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Covington’s tax group advises our multinational clients on their most significant and challenging tax issues. Most members of our group have extensive government experience, including several who have held senior positions at the U.S. Department of Treasury, the Internal Revenue Service, and the U.S. Senate. This experience, combined with our focus and creativity, enable us to develop bespoke solutions for sustained tax minimization in an increasingly regulated world. And, when our clients find themselves in a dispute with the tax authorities, we secure favorable results by efficiently resolving matters as early in the administrative process as possible, and before they are made public. Of course, when unable to achieve a desired outcome in this manner, we litigate.

Our team has experience across all tax disciplines, regularly working on bespoke issues with some of the largest multinational corporations, global financial institutions, sovereign wealth funds, sports teams and leagues, and foreign governments. We work closely with our clients on matters including structural tax planning for global businesses; transactional tax planning for mergers, acquisitions, dispositions, and restructurings; government representation before the IRS, Treasury, and Congress; resolving domestic and international tax controversies in the Exam, Appeals, litigation, and treaty processes; and the development, documentation, and defense of transfer pricing policies.

Our senior lawyers include:

  • Former International Tax Counsel Michael Caballero spent a total of eight years in the U.S. Treasury’s Office of Tax Policy where he was responsible for some of the most important legislative and regulatory projects affecting multinational corporations and financial institutions.
  • Bill Chip is a member of the OECD’s Business and Industry Advisory Committee and author of the “Economic Substance” and “OECD Transfer Pricing Guidelines” Tax Management Portfolios.
  • Rob Culbertson is a former IRS Associate Chief Counsel (International). He also served on the Joint Committee on Taxation during the Tax Reform Act of 1986, and participated in the development of key U.S. international tax rules, including those regarding subpart F, the foreign tax credit, and transfer pricing.   
  • Rob Heller leads our New York-based transactional tax practice. He is a member of the New York City Bar Association’s Committee on Taxation of Business Entities.
  • Former Deputy Tax Legislative Counsel at the U.S. Treasury Lee Kelley led various legislative and regulatory projects, including guidance that implemented codification of the economic substance doctrine. She also served as Deputy Associate Chief Counsel (Corporate) at the IRS.
  • Until he left the U.S. Senate in January 2013, Senator Jon Kyl served on the Senate Finance Committee and as Assistant Republican Leader (Whip), where he worked closely with Senator Mitch McConnell and the House Leadership on major tax legislation, including the 2011 Budget, the 2010 Bush Tax Cut extension, and the 2012 “Fiscal Cliff” negotiations.
  • Susan Leahy leads our tax-exempt organizations practice and focuses on: the formation, policies, and practices of exempt organizations; handles interactions with federal and state tax authorities; and assists clients in complying with the regulation of exempt organizations’ lobbying and political activities.
  • Bob Long, Chair of the firm’s Appellate and Supreme Court Litigation Group, has argued multiple tax cases and also advises clients on administrative law issues.
  • Chair of the tax group, Daniel Luchsinger is an expert on partnership tax, international tax, and related subjects.
  • Former IRS Director of Transfer Pricing Operations Sam Maruca was responsible at the IRS for transfer pricing compliance nationally and for double tax cases arising under U.S. tax treaties. He was also deeply involved in the OECD’s base erosion and profit shifting (BEPS) initiative.   
  • Lead of the firm’s sports tax practice, Jeremy Spector is