Miller & Chevalier's lawyers excel at advising on the myriad U.S. federal tax aspects of complex, multi-billion dollar, multinational transactions. We are generally consulted for transactions with novel tax issues or that are especially tax-sensitive. We have a unique mix of specialized tax capabilities, extensive transactional experience, and both government and in-house experience. We work collaboratively with in-house specialists and external advisors.

Our client base includes U.S. and foreign-based multinationals, large partnerships, S-corporations, and privately-held companies. We analyze the tax aspects of mergers and acquisitions, spin-offs, partnership, and joint venture transactions and obtain PLRs for our clients when necessary. We assist in the negotiation and drafting of the appropriate documents, often in cross-border contexts. Our tax lawyers have experience in designing and assessing the viability of the tax consequences of innovative financial product transactions, and in developing sophisticated hedging programs for both domestic and multinational operations.

  • Commissioner, Internal Revenue Service
  • Assistant Commissioner (Technical), Internal Revenue Service
  • Tax 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 Commissioner, Internal Revenue Service
  • Majority Tax Counsel, U.S. House of Representatives Committee on Ways and Means
  • Senior Counsel and Lead Economic Policy Advisor, Senior Member of the U.S. Senate Committee on Finance
  • Tax and Trade Counsel, Senior Member of the U.S. House of Representatives Committee on Ways and Means
  • Advisor to the Assistant Secretary for Tax Policy, U.S. Department of the Treasury
  • 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. Senate
  • Associate International Tax Counsel, U.S. Department of the Treasury
  • 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
Speaking Engagement

Jim Gadwood and Alexander Zakupowsky will present, "Tax Counsel's Report," at the EEI/AGA Virtual Taxation Committee Meeting on November 17, 2020.


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