Tax: Controversy (Band 4)
Practice Areas: Thomas Kittle-Kamp represents clients in tax controversy and litigation. His experience includes the trial and appeal of major corporate cases involving Section 482 allocations, substance-over-form theories, intangible assets, valuation disputes, capitalization questions, Subchapter C issues, and leasing transactions. Tom also represents clients in IRS audits, IRS Appeals and competent authority negotiations. Tom has deep experience in all aspects of international transfer pricing, particularly matters involving intangible assets and intellectual property, and provides tax planning advice with respect to cross-border transactions. He co-authors the treatise Federal Income Taxation of Intellectual Properties and Intangible Assets (Warren, Gorham & Lamont 1997).