Tax: Controversy: Nationwide

THE FIRM This outstanding team continues to impress market sources with its solid counsel on complex controversy and litigation. It regularly represents clients from the financial services, real estate, technology, energy and consumer products industries, and handles major disputes with the IRS as well as cross-border controversy. Its already solid transfer pricing practice has been bolstered in the last year with a number of lateral hires on the West Coast. Major clients of the group include Santander, GE Capital and BB&T.  

Client Service "They are always accessible and make us feel like their only client."

KEY INDIVIDUALS John Magee maintains an excellent reputation for complex controversy work, with a particular emphasis on transfer pricing matters. Clients say: "He is very experienced and an excellent negotiator. He has a great ability to extract information to establish an understanding, and he provides excellent counsel to the company."

Practice co-head William Nelson "has wonderful judgment and maturity, and is a great litigator," say sources. In addition to excellent command of controversy and litigation matters, he is also a skilled partnership tax expert. 

Raj Madan's fantastic reputation continues to grow. He focuses on representing financial institutions in tax litigation and controversy, regularly appearing before the IRS. "He is dealing with some significant and high-value matters for us and everyone here has a high level of comfort that he steers us in the right direction," said one client. 

David Curtin stands out for his solid advice on the most complex controversy and litigation matters. His vast experience enables him to handle both civil and criminal cases, and he continues to represent GE Capital in a number of federal tax matters.

Sanford Stark is noted for his transfer pricing expertise and also handles tax accounting, cross-border structures and procedural considerations. Clients report: "He takes the time to understand us and you really feel he is part of your team. He always does what's right for the client." Stark represents clients in every level of the controversy process, from pre-audit to the federal trial and appellate courts.

THE FIRM This team includes attorneys who are skilled in the full range of tax controversy work, including litigation at trial and appellate level, tax audits, state and local controversy, transfer pricing and other international controversy matters. Clients are particularly quick to commend its impressive and exceptionally helpful international outlook. The firm is headquartered in Chicago, and offers additional strength in California and New York. It recently counseled Boston Scientific and its subsidiaries on actions filed in US tax court, and represented Flextronics in litigation associated with the acquisition of a manufacturing facility in North Carolina.  

Commercial Awareness "They keep us up to date on relevant news items and banking developments in the USA. This adds value to our company."

KEY INDIVIDUALS Joel Williamson is singled out as one of the top tax litigators in the country, with clients saying "he is top in the field; one of the top litigators in the USA. He'll resolve issues without litigation too as he's an excellent negotiator." He was recently involved in the abovementioned matter on behalf of Boston Scientific and its subsidiaries.  

Thomas Durham is highly recommended for his expertise in litigation associated with tax-advantage investments, leasing, economic substance and foreign tax issues. He is also highly experienced in natural resources tax law and matters facing tax-exempt organizations. He continues to represent Wells Fargo Bank.  

Palo Alto-based Larry Langdon "has a high level of expertise and is a pleasure to work with," say sources. He is credited with building an excellent tax controversy practice on the West Coast, and is vastly knowledgeable on federal tax policies. He has handled significant transfer pricing matters at IRS appeals level in the past year.  

In tax litigation, David Abbott is "absolutely superb," say clients. In addition to providing solid counsel on controversy, litigation and bankruptcy disputes, he also advises on a range of transactional matters. He recently advised Union Bank of California on a matter involving leverage leases of a sports entertainment complex and hydroelectric power facilities. Thomas Kittle-Kamp was also involved in this matter and is held in high regard for his broad controversy practice, which covers valuation disputes, Subchapter C issues, Section 482 allocations, and IRS audits and appeals, among other matters.

The "responsive and knowledgeable" Scott Stewart is a strong choice for transfer pricing matters. He represents clients at every level of federal tax controversy, from audit level to litigation before US tax court and the Court of Federal Claims. He has recently represented Nestlé and Tyco International.  

THE FIRM This group maintains a platinum-standard reputation for litigation and complex tax controversy. Many of its exceptionally high-quality practitioners have prior experience at the IRS or the Treasury Department. In addition to strong litigation expertise, the team is also vastly experienced in every type of dispute resolution. It advises individuals, corporations, estates and governments, and recently represented a domestic financial institution in an IRS examination concerning cross-border intercompany financing arrangements. 

