Covington & Burling LLP operates as a limited liability partnership worldwide, with the practice in England and Wales conducted by an affiliated
limited liability multinational partnership, Covington & Burling LLP, which is formed under the laws of the State of Delaware in the United States
and authorized and regulated by the Solicitors Regulation Authority with registration number 77071..
Kevin Otero advises and represents multinational corporations, financial institutions, and individuals in all aspects of federal and state tax controversy, including audits, investigations, administrative appeals, and tax litigation.
Kevin has led the successful defense of some of the most complex multi-year and multi-issue tax audits in the country and has represented clients in every facet of tax controversy from administrative phases through judicial proceedings. His experience covers an array of international and domestic tax issues, including transfer pricing, financial products, foreign tax credits, renewable energy incentives, complex corporate restructurings, bad debt and worthless stock, tax-free dispositions, valuation disputes, and privilege issues in the tax context.
He also represents clients in tax-related internal investigations and civil and criminal tax investigations.
Clients across industries benefit from Kevin’s extensive experience negotiating with tax authorities at various levels and his record of success in resolving controversies at various procedural stages, including alternative dispute forums.
Before joining Covington, Kevin served as Senior Tax Counsel & Tax Director of IRS Examinations, Appeals & Litigation for the General Electric Company, where he led the company’s relationship with the Internal Revenue Service and led the defense of tax controversy matters for the company. His time in-house provides clients with unique insights into tax risk management, strategic audit and litigation readiness, and best practices for tax and legal departments.
Kevin speaks regularly on tax controversy topics and is the co-author of chapters in Bloomberg BNA’s Portfolio - Transfer Pricing: The Code, The Regulations, and Selected Case Law, and in LexisNexis’ Practical Guide to U.S. Transfer Pricing. The International Tax Review has consistently recognized Kevin as a leading tax controversy lawyer in the United States.
Outside of his work at Covington, Kevin serves as a member of the Board of Trustees of Prep for Prep (a non-profit focused on bringing educational opportunities to students in underserved communities).
Advising several Fortune 500 companies on multiple matters before the Internal Revenue Service, including issues related to the Tax Cut and Jobs Act of 2017.
Representing former executive of international business in DOJ criminal tax investigation.
Counseling Fortune 50 technology company in developing advocacy strategy for transfer pricing disputes with the IRS.
Led internal investigation of whistleblower allegations of tax and accounting fraud for a multinational company.
Represented Fortune 500 company in protecting from public disclosure in Tax Court litigation proprietary company information.
Led defense of multi-billion dollar worthless stock deduction dispute that raised complex valuation and legal questions and required negotiations at various levels of the IRS.
Representing Fortune 500 financial institution in connection with grand jury investigation.
Negotiated favorable settlement of multinational company’s significant federal district court tax litigation on the eve of trial.
Represented Fortune 200 financial institution before the IRS in developing and negotiating precedent-setting procedure with the IRS related to the institution’s assistance to the U.S. government in combatting tax refund fraud.
Represented financial institutions in federal court litigation concerning the tax treatment of structured financing transactions.
Represented investment partnership in federal district and appellate court litigation involving complex partnership tax issues.
Represented university in state tax litigation the proper tax treatment of a complex restructuring.
Argued successfully on behalf of a retailer in its dispute with state and local authorities concerning the constitutionality of a threatened criminal tax indictment.
Represented multinational manufacturing and technology company in a multi-year and multi-jurisdictional transfer pricing dispute.
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