George Matthew Gerachis

Senior Partner

Tax

“I have the good fortune to lead a group of tax lawyers who not only enjoy mastering the intricacies of the tax code, but who also communicate in plain English and look for practical ways to help clients achieve their objectives.”

Overview

George is Co-Head of the firm’s Tax Controversy Practice. During his more than three decades with V&E, George has tried cases in the United States Tax Court and Federal District Courts and handled many appeals. While he has been involved in many high-profile court cases, often establishing key precedents along the way, George is equally proud of the more numerous matters that never made headlines — ones where solutions were reached after sometimes tough, but always civil, debate with the government. By developing strategy early, preparing cases meticulously, and negotiating firmly, he and his team have frequently resolved their clients’ IRS audits and appeals on a cost-effective basis, avoiding court proceedings altogether.

Experience

U.S. and non-U.S. based multinational public companies with providing outside tax counsel on issues spanning the Internal Revenue Code; experienced in using wide array of alternative dispute resolution techniques, including mediation, arbitration, fast track settlement, Pre-Filing Agreements; and has handled summons enforcement matters
Publicly traded partnerships, such as MLPs, and private partnerships in disputes concerning the partnership tax provisions of Subchapter K, including disputes over allocations, distributions and basis adjustments; extensive experience handling partnership examinations and litigation under both the TEFRA and BBA Centralized Partnership Audit regimes
Federal income tax and excise tax refund litigation in the U.S. District Courts
Disputes between formerly affiliated corporations in resolving disputes under tax sharing agreements as well as tax indemnification disputes between parties to merger & acquisition transactions
Private equity and hedge funds and their investors in TEFRA and non-TEFRA partnership examinations involving a variety of partnership and international tax issues, including the sourcing of income, withholding tax, and existence of a U.S. trade or business
Global high-net-worth individuals and their closely held companies in IRS audit initiative
Corporate clients—both “inbound” and “outbound”—in establishing, documenting, and defending intercompany transfer pricing strategies and policies; extensive experience in disputes involving cost-sharing arrangements; has negotiated Advance Pricing Agreements

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The Williams Companies, Inc. v. Energy Transfer Equity, L.P., __ A.3d. __ WL 1090912 (Del. 2017), affirming WL 3576682 (Del. Ch. June 24, 2016) (Member of trial team representing Energy Transfer Equity, LP in Delaware Chancery Court in litigation over termination of merger agreement with The Williams Companies based on failure of condition precedent relating to the provision of a tax opinion under Section 721 of the Internal Revenue Code; trial result for Energy Transfer affirmed by Delaware Supreme Court)
BMC Software Inc. v. Commissioner, No. 13-60684 (5th Cir., March 13, 2015) – Reversing Tax Court on IRC §965 dividends received deduction for repatriated cash
Trinity Industries, Inc. v. U.S., 757 F.3d 400 (2014) – Affirming in part and vacating and remanding in part, District Court on research and development tax credit “consistency rule”
Halliburton Co. v. Commissioner, 946 F.2d 395 (1991) – Affirming Tax Court and upholding bad debt and worthless stock deductions arising from 1979 Iranian expropriation

Capabilities

Credentials

Education

University of Virginia Law School, J.D., 1983
University of Virginia, B.A. with high distinction, 1979

Admissions

Texas
U.S. Tax Court
U.S. District Courts (various)
U.S. Court of Appeals for the Fifth Circuit

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“Changes and Developments in IRS Examinations and Appeals,” UT Law Parker C. Fielder Oil and Gas Tax Conference, November 22, 2019 (panelist)
“What Technology Clients Need to Know About the New Tax Act,” Intellectual Property CLE Series, V&E Houston Office, February 1, 2018 (speaker)
“New Proposed Regulations for BBA Partnership Audits Allow for Push Out Elections in Tiered Partnerships,” V&E Tax Update E-communication, December 19, 2017 (co-author)
“Tax Reform Advances: White House and Congressional Republican Leaders Release Unified Framework,” V&E Tax Update E-communication, October 3, 2017 (co-author)
“The New Era of Partnerships As Taxpayers,” American Investment Council, September 28, 2017, (co-author)
“Relief for Taxpayers Affected by Hurricane Harvey,” V&E Tax Update E-communication, August 31, 2017 (co-author)
“A Greek Company Mines for Magnesite and Strikes Gold for Inbound Investors,” V&E Tax Update E-communication, July 17, 2017 (co-author)
“New IRS Campaign Targets Non-U.S. Companies That Have Not Filed U.S. Tax Returns,” V&E Tax Update E-communication, June 1, 2017 (co-author)

