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Reeves Westbrook is the coordinator of the firm's tax practice group. His practice concentrates on the needs of large corporate taxpayers, including both counseling and tax controversies.
Mr. Westbrook has provided counseling on international asset transfers and tax optimal corporate structures, acquisitions and dispositions, cross-border transfer pricing, cross-border financings, tax credit planning, foreign and domestic joint ventures and partnerships. Mr. Westbrook also counsels clients on regulatory and legislative issues and matters before the national office of the Internal Revenue Service.
Mr. Westbrook's controversy experience includes audits, administrative appeals and litigation. Mr. Westbrook has handled controversies in a broad spectrum of subject matter areas, including foreign tax credits, accounting and capitalization, valuations and purchase price allocations, research and development credits and deductions, income and expense reallocations under Section 482, treatment of corporate reorganizations and restructurings, computation of allowable FSC benefits, treatment of items under the consolidated return regulations, allocations under Section 861, partnership issues, allowance of losses on subsidiary stock, form over substance and Subpart F inclusions.
Mr. Westbrook is an active participant in the International Bar Association having coordinated and co-chaired panels on tax controversy issues at the last 2 annual meetings of the IBA.
Representative Clients: Eastman Kodak Company, GE Capital Corporation, International Business Machines Corporation, Microsoft Corporation, Norfolk Southern Corporation, Unisys Corporation, United Technologies Corporation.
Mr. Westbrook was listed in the 2007 edition of Best Lawyers in America and chairs the Transfer Pricing and Litigation Subcommittee of the International Bar Association’s Tax Committee. He has spoken or co-chaired panels on tax controversy at annual meetings of the IBA.
Honors and Rankings
- Chambers USA - America's Leading Business Lawyers, Tax (2008)
- Legal 500 US, Tax - Domestic Tax - East Coast (2008)
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