Brian S. Gleicher

Brian Gleicher focuses on international and domestic tax matters with an emphasis on resolving tax controversies. He routinely represents taxpayers in complex disputes with the Internal Revenue Service (IRS), achieving favorable results at exam and with the IRS Independent Office of Appeals. Mr. Gleicher has almost 30 years of experience resolving international tax disputes issues through the Mutual Agreement Procedure (MAP) of bilateral income tax treaties. He has spent a considerable portion of his career on transfer pricing matters, including advisory work, dispute resolutions, and advance pricing agreements (APAs). He counsels on tax treaty matters before U.S. and foreign competent authorities on a broad range of issues, including double taxation, residency, and permanent establishment questions. 

Mr. Gleicher partners with the firm's other practices to bring his experience and expertise to matters where tax intersects with other areas of the law. Most notably, Mr. Gleicher routinely works with Miller & Chevalier's Customs & Import Trade practice on a broad array of issues, including the application of the first sale for export rule and overlapping issues involving transfer pricing and customs in the context of related party imports. He has also represented companies with tax issues arising in bankruptcy and those involved in investor-state disputes. 

Mr. Gleicher was described by clients in Chambers USA as "intelligent, driven, and strategic" and "able to very quickly become an expert on the issue at hand and craft a winning strategy for resolution."

Prior to joining Miller & Chevalier, Mr. Gleicher was a partner at a multinational law firm. He is the former chair of the Federal Bar Association's (FBA) Section of Taxation.