee on Ways and Means
  • Senior Counsel and Lead Economic Policy Advisor, Senator John D. Rockefeller IV, Chairman of the Senate Commerce, Science and Transportation Committee and Senior Member of the Senate Finance Committee
  • Tax and Trade Counsel, Congresswoman Stephanie Tubbs Jones, Senior Member of the House Ways and Means Committee
  • Advisor to the Assistant Secretary for Tax Policy, U.S. Department of the Treasury
  • Counsel, Subcommittee on the Environment of the U.S. Senate Committee on Commerce
  • Attorney Advisor, U.S. Department of the Treasury
  • Honors Attorney, Office of the Associate Chief Counsel (International), Internal Revenue Service
  • Honors Attorney, U.S. Department of the Treasury
  • Staff Attorney, United States Court of Appeals for the 11th Circuit
  • Legislative Director, U.S. Senator
  • Member, President Barack Obama's Transition Team, Economic and International Agency Review Working Group
  • Chambers USA: Tax Team of the Year, 2016
  • Chambers USA: Tax: Controversy (Nationwide), 2007 - 2020
  • Chambers USA: Government Relations: Specialist Tax Firms (Nationwide), 2019 - 2020
  • Chambers USA: Tax (District of Columbia), 2003 - 2020
  • Chambers USA: Tax: Corporate & Finance (Nationwide), 2020
  • Legal 500: Tax: Contentious (U.S.), 2007 - 2020
  • Legal 500: Tax: International Tax (U.S.), 2013 - 2020
  • Legal 500: Tax: Non-Contentious (U.S.), 2013 - 2020
  • U.S. News - Best Lawyers® "Best Law Firms": Tax Law (National), 2010 - 2021
  • U.S. News - Best Lawyers® "Best Law Firms": Tax Law (District of Columbia), 2010 - 2021
  • International Tax Review "Americas Tax Awards": Americas Tax Policy Firm of the Year, 2012 - 2013, 2015 - 2016 
  • International Tax Review "Americas Tax Awards": Washington, DC Tax Firm of the Year, 2013
  • International Tax Review "Americas Tax Awards": Washington, DC Transfer Pricing Firm of the Year, 2012
  • International Tax Review: World Tax (Washington, DC), 2012, 2014 - 2020
  • International Tax Review: World Transfer Pricing (National), 2014 - 2020
  • International Tax Review: Tier 1 U.S. Firm, Tax Planning Survey, 2018

The IRS's Large Business and International Division (LB&I) recently requested comments from large corporate taxpayers that rely on Revenue Procedure 94-69 to disclose potential tax adjustments

Tax Alert

Almost 18 months after the passage of the Tax Cuts and Jobs Act of 2017 (TCJA), tax executives remain undecided about the law's impact on U.S.