George A. Hani


Practice Co-Lead, Tax Controversy & Litigation

  • J.D.
    The Catholic University of America, Columbus School of Law
    magna cum laude
  • Ed.M.
    Harvard University
  • B.A.
    Duke University

George Hani concentrates his practice on the resolution of tax controversies at the administrative level, with a particular focus on tax accounting issues. He has represented clients in traditional Internal Revenue Service (IRS) examinations and administrative appeals, as well as in connection with a number of IRS dispute resolution programs, such as the Advanced Pricing Agreement (APA) program, the Pre-Filing Agreement (PFA) program, the Compliance Assurance Process (CAP), Fast Track Appeals and Accelerated Issue Resolution (AIR). Mr. Hani has assisted taxpayers to secure consents for changes in methods of accounting, private letter rulings and favorable technical advice memos from the IRS National Office. When necessary, he has represented taxpayers in United States Tax Court and in federal district courts. He has also represented individuals in collection matters, criminal investigations and the off-shore voluntary disclosure programs.

Mr. Hani has broad substantive experience driven in large part in response to the spectrum of issues that the IRS decides to audit and challenge. Recently, Mr. Hani has been involved in several large matters involving the application of the clear reflection of income standard as well as the interaction between the financial products rules and the tax accounting rules. Other recent cases involved the application of either the economic performance rules for deductions the IRS sought to defer or the all-events test for income the IRS sought to accelerate. In addition, Mr. Hani has extensive experience in audit issues regarding employee fringe benefits, use of mark-to-market under Section 475, and U.S. withholding taxes on cross-border payments. He also has experience in IRS challenges to the use of various tax incentives, such as the credits for blended fuels, the allowance of accelerated depreciation for particular types of property, and the use of tax-exempt financing to construct recycling facilities.

  • Honors Attorney, U.S. Department of the Treasury, 1995 - 1996
  • Honors Attorney, Office of the Associate Chief Counsel (International), Internal Revenue Service, 1994 - 1995
  • Chambers USA: Tax Controversy (National), 2016 - 2021
  • Chambers USA: Tax (District of Columbia), 2016 - 2021
  • International Tax Review: Tax Controversy Leaders (U.S.), 2015, 2017
  • Legal 500: Tax: U.S. Taxes: Contentious, 2016 - 2021
  • Legal 500: Tax: International Tax, 2016 - 2019 
  • Legal 500: Tax: U.S. Taxes: Non-Contentious, 2017 - 2019
  • The Best Lawyers in America®: Tax Law, 2020 - 2022
  • Washington's Top Lawyers: Tax (Washingtonian Magazine), 2015 - 2018, 2020
  • DC Bar Capital Pro Bono Honor Roll, 2014, 2016 - 2017
  • Council Director, ABA Taxation Section
  • Member, Advisory Board, Texas Federal Tax Institute
  • Member, Board of Trustees, Southern Federal Tax Institute
  • Former Chair, ABA Taxation Section, Administrative Practice Committee
  • Former Member, Steering Committee, Taxation Section, District of Columbia Bar
  • Former Chair, Taxation Section, District of Columbia Bar
  • Former Chair, Tax Audits and Litigation Committee, Taxation Section, District of Columbia Bar
Bar Admissions
  • District of Columbia
  • Maryland
Court Admissions
  • United States Tax Court
  • United States Court of Federal Claims
  • United States District Court for the Northern District of Texas
  • United States District Court for the Southern District of Texas
  • United States District Court for the Western District of Texas
  • United States Court of Appeals for the Ninth Circuit

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


In this article, George Hani and Colleen Brown, Senior Tax Advisor at Barrick Gold Corporation, discuss key changes to the "recalibrated" Compliance Assurance Process (CAP) announced by the IRS Lar