Client Service "They understand what your priorities and interests are, and they do their best to approach them."

Commercial Awareness "One thing that makes them stand out is their practical business sense."

KEY INDIVIDUALS Kenneth Gideon is a preeminent figure on the nationwide tax controversy landscape. He focuses on litigation and controversy resolution at both the appeals and examination levels, and also provides counsel on tax planning matters. He recently represented Anschutz in a Tenth Circuit appeal.  

Fred Goldberg co-heads the firm's global tax practice and has an outstanding reputation for advising on the most complex controversies and IRS regulatory and administrative proceedings. "He is a very rare individual in the US landscape as he has done so much in so many different government positions," note impressed observers, adding: "He is a wonderful adviser who gets along with everyone, and he is also an effective problem solver in every situation."

"Top-of-the-line" practitioner John Williams draws widespread praise for his excellent practice, which covers every level of federal tax controversy and litigation. Recent highlights include representing CIGNA in a US Tax Court trial, which has industry-wide implications. He handled this matter with Alan Swirski, who also focuses on every federal tax controversy and litigation.  

Julia Kazaks continues to make waves in the marketplace, with observers reporting that "she is a really effective advocate who clients really trust." She recently successfully represented a prominent national franchise before the IRS in a matter concerning potential employment tax penalties.  

THE FIRM Commentators praise this group for its dedication, broad-based knowledge and responsiveness, and for its distinguished forte in transfer pricing. The team also offers expertise on litigation, alternative dispute resolution and cross-jurisdictional tax controversies, providing counsel to clients in a broad range of industries including financial, aerospace and pharmaceutical. The team is spread across offices in Chicago, Palo Alto and Washington, DC, and recently achieved a successful settlement for Broadcom in its defense against proposed transfer pricing adjustments totaling more than $5 billion. 

Commercial Awareness "They are very thorough and have been successful in highlighting the concerns which are pivotal when making business decisions."

Client Service "Fantastic, very bright and hard working people. Client service is absolutely number one there."

KEY INDIVIDUALS Outstanding trial lawyer Mark Oates is highly recommended for his excellent handling of the most high-profile and complex litigation, and also undertakes work on tax fraud and criminal defense. He is based in Chicago.  

"Tremendous lawyer" Gregg Lemein is an established name in the field. He is based in Chicago, and counsels clients on multijurisdictional tax controversies and international planning issues. He is particularly skilled in intercompany pricing issues.  

James O'Brien focuses on complex corporate and international litigation, and recently represented Western Union in a US Tax Court trial. "He has been completely fantastic!" said one impressed client. "His advantage is his technical skills and abilities. Fantastic guy, fantastic liaison with appeals, fantastic outcome!"

Observers are quick to commend Washington, DC-based Duane Webber for his impressive and successful performance in court. In addition to litigation, he is also skilled in a number of alternative dispute resolution techniques. He continues to represent leading aerospace and defense company Boeing.

Palo Alto-based John Peterson has extensive experience in intercompany pricing, federal tax controversy and hi-tech taxation. "He is an exceptional tax adviser; the most technically competent I know," said one interviewee. "He is also practical, personable, easy to work with and available night and day."

THE FIRM This group offers counsel on a range of tax controversies and matters before the IRS. It has experience handling a broad range of matters, from examination level through to litigation, and regularly represents accounting and law firms. Its impressive client list also includes companies in the real estate, healthcare, finance and communications industries. Recent highlights include representing Wilmington Partners in a complex case before the Supreme Court, and advising Vi in connection with an IRS examination.

Commercial Awareness "They provide very commercial advice that is significantly valuable."

KEY INDIVIDUALS Washington, DC-based practice chair Gerald Kafka is an exceptionally talented tax controversy and litigation specialist who regularly handles very high-value matters. In the last year he represented Manor Care in relation to its refund claims to recover work opportunity tax credits, both before the US Court of Federal Claims and, on appeal, before the US Court of Appeals. 

