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George Matthew Gerachis
George Matthew Gerachis
Partner — Tax
Partner — Tax

George Matthew Gerachis

George Matthew Gerachis
Houston

1001 Fannin Street
Suite 2500
Houston, TX 77002

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.
George Matthew Gerachis

George is the head of the Tax and Executive Compensation and Benefits (ECB) department, where he represents individuals, partnerships and multinational corporations in tax planning and tax controversy matters.

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.

Having sustained clients’ tax positions on a wide variety of contested matters, George brings a unique perspective to the structuring and documentation of complex transactions. He believes it is important also to take a multi-disciplinary approach to accommodate sometimes competing objectives, and so he regularly works closely with clients’ tax executives and in-house counsel, as well as financial and operating personnel, external auditors and various consultants. George particularly relishes the opportunity to address emerging issues at the intersection of tax law and other legal disciplines, such as intellectual property law. Like others in V&E’s tax practice, George takes a practical, commercial approach.

Experience Highlights

  • 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

  • Disputes between formerly affiliated corporations in resolving disputes under tax sharing agreements 

  • 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

  • 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

  • Corporate spin-offs and other divisive transactions 

  • Technology licenses and joint ventures 

  • Pass-through entities including REITs and publicly traded partnerships (MLPs) in a variety of transactional matters

  • Business clients in structuring complex financing arrangements, including the use of hybrid instruments and hybrid entities 

Credentials

  • University of Virginia Law School, J.D., 1983
  • University of Virginia, B.A. with high distinction, 1979
  • Chambers USA, Tax (Texas), 2005−2014, 2016; Tax Litigation (Texas), 2017−2019; Tax Controversy (nationwide), 2011, 2013−2014, 2016−2019
  • Legal 500 U.S., General Commercial Disputes, 2017; International Tax, 2012−2016, 2018 and 2019; Employee Benefits and Executive Compensation, 2011, 2015−2017; Tax U.S. Contentious, 2011−2019; Tax U.S. Non Contentious, 2011, 2013−2015, 2017 and 2018
  • The Best Lawyers in America© (BL Rankings, LLC), “Lawyer of the Year,” Litigation and Controversy–Tax (Houston), 2017, 2020
  • The Best Lawyers in America© (BL Rankings, LLC), Tax Law, 2001−2020; Litigation and Controversy–Tax, 2011−2020
  • Selected to the Texas Super Lawyers list, Super Lawyers (Thomson Reuters), 2003−2019
  • Who’s Who Legal (Law Business Research Ltd.); Corporate Tax, 2017
  • International Tax Review: World Tax Review, Leading Lawyer list, 2005−2008
  • Member: American Bar Association, Tax Section: Court Procedure Committee, U.S. Activities of Foreigners and Tax Treaties; Houston Bar Association; International Fiscal Association
  • Texas
  • U.S. Tax Court
  • U.S. District Courts (various)
  • U.S. Court of Appeals for the Fifth Circuit
  • German
  • Spanish
  • “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)