Tax: Controversy: Nationwide

THE FIRM As a result of the 2009 merger between Bingham McCutchen and McKee Nelson, this group emerges stronger than ever with 23 tax controversy specialists. The team covers complex litigation and controversy, often relating to the financial services industry. Transfer pricing is another core strength of the practice, which recently represented GlaxoSmithKline in the largest single Tax Court case in history. Its workload has been dominated by significant cross-border matters relating to undisclosed overseas bank accounts. 

Sources say: "For the amounts that we have at stake, this is the top team for IRS controversy and tax litigation issues."

KEY INDIVIDUALS Practice group leader John Magee is one of the premier contentious tax lawyers in the country. He is perhaps best known for high-end transfer pricing work, but is also active on tax litigation, planning and IRS administrative proceedings. Magee is described as "a veteran with superb insight." Co-leader William Nelson wins praise for being "quick on his feet in the courtroom and possessing excellent policy instincts." He is an authority on partnership tax, and has extensive knowledge of the government stemming from his previous role as IRS chief counsel. He is frequently found advising companies and individuals on high-profile IRS disputes. Raj Madan is "great on his feet and thinking strategically," sources reveal. Focusing on controversy and litigation matters, he primarily represents large financial institutions, handling transfer pricing, foreign tax credits and investment tax matters. Of particular note was his recent work with Sovereign Bancorp, in a lawsuit seeking to recover $235 million. Sanford Stark is acclaimed for his superior advice on high-end transfer pricing and federal tax matters. He handles complicated disputes for a number of Fortune 500 companies, including the seminal GSK transfer pricing case. Michael Desmond is a former DOJ tax litigator who is described as "an absolute star and one of the smartest lawyers I have ever met," by one source. Focal points of his controversy practice are administrative dispute resolution and tax policy counseling for blue-chip companies.

THE FIRM A formidable presence in the global tax world, this sizable practice wins acclaim for its superior handling of controversy issues. The 55-strong team often advises on high-end transfer pricing and substantial tax litigation, acting for Ford, Wells Fargo and JPMorgan among other high-profile clients. Particular highlights include its representation of Consolidated Edison in a $400 million cross-border leasing transaction.

Sources say: "A full-service firm with an excellent reputation in tax litigation - the lawyers are very strong, thoughtful and client-oriented."

KEY INDIVIDUALS Joel Williamson is a dean of the tax controversy Bar, revered for his "spectacular courtroom manner and skills." A seasoned practitioner with considerable experience of the government, he worked on the landmark Consolidated Edison case. Thomas Durham tackles litigation relating to foreign tax issues, Section 482 and appellate matters, and has extensive experience before the US Tax Court, US Court of Federal Claims and all other levels of the federal court. David Abbott is a crucial member of the firm's New York office, winning acclaim for his "impressive courtroom manner and knowledge of market moves." Recently, he has been involved in high-profile cross-border leasing matters, handling work for Wells Fargo, Union Bank of California and, most notably, Consolidated Edison. Thomas Kittle-Kamp has broad controversy expertise, taking in IRS audits, IRS appeals and competent authority negotiations. He is described as a "very thoughtful practitioner who works well with clients." Chicago-based Scott Stewart focuses on federal tax controversy matters, including administrative appeals before the IRS, audits, and litigation matters. Of note was his recent work with Exelon, concerning $1 billion of expense deductions relating to decommissioned nuclear power plants. Larry Langdon advises clients on a wide range of federal tax policies and is "steeped in IRS law, and very effective at putting his experience in government to good use." He represents JPMorgan in a variety of tax controversy issues.

THE FIRM This premier practice undertakes a wide range of tax controversy work, including partnership taxation, transfer pricing, REITs and financing. Many of the practitioners have substantial governmental experience with the Treasury Department and the IRS, in addition to legislative experience with the Senate Finance Committee and the Congressional Joint Committee on Taxation. The group frequently advises on cutting-edge, innovative tax matters for corporate clients and noteworthy individuals.