Miriam Fisher recently joined the firm from Morgan, Lewis & Bockius. She moves into the top tier having earned praise as "one of the top tax lawyers" in the field. Her outstanding civil and criminal tax practice covers tax disputes before state tax authorities and the IRS at the examination level through to litigation. She has handled a number of impressive and high-profile cases in the last year, including the above-mentioned litigation on behalf of Iberdrola. "She is one of the most capable people I have worked with," said one source. 

THE FIRM With strong controversy practitioners spread across its offices in New York, Chicago, Washington, DC and California, McDermott Will & Emery provides impressive national coverage. The team handles litigation, tax malpractice, international controversy, audits and appeals, and also has a thriving state and local tax controversy practice. Major work includes defending insurance company John Hancock in US Tax Court in response to IRS challenges to its treatment of certain leveraged lease transactions. Other clients include New York Times, Citibank, Johnson & Johnson and Honeywell.

Sources say: "A very responsive and knowledgeable group that is honest about what it can and cannot do."

KEY INDIVIDUALS Thomas Borders is a strong choice for federal tax controversies, handling litigation, criminal investigations, audits and administrative appeals. Clients enthuse that he "is extremely smart, possesses good skills, works hard and is doing a wonderful job of helping us reach our goals." He frequently represents accountants, lawyers and private clients, and recently achieved a Tax Court victory for the executors of the Estate of Duncan. 

"Solid state and local tax practitioner" Peter Faber is based in New York and rises in the rankings this year having earned some exceptional feedback. He handles both controversy work and business tax planning, and is "terrific – he's reaching the top of his game," claim interviewees. He recently achieved a successful outcome for Labor Ready Northeast in New Jersey Tax Court.

Practice head Jean Pawlow also rises in the rankings, with one impressed client revealing: "I would say that she is one of the preeminent tax lawyers in the US – I can't think of anyone else doing a better job than she does. She gives 100% and is very enthusiastic, bright and responsive." Pawlow recently advised credit card company Discover on a controversy matter associated with its income from interchange fees.  

Michael Kelleher stands out for his transfer pricing and federal income tax controversy expertise. He is described as a "reasonable, level-headed and practical sounding board," and is also noted for his helpful insight into the pharmaceutical industry. His highlights include representing Securitas in tax court litigation. 

Senior counsel William Goldman is widely respected for his wealth of experience in federal and state controversy. He has been involved in representing a subsidiary of AT&T in an appeal at the Appellate Court of Illinois.

Roger Jones recently joined the firm from Latham & Watkins. He is "very personable and capable in tax court," and "his technical expertise is extremely good," clients say. Jones is based in Chicago and handles a substantial amount of domestic and international tax controversy matters.   

THE FIRM This Washington, DC-headquartered firm has a reputation for handling sophisticated and high-value tax controversies for clients from a range of industries, including natural resources, financial services, media and entertainment, and telecommunications. Clients are particularly quick to commend its strength in Tax Court litigation, and the team also frequently appears before the Court of Claims, US District Courts and appellate courts.  

Sources say: "Not only are they technically strong, but they have public sector experience and relationships with tax officials."

KEY INDIVIDUALS Leading practitioner Kevin Kenworthy focuses on tax litigation and a range of controversies, regularly representing major multinational corporations. He is a strong litigator, and is equally adept at settling complex IRS disputes at the administrative level.

Alan Horowitz focuses on appellate litigation and is particularly skilled when it comes to federal tax appeals. His vast experience has seen him undertake work in the federal court of appeals, Supreme Court and trial courts.

THE FIRM Sutherland Asbill & Brennan fields a number of superb controversy attorneys across its offices in New York, Atlanta and Washington, DC. The team is noted primarily for its exceptional state and local tax controversy practice, and also offers strong representation in a variety of federal and international controversy and litigation matters. It continues to represent GM in litigation, recently advising it on a Michigan state court refund suit for its 1996-2007 tax years, seeking the return of state taxes worth approximately $116 million. Other clients include FedEx, AIG and Procter & Gamble.  

Client Service "They are very professional and provide value-added services."

