Skip to content

U.S. Tax Controversy & Litigation

Experience Highlights

  • BMC Software in trial before the U.S. Tax Court, and on appeal before the Fifth Circuit Court of Appeals, in litigation concerning dividend repatriation under section 965

  • Trinity Industries in a trial and Fifth Circuit appeal involving the eligibility of prototype vessels for R&D credits and the interpretation of the “consistency rule” for qualified research expenditures

  • An offshore drilling contractor in a transfer pricing dispute with IRS regarding transfer of intangibles; resolved with a full concession by IRS Appeals

  • A foreign energy company relating to tax treaty issues arising from transactions with U.S. affiliates

  • Obtained a full concession from IRS Appeals on a “hobby loss” issue under Code Section 183

  • A partnership in a TEFRA proceeding involving multiple hearings and trial in Tax Court on issues, including jurisdiction, economic substance, and privilege

  • A private equity fund and fund manager in a Tax Court dispute regarding withholding tax issues and treatment of hedging transactions

  • A real estate investment trust in a dispute regarding economic substance of recapitalization of foreign subsidiary; resolved with a full concession by IRS Appeals

  • An oilfield services provider in a research and experimentation credit dispute; settled at IRS Appeals

  • A corporation in a valuation dispute regarding Alaskan onshore and offshore oil and gas properties; settled at IRS Appeals

  • Large, publicly traded, international energy company in administrative appeals proceedings with IRS

  • Publicly traded grocery company in administrative appeals proceedings with IRS

  • Large international trading firm in IRS administrative appeals matters and non-tax litigation involving U.S. tax matters