Sources say: "Every attorney here has enormous technical capabilities in their area of expertise."

KEY INDIVIDUALS Kenneth Gideon is described as an "exceptional thinker," and takes on substantial controversy, litigation and planning matters, representing clients before the IRS and Treasury. Albert Turkus is a renowned tax litigator who "really knows his way around a courtroom." His trial experience includes appearances in federal, state and trial courts nationwide. John Williams is described as "brilliant and creative," and receives praise for his forceful litigation skills. A former chief counsel for the IRS, he uses his government experience to represent clients in federal tax controversy and litigation matters in the federal courts. Fred Goldberg is a "gifted tax diplomat" and former IRS commissioner. He focuses on tax accounting, foreign tax credits and transfer pricing matters. Clients laud his "unflappable judgment and invaluable opinions." Pamela Olson is prized for being a "brilliant and gifted tax policy leader." She undertakes IRS audits, litigation, appeals and administrative guidance. Former assistant secretary at the Treasury Department, she is a well-respected figure in the community. Alan Swirski is a leading choice for tax litigation and federal tax controversy matters. He was recently lead counsel in a case brought by the IRS Office of Professional Responsibility against a tax practitioner – the first trial victory ever by a practitioner in such a case.

THE FIRM Prized for its high-end international transfer pricing expertise, this 150-strong team also acts on general controversy and tax planning matters. Mostly operating out of the Washington, DC and Chicago offices, the group combines litigation skill with the knowledge base of a number of seasoned tax practitioners. Work highlights include the landmark Vertias/Symantec transfer pricing case.

Sources say: "Gets the big cases and is major competition on a global basis."

KEY INDIVIDUALS Mark Oates is an international tax specialist and handles transfer pricing, financial products and tax treaty matters for high-profile clients. Sources reveal that he is "terrific on his feet, a really strategic thinker." James O'Brien is highly valued for his "thoughtful approach to litigation" and procedural knowledge. A transfer pricing expert, he also undertakes international and corporate tax litigation. Gregg Lemein is commended for his specialist advice on federal income taxation matters, especially those connected with inter-company pricing issues. DC-based partner Duane Webber concentrates on federal income tax controversy issues, including alternative dispute resolution techniques. He is described as "a tenacious litigator whose crafting of arguments is top-drawer." John Peterson is based in Palo Alto and chairs the global tax practice group. He focuses on pricing, international tax planning and controversy matters.

THE FIRM This team has expertise in federal controversy and IRS audit work. It operates primarily out of offices in Chicago, Los Angeles and New York, and has a well-established national reputation. 

KEY INDIVIDUALS DC-based Gerald Kafka handles federal income tax matters before the IRS. Chicago-based Roger Jones has tax controversy expertise and his clients include Fortune 500 companies.

THE FIRM This controversy practice has a deep bench of talent and handles a diverse workload that includes domestic and international issues, IRS audits and appeals, and litigation at the trial and appellate levels, including the Supreme Court. The 30-strong team is also experienced in state and local tax, handling work for a national clientele in connection with local taxing authorities.

Sources say: "This group is ready, willing and able. It has expertise in virtually all areas of business taxation, and excels at bringing to bear the correct resources."

KEY INDIVIDUALS William Goldman is unsurpassed when it comes to tax controversy. Senior counsel based in Washington, DC, his expertise extends to federal and state tax controversy matters. Thomas Borders is a "high-quality litigator with good courtroom presence." Co-head of the group, he focuses on federal tax controversy issues including audits, administrative appeals and litigation. Of note was his recent representation of Bryan Cave in tax malpractice suits. New York-based senior counsel Peter Faber is "a brilliant intellect and  deservedly respected" when it comes to controversy matters at the federal, state and local level. Michael Kelleher acts on substantial federal income tax controversies, transfer pricing, and insurance matters from his base in Washington, DC. He is described as "extremely effective with excellent judgment." Jean Pawlow is "dedicated to client service," and recently made headlines, winning an important case for Capital One Financial.