“The IRS Incorrectly Concludes that an FCPA Civil Disgorgement Payment is a Nondeductible Fine or Penalty,”Tax Notes, September 26, 2016 (co-author)
“Cross-Border Legal Issues for In-House Counsel,” Corporate Counsel Institute, Dallas, Texas, May 6, 2016
“Changes to the Partnership Audit Tax Rules – What Partnerships Need to Consider Now,” February 4, 2016 (presenter)
“Dramatic Changes to Partnership Audit Rules and Their Implications for Existing Partnerships,” V&E Tax Update E-communication, November 5, 2015 (co-author)
Changes to the Partnership Audit Tax Rules – What Partnerships Need to Consider Now
Changes to the Partnership Audit Tax Rules – What Partnerships Need to Consider Now
“Partnership Tax Audits,” TEI’s 69th Annual Conference, Houston, Texas, November 3, 2014
“Current Issues, Pitfalls and Best Practices Involving Audits, Controversies, and Dispute Resolution for Taxpayers in the Oil and Gas Industry,” 12th Biennial Parker C. Fielder Oil and Gas Tax Conference, Houston, Texas, November 22, 2013
“Tax Controversy Update,” V&E Client Presentation, Houston, Texas, November 7, 2013
“The Uncertain World of Uncertain Tax Position Disclosures and Privilege,”Bloomberg BNA Daily Tax Report, March 23, 2012 (co-author)

Recognitions

Chambers USA, Tax (Texas), 2005−2014, 2016; Tax: Litigation (Texas), 2017−2026; Tax: Controversy (Nationwide), 2011, 2013−2014, 2016−2026
Legal 500 U.S., General Commercial Disputes, 2017; Tax: International Tax, 2012−2016, 2018–2024, and 2026; Employee Benefits and Executive Compensation, 2011, 2015–2017 and 2020; Tax: U.S. Taxes: Contentious, 2011–2026; Tax: U.S. Taxes: Non-Contentious, 2011, 2013–2015, 2017, 2018, 2020–2022
The Best Lawyers in America_^© (BL Rankings, LLC), “Lawyer of the Year,” (Houston): Litigation and Controversy–Tax, 2017 and 2020; Tax Law, 2025
The Best Lawyers in America^_© (BL Rankings, LLC), (Houston): Tax Law, 2001−2027; Litigation and Controversy–Tax, 2011−2027
Selected to the Texas Super Lawyers list, Super Lawyers (Thomson Reuters), 2003−2025
Selected to the 500 Leading Litigators in America, Lawdragon, 2026
International Tax Review: World Tax Review, Leading Lawyer list, 2005−2008, 2021, 2022, and 2024
Texas Lawyer (American Lawyer Media), Texas Trailblazer, 2020
Texas Lawyer (American Lawyer Media), Best Mentor, 2020
Who’s Who Legal (Law Business Research Ltd.); Corporate Tax, 2017

Insights

Events

George Gerachis and Jenny Speck Presenting at the UT Law CLE 2025 Oil, Gas, and Energy Taxation Symposium

Vinson & Elkins is a sponsor of the UT Law CLE 2025 Oil, Gas, and Energy Taxation Symposium, taking place Wednesday, November 19 in Houston, Texas.

November 19, 2025

November 19, 2025 • 1-minute read

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Summary of Business Income Tax Provisions in the CARES Act Background Decorative Image

Client Alerts

Treasury and IRS Finalize Disclosure Requirements for So-Called Related-Party “Basis-Shifting” Transactions

The Department of the Treasury (“Treasury”) and the Internal Revenue Service (“IRS”) have released final regulations designating so-called “basis-shifting” transactions among related parties as “transactions of interest.”

January 13, 2025 • V&E Tax Update

January 13, 2025 • 4-minute read

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Inflation Reduction Act of 2022: Corporate Alternative Minimum Tax Background Image

Client Alerts

“The Ball is in Congress’ Court”: U.S. Supreme Court in Corner Post Paves the Way for Challenges to Longstanding Treasury Regulations

In the final decision of the Supreme Court’s term, the Court again considered the Administrative Procedure Act (“APA”).

July 3, 2024 • V&E Tax Update

July 3, 2024 • 3-minute read

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Watch It on Weight Issues in Washington Background Decorative Image

Client Alerts

“A Massive Shock to the Legal System”: Supreme Court Supermajority Significantly Curtails Administrative Agency Authority in Loper Bright with Momentous Impact on Federal Tax System

In a landmark decision, the Supreme Court has overruled the Chevron doctrine, fundamentally altering the landscape of administrative law and significantly impacting federal tax administration.

July 1, 2024 • V&E Tax Update

July 1, 2024 • 5-minute read

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Supreme Court Decision Establishes Important Precedent for Prisoners Seeking Access to Judicial System Background Image

Client Alerts

IRS, Treasury Look to Challenge So-Called Basis-Shifting Transactions, But It Won’t Be Easy

The Department of the Treasury (“Treasury”) and the Internal Revenue Service (“IRS”) announced the latest chapter in the long-trumpeted enforcement initiative aimed at large partnerships.

June 18, 2024 • V&E Tax Update

June 18, 2024 • 4-minute read

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George Matthew Gerachis

Overview

Experience

Capabilities

Credentials

Recognitions

Insights

News & Achievements

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