Since its founding in 1920 as the first federal tax practice in the U.S., Miller & Chevalier has been successfully resolving major tax controversies for the world's largest multinational corporations. Our tax lawyers combine deep technical tax knowledge with a wealth of experience in all facets of controversy and litigation.

We advise our clients on all procedural and strategic aspects of controversies as they evolve, including responding to information document requests, complying with formal document requests, quashing summonses, controlling statutes of limitation, establishing document retention procedures, identifying and protecting privileged documents, and dealing with specific audit adjustments proposed by examining agents.

Some clients seek to resolve disputes short of litigation. And when it comes to those disputes, we are experienced in all forms of administrative dispute resolution, from Fast Track Settlement to Early Referral to Appeals, traditional Appeals, Post-Appeals Mediation, the Compliance Agreement Program (CAP), the Pre-Filing Agreement program, and Advance Pricing Agreements.

But some controversies call for litigation, and when they do we defend our clients with skill and determination. Over the last two decades, Miller & Chevalier lawyers have litigated more than one hundred tax cases in the federal courts. In recent years, we have taken cases to trial in the Tax Court, the Court of Federal Claims, and in district court. And the subject matter of our litigation experience is broad; recent cases have involved tax accounting, cost basis and valuation, treaty benefits, tax credits, interest netting, and transfer pricing. We also have significant experience and a successful track record in appeals to the circuit courts and the United States Supreme Court.

  • 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
  • Assistant Chief of Staff, Joint Committee on Taxation, U.S. Congress
  • Majority Tax Counsel, U.S. House of Representatives Committee on Ways and Means
  • Assistant Legislative Counsel, Joint Committee on Taxation, U.S. Congress
  • 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
  • Attorney Advisor, Legislation and Regulations Division, Office of Chief Counsel, Internal Revenue Service
  • Honors Attorney, Office of the Associate Chief Counsel (International), Internal Revenue Service
  • Honors Attorney, U.S. Department of the Treasury
  • Legislation Attorney, Joint Committee on Taxation, U.S. Congress
  • 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 (National), 2007 - 2018
  • Chambers USA: Tax (District of Columbia), 2003 - 2018
  • Legal 500: Tax: Contentious (US), 2007 - 2018
  • Legal 500: Tax: International Tax (US), 2013 - 2018
  • Legal 500: Tax: Non-Contentious (US), 2013 - 2018
  • U.S. News - Best Lawyers® "Best Law Firms": Litigation - Tax (National), 2011 - 2019
  • U.S. News - Best Lawyers® "Best Law Firms": Tax Law (National), 2010 - 2019
  • U.S. News - Best Lawyers® "Best Law Firms": Employee Benefits (ERISA) Law (National), 2014 - 2019
  • U.S. News - Best Lawyers® "Best Law Firms": Litigation - Tax (District of Columbia), 2011 - 2019
  • U.S. News - Best Lawyers® "Best Law Firms": Tax Law (District of Columbia), 2010 - 2019
  • U.S. News - Best Lawyers® "Best Law Firms": Employee Benefits (ERISA) Law (District of Columbia), 2010 - 2019
  • 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 - 2018
  • International Tax Review: World Transfer Pricing (National), 2014 - 2018
  • International Tax Review: Tier 1 U.S. Firm, Tax Planning Survey, 2018
12.20.2018

On December 13, 2018, the Department of Treasury (Treasury) and the Internal Revenue Service (IRS) issued proposed regulations (Proposed Regulations) under section 59A, the base erosion and anti-ab

Tax Alert