Commercial Awareness "They understand and are entrenched in our business now – they're first in line when we seek advice!" 

KEY INDIVIDUALS Atlanta-based tax superstar Jerold Cohen has an excellent reputation for his work on high-profile tax controversies, both national and international in scope. "He is a remarkable guy," said one impressed client, adding: "I couldn't begin to describe the superlative experience of working with him. He is just outstanding!" Cohen has represented a number of partnerships in matters before the US Tax Court and the US Court of Federal Claims.  

Market observers agree that Jerome Libin is "just super." He heads the group out of DC and, like Cohen, is considered a dean of the nationwide tax controversy Bar. He offers counsel on a range of domestic and international tax controversy and litigation matters, including transfer pricing, and recently represented AIG in a refund suit seeking the return of approximately $306 million in tax, penalties and interests. 

THE FIRM This excellent tax boutique provides expertise in international tax controversy, civil tax disputes, litigation and voluntary disclosure, offering an integrated nationwide service out of Washington, DC. The already distinguished tax fraud practice has been strengthened by some recent significant additions. Clients are particularly quick to commend the group's credibility with regulators and other firms. 

Sources say: "They are on top of all aspects and their work is clearly respected by the IRS and many others."

KEY INDIVIDUALS Firm president Scott Michel spearheads the firm's criminal tax fraud work and regularly handles voluntary disclosure matters. One interviewee said: "I don't know anybody in the US who is more knowledgeable and accessible in his area of the law. He is super accessible, sound and calming – no weaknesses at all!" Over the past year, Michel has represented very wealthy individuals as well as a famous sports personality in voluntary disclosure matters.  

Cono Namorato maintains an excellent reputation for financial fraud and criminal tax investigations, complex voluntary disclosures and civil IRS examinations, frequently advising worldwide professional firms and Fortune 500 corporations. "He is absolutely great – whatever he does, he does it really well," enthuse clients.

Mark Matthews recently joined the group from Morgan, Lewis & Bockius. Peers describe him as "outstanding," highlighting his prominence in the foreign disclosure field over the past few years. In addition to handling hundreds of foreign disclosure matters in the last year, Matthews also recently successfully converted a criminal employment tax investigation to civil resolution. 

David Rosenbloom is an icon in the nationwide tax arena, praised by sources as a "terrific, terrific lawyer." He focuses on international and cross-border controversies, and dedicates a substantial part of his practice to serving as an expert witness in complex domestic and international tax disputes. In the last year he advised a major association of banks and financial institutions on the administrative and tax implications of the Foreign Account Tax Compliance Act.  

Sources agree that Christopher Rizek is "a well-regarded and knowledgeable top practitioner." He represents corporate and individual clients in tax disputes concerning insurance and benefit issues, transfer pricing, debt financing and high net worth audit and penalty matters. Clients note: "He is well connected and his advice as to how the government will react and what other players might do has been spot on."

THE FIRM Market sources praise this firm's brilliant tax litigation expertise, and also highlight its impressive nationwide profile. It undertakes work on a federal, state and local level, and has a particular forte in civil and criminal tax controversies. The team is based across offices in Atlanta, Houston and Philadelphia, and also offers expertise on tax shelters, estate and gift taxation. Major clients include HollyFrontier and Wells Fargo.  

Sources say: "They did a great deal of research and are very tenacious. They also worked very well with the in-house counsel at our company."

KEY INDIVIDUALS Larry Campagna is applauded for his top-drawer work on criminal and civil tax litigation. In addition to handling hundreds of voluntary disclosure matters, he also recently represented Western Refining and Discovery Couer d’Alene Investors in two separate Tax Court cases. "I was very impressed with his responsiveness, knowledge and experience," said one client.

Atlanta-based "top-flight litigator" David Aughtry focuses on civil and criminal tax litigation, and is highlighted by peers for his particularly strong performance in tax shelter work. According to commentators, "no one works harder." 

Widely experienced trial lawyer Philip Karter is based in Philadelphia and is noted for his familiarity with the IRS and judges. Clients applaud him as being "intelligent, professional, creative, even-keeled and technically very sound." He recently represented Wells Fargo in federal tax refund litigation worth $423 million.

