As a leading tax practice in the U.S. according to Chambers USA, we are routinely asked by clients to advise on the tax implications of major transactions. Whether they are engaged in mergers and acquisitions, divestitures, reorganizations, spin-offs, joint ventures, strategic alliances, or equity and debt financing, our clients rely on us to help them resolve tax questions that can have a significant impact on the success of the transaction. We are adept at understanding the tax implications of complex, multi-billion dollar, and cross-border transactions with novel tax issues, including public company and private equity driven deals and reorganizations.

We are generally consulted for transactions with cutting edge tax issues or that are especially tax sensitive. We bring to our clients a unique mix of specialized tax capabilities, extensive transactional experience including with global transactions, and both government and in-house experience. Our client base includes U.S. and foreign-based multinationals, large partnerships, S-corporations, and privately held companies. We are adept at collaborating with in-house specialists and external advisors, including the bankers, law firms and other consultants leading the deals. 

We help our clients structure their transactions at every stage of their deals. We have been instrumental in exploring the tax implications of potential transactions, conducting due diligence concerning the tax histories of the entities involved, structuring the tax aspects of potential deals, obtaining IRS and regulatory approvals for transactions, and managing closing and post-closing tax aspects of the deal. Throughout the process we provide customized guidance to minimize potential tax burdens and maximize the value of the deal.

  • 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 - 2021
  • Chambers USA: Government Relations: Specialist Tax Firms (Nationwide), 2019 - 2021
  • Chambers USA: Tax (District of Columbia), 2003 - 2021
  • Chambers USA: Tax: Corporate & Finance (Nationwide), 2020 - 2021
  • Legal 500: Tax: Contentious (U.S.), 2007 - 2021
  • Legal 500: Tax: International Tax (U.S.), 2013 - 2021
  • Legal 500: Tax: Non-Contentious (U.S.), 2013 - 2021
  • 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 Virtual Taxation Committee Meeting on June 7, 2021.


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