- J.D.Boston University School of Law2008
- B.A.University of Michigan2005
Jim Gadwood is Counsel in the Tax Department. His practice focuses on federal civil tax controversies and other taxpayer interactions with the Internal Revenue Service. He has experience representing both corporate and individual taxpayers in matters involving federal, state, and local tax authorities. Mr. Gadwood has been described by clients in Legal 500 as a lawyer that combines "knowledge and ability with outstanding customer service and interpersonal, financial, business, and commercial skills."
Federal Tax Audits
- Obtained a full IRS concession of a cross-border debt-equity issue involving several billion dollars of proposed tax, penalties, and interest.
- Prepared a multilateral advance pricing agreement request.
- Successfully resolved an IRS audit of a cross-border cost sharing arrangement.
- Reduced a proposed assessment relating to transferee liability by millions of dollars.
- Obtained an accounting method change regarding a taxpayer's LIFO accounting.
- Negotiated an IRS Appeals settlement of an audit involving a management fee waiver.
- Experience with Global High Wealth and estate and gift tax audits.
State and Local Tax Audits
- Reduced a proposed assessment of New York City General Corporation Tax by millions of dollars in an audit involving formulary apportionment.
- Experience with New York City Real Property Transfer Tax audits.
- Used the docketed Appeals process to obtain a no-change stipulated decision in a Tax Court case involving IRS assertions of underreported income.
- Negotiated a multi-year settlement with the IRS after filing a motion for summary judgment in a Tax Court case involving the TEFRA statute of limitation.
- Obtained a complete victory in New York State Supreme Court on a motion for summary judgment involving a $200 million dispute over tax provisions in a contract between third parties.
- Experience with tax-related qui tam litigation under the New York False Claims Act.
- DC Bar Capital Pro Bono Honor Roll, 2018
- Legal 500: Tax: Contentious, 2016 - 2018
- Legal 500: Tax: International Tax, 2017
- Washington, DC Super Lawyers®: Rising Star, Tax, 2015 - 2016, 2018 - 2019
- New York Super Lawyers®: Rising Star, Tax, 2015 - 2016
- Member, American Bar Association, Section of Taxation, Administrative Practice Committee
District of Columbia
James Gadwood will speak at the 73rd Congress of the International Fiscal Association on September 8-12, 2019, in London. Gadwood will present, "Interest Deductibility: The Implementation of BEPS
Washington, DC, August 16, 2019 – Miller & Chevalier Chartered is pleased to announce that 26 firm lawyers were selected as top Washington, DC, practitioners in The Best Lawyer
James Gadwood will speak at the Edison Electric Institute (EEI) Taxation Committee Meeting on June 25, 2019. Gadwood will speak about Opportunity Zones.
Miller & Chevalier is pleased to announce that the firm was recognized as a "Gold Level Donor" to the DC Bar's Raising the Bar campaign.
Layla Asali, Erin Sweeney, and Jim Gadwood will speak at the American Bar Association Tax Section May Meeting on May 10 and 11, 2019, in Washington, DC.
In this chapter for Major Tax Planning
The Internal Revenue Service (IRS) Large Business & International Division (LB&I) is transitioning to a centralized compliance and examination process that focuses on issue-based campaigns.
In this article, Jim Gadwood analyzes the Appeals Judicial Approach and Culture (AJAC) Project and
In this article, Jim Gadwood provides an overview of the Internal Revenue Service's (IRS's) Large Busine
In this article, Jim Gadwood discusses the implications of miscalculated net operatin