Herbert Odell has more than 40 years of experience in tax controversy and litigation, and also counsels clients on tax planning matters. "He is the only tax attorney I have met who understands tax planning as well as litigation," said one client, adding: "This is an important combination, of which he has complete knowledge."

Juan Vasquez comes highly recommended for his expertise in federal, state and local tax controversies, handling matters all the way from examination level to trial. In addition to his strong subject matter expertise, sources praise his friendly and helpful manner.  

THE FIRM This Houston-headquartered tax controversy team handles IRS examinations, tax shelters, gift tax matters and litigation, regularly acting for clients in the oil and gas industry. The group continues to expand its work in the tax fraud arena, and has been involved in a number of criminal investigations of late. Expertise in state and local tax controversy further rounds out the practice.

Sources say: "They have a lot of horsepower and a very strong practice in oil and gas work."

KEY INDIVIDUALS Jasper Taylor is held in high regard for his strong nationwide tax controversy and litigation practice. He represents clients from a wide range of industries, including telecommunications, energy and real estate, on both administrative proceedings and litigation. His impressive client list includes Intergys Group and Academy Sports & Outdoors.

Senior tax star Charles Hall is of counsel to the firm and continues to enjoy a fantastic nationwide reputation for complex court work. "He is a great lawyer and one of the nicest people I have ever encountered," enthused one interviewee.

THE FIRM Steptoe & Johnson rises in the rankings this year in recognition of its impressive workload and strong feedback from interviewees. Its strong tax litigators have experience trying cases in every court, including the Supreme Court, and are also highly adept at resolving cases pre-litigation. The group handles IRS audits and appeals, administrative controversies and tax shelter controversies. A number of its recent highlights have been highly complex, international in scope and exceeded billions of dollars in value. Key clients include Thermo Fisher Scientific, Cargill and Amazon. 

Sources say: "I interact with a lot of firms and this firm is the most reliable in terms of the advice I get."

KEY INDIVIDUALS Arthur Bailey specializes in complex and high-profile tax litigation, including defending cross-border investments, and is singled out as a top choice for life insurance tax matters.

Walker Johnson is highly recommended for complex financial and investment tax issues, and is also highlighted for his expertise in life insurance-related tax.

Matthew Lerner's broad tax controversy practice extends from pre-audit advice to litigation in Federal Courts. "He is first rate and one of the smartest people I have ever met," said one client. "He is very client-oriented and is a great advocate and lawyer."

THE FIRM This top-notch tax fraud firm is known throughout the country for representing individuals and corporations in white-collar criminal and civil tax litigation. Clients applaud the team's exceptional strength in foreign disclosure and other offshore disputes, as well as its attentive and flexible approach. It frequently represents high-profile business, sports and government community members, as well as a number of Fortune 500 corporations. 

Client Service "I have been exceptionally impressed with their services. They are extremely diligent, hard-working and intelligent, and they give their clients a fair reflection of the law. They are very responsive at all times and very personable."

KEY INDIVIDUALS Robert Fink is "nothing short of great – he's extremely bright, knowledgeable and patient, and tells it like it is,” say clients. Fink is prominent in the nationwide tax controversy community, with expertise spanning civil and criminal tax and white-collar criminal defense.

Bryan Skarlatos is "extremely knowledgeable and very well connected to the various taxing authorities," according to interviewees. His wide-ranging practice covers voluntary disclosure, white-collar criminal investigations, civil and criminal tax controversies and whistleblower claims. Clients applaud him as being "exceptionally brilliant at coming up with great outcomes."

THE FIRM This dynamic group is well regarded for handling a range of international, federal, state and local tax disputes. Many of its impressive attorneys have prior government experience, which informs their advice on matters including foreign disclosure, inter-company tax disputes, transfer pricing, IRS audits and appeals. The team recently acted for Iberdrola in one of the largest tax cases of 2011, involving close to $1 billion. Other major clients include Cisco Systems, Exelon and Bunzl USA.  

Sources say: "It is a good and well-run firm with a good corporate ethos."