THE FIRM This national group contains a substantial number of attorneys with government backgrounds, and handles controversy work in the administrative and litigation areas. Its client base largely consists of multinational companies in the energy, healthcare and financial services industries.

Sources say: "You can throw the most complicated matters their way, and be confident in getting the right result."

KEY INDIVIDUALS Alan Horowitz is frequently found handling appellate litigation, with a particular niche in federal tax appeals. He is described as "an amazing practitioner." Kevin Kenworthy receives praise for his outstanding litigation skills and ability to "take an issue and fully understand its complexities." He concentrates on federal income taxation, including tax litigation and controversy matters.

THE FIRM This tax boutique handles sophisticated international tax, litigation, fraud, and tax-exempt organizations work. The team has been extraordinarily busy in recent times, dealing with over 350 voluntary disclosure matters, as well as carrying out substantial high-profile international tax work for foreign corporations and governments. Other strengths include cross-border controversies, transfer pricing and foreign tax credits.

KEY INDIVIDUALS Cono Namorato "is on everyone's short list for criminal tax work," say sources. Representing individuals and corporations in tax investigations, he has been extremely active on voluntary disclosure matters. His extensive government experience brings "a lot of insight to the table." David Rosenbloom handles high-profile controversy matters, with particular expertise in international and transfer pricing work. Clients appreciate his "combination of analytical skills and government experience." Scott Michel wins acclaim as "a skilled negotiator who can take sensitive criminal matters and lower the risk level, moving them back into the civil area." President of the firm, he has been active on around 150-175 voluntary disclosure matters in the past nine months.

THE FIRM Operating out of offices in Atlanta, Houston, and Philadelphia, this 16-strong team has a stellar reputation for handling IRS tax controversies, tax shelter cases, and state and gift tax litigation. The group's extensive trial experience includes appearances before the Tax Court, the Federal District Courts, the Court of Federal Claims and the Supreme Court. 

Sources say: "A great firm that is really effective on tax controversy."

KEY INDIVIDUALS Houston-based Larry Campagna is "a brilliant practitioner both in law and procedure," sources reveal. He covers federal, state and local tax controversy matters, and white-collar criminal defense issues. He has recently acted on a vast number of voluntary disclosure matters. David Aughtry is "a superb courtroom lawyer and a persuasive orator," sources comment. Based in Atlanta, he undertakes civil and criminal tax litigation, especially tax shelter cases. Philip Karter is based in Philadelphia and frequently handles tax controversy and litigation matters relating to federal income, estate and gift tax matters. He has extensive trial experience, including appearances before the Tax Court, the District Courts and Court of Appeals. A former DOJ litigator, he is an "excellent communicator and top litigator." Also in Philadelphia, Herbert Odell is admired for his comprehensive controversy and international tax planning work for major corporations. He frequently handles administrative matters and ruling requests. Juan Vasquez has "enormous energy and is a deep thinker." He focuses on tax controversy, litigation and administrative matters at the federal, state and local level.

THE FIRM This group advises major financial institutions, insurers, and multinational companies on IRS disputes and criminal and civil tax matters, including tax shelters, transfer pricing and offshore cross-border matters.

Sources say: "A firm to trust with the big cases."

KEY INDIVIDUALS Seth Farber works closely with the controversy team, and advises on white-collar criminal defense, antitrust and corporate internal investigations. Practice head Lawrence Hill focuses on controversy, litigation and white-collar investigations. He is described as "a real-deal, stand-up trial lawyer."

THE FIRM This group is known for its tax controversy work, and handles IRS audits and appeals, tax shelters and gift tax cases. Criminal tax defense is another core strength, and the team is well versed in IRS criminal and grand jury investigations. The practice is largely based in the Houston and New York offices.

KEY INDIVIDUALS Texas-based Jasper Taylor is a "strategic thinker" who focuses on controversy matters and litigation, representing individuals and energy, telecom and real estate corporations. He has recently been occupied with substantial tax shelter matters. Kathryn Keneally wins acclaim for her well-rounded practice, which covers controversy, criminal tax defense, fraud and commercial litigation. Based in New York, she has been active on offshore bank account matters. Sources praise her "organizational skills and excellent insight into the thinking of government officials." Charles Hall is a legend in the marketplace. He has a distinguished national reputation in significant controversy matters at the federal, state and local level.

THE FIRM Regularly acting on high-profile controversy work, this 91-strong practice has expertise in partnership tax, high-value refund cases and, most recently, a great deal of tax shelter matters. With key offices in Atlanta, New York and Washington, DC, it has the resources to serve a global clientele, which includes AIG, Time Warner, Kraft and Procter & Gamble.

Sources say: "Impressive and effective, with a wide experience base."

KEY INDIVIDUALS Atlanta-based Jerold Cohen is a former chief counsel of the IRS, and wins unanimous praise for his "insight into the government, knowledge of a broad spectrum of dispute resolution techniques, and creativity in getting things resolved effectively." Focusing his practice on tax planning and controversy, he often represents clients on a national and international level. Practice group leader Jerome Libin is a stalwart of the Bar, admired for his sterling litigation, controversy and corporate acquisitions skills. Kent Jones is an appellate lawyer who focuses his practice on tax, commercial and government litigation. Clients report that his greatest strength is "his expertise, creativity and willingness to help us pursue a novel position."

THE FIRM This group handles controversy and litigation work at the federal, state and appellate level. It has expertise in international planning, among other areas.

KEY INDIVIDUALS Washington, DC-based practice head Miriam Fisher has expertise in controversy and criminal tax matters. Mark Matthews focuses on criminal tax enforcement, civil tax compliance and white-collar matters. William Colgin is based in Palo Alto and acts on controversy and litigation matters. He has expertise in audit and examination defense, and administrative appeals and settlements.

THE FIRM This team comprises 32 attorneys based in San Francisco and Washington, DC. It has comprehensive expertise in federal controversy and litigation matters, as well as state and local tax. Recent work includes the representation of Chevron in a challenge to a new city tax that raised its business license tax from $60,000 to over $20 million.

Sources say: "A detail-oriented team that provides superior value." 

KEY INDIVIDUALS William Bonano is "the real article: a marvelous strategist and a really good courtroom lawyer." Based in San Francisco, he focuses his practice on international tax planning and controversy matters, from examinations to litigation and appeals.

THE FIRM Operating out of Washington, DC and New York, this high-quality boutique is prized for its real estate, tax planning, controversy, and state and local taxation audit and administrative hearing expertise. The group has represented clients in the Tax Court, federal district and appellate courts, and the Court of Claims.

KEY INDIVIDUALS Main contacts include Theodore Peyser in Washington, DC and Richard Levine in New York.

THE FIRM Steptoe & Johnson typically acts on complex tax controversy matters, including audits and appeals, tax shelter litigation, tax refund, and accounting issues. Recent work highlights include representing Textron in a case centered on the precedent for the fundamental right to protect internal tax documents.

KEY INDIVIDUALS Arthur Bailey played a significant role in the Textron case, and is praised for his extensive litigation experience. He acts on tax-advantaged investments, defense of listed transactions, and cross-border lease transactions. Matthew Lerner is hailed as a "superb writer and thinker," who focuses on civil and criminal tax controversy. He recently represented Koch Industries in a federal tax refund suit.

THE FIRM This team operates as part of a global network and undertakes tax controversy and litigation work. Its expertise includes insurance taxation.

KEY INDIVIDUALS Practice leader Michael Quigley undertakes tax litigation in connection with transfer pricing, partnerships, and life insurance taxation among other issues.