KEY INDIVIDUALS Clients praise William Colgin as being "knowledgeable, professional, experienced and pleasant to work with," adding: "He is also very adept at navigating the client through both the audit and appeals processes." Colgin is singled out as a force when it comes to complex and high-value federal disputes, and recently resolved a sophisticated multi-issue transfer pricing dispute at IRS Appeals level.

THE FIRM Morrison & Foerster is perhaps best known for its exceptionally talented state and local tax controversy team, but also houses a substantial number of federal tax controversy specialists. The team advises on matters relating to transfer pricing, bad debts, insurance and financial products and executive compensation, and is active in a large number of states. It provides impressive national coverage with attorneys spread across six offices on both coasts, including San Francisco, Denver and New York. 

Sources say: "They have all been very supportive, timely and responsive, and we have found great value in what they have provided to us."

KEY INDIVIDUALS Paul Frankel is "a very good attorney and one of the top people in the state and local tax field in the USA," clients enthuse. He is based in New York but has handled complex state and local tax controversies in almost every state. He continues to represent General Mills in California state tax controversy involving the Franchise Tax Board.

Washington, DC-based Edward Froelich specializes in federal tax controversies, and recently advised the official creditors' committee for Ambac Financial Group on its adversary proceedings against the IRS concerning tax refunds worth approximately $700 million. Clients report: "He is a fantastic tax attorney who has terrific IRS, tax planning and audit experience. He is very effective, thorough and a pleasure to work with."

THE FIRM This talented tax group advises individuals, new business ventures and large multinational corporations on federal, state and local tax controversy and litigation matters, and clients are particularly quick to commend its expertise in real estate taxes. The team recently represented Apple in a complex case concerning California state franchise and income taxes.

Sources say: "The firm’s response time, business acumen and industry knowledge, advice and depth were all outstanding."

KEY INDIVIDUALS San Francisco-based William Bonano is held in high regard for his work on a range of domestic and international tax controversies, including transfer pricing and litigation. Expertise on tax shelter regulation further rounds out his practice.

THE FIRM The tax controversy team at Vinson & Elkins provides strong representation to clients at all stages of federal controversy, including examination, administrative appeals, trial, and appellate review. It is lauded for its forte in oil and gas taxation, and also represents entertainment, software, healthcare, retail and insurance industry clients. Major highlights include representing Trinity Industries in a federal income tax refund case in Dallas District Court.

Sources say: "I know when we initiate contact with them that they will respond ASAP, usually within the hour. We feel that we get exceptional value for our money given the complex matters we utilize them for."

KEY INDIVIDUALS Houston-based practice head George Gerachis is well respected for his broad-based tax controversy practice. Impressed clients report: "He is always available and is one of these guys who is very comfortable sharing his opinions, which has made him a great sounding board and a trusted adviser. He's really responsive as well." Gerachis has recently represented BMC Software, 7-Eleven and Trinity Industries.  

THE FIRM This eight-strong group has experience of litigating cases in all trial courts but is also very well placed to settle disputes through mediation, fast-track settlement procedures, examination and at appeals. It is widely praised for its international and cross-border work, and also represented clients in domestic tax controversies. Clients applaud the group's impressive global presence, and highlight transfer pricing as an area of particular strength.

Sources say: "I think they are very professional, technically sound and knowledgeable. Very intelligent folks who communicate very well with us as clients."

KEY INDIVIDUALS International tax controversy specialist Michael Quigley is "friendly, warm, engaging and a great negotiator," clients report. He has a wealth of experience in litigating and negotiating settlements on matters including debt and equity issues, transfer pricing, civil fraud penalties and life insurance company taxation. He also has a forte in matters concerning US relations with India and Korea. Noteworthy work includes representing Verizon Wireless in a refund suit pending in the US Court of Federal Claims.

Brian Gleicher focuses on domestic and international tax controversies, including transfer pricing, earning praise for his helpful ties with tax authorities. Clients enthuse: "He is very responsive, thorough, energetic, patient and helpful." "I was very impressed with his representation of our company and his interpretation of the tax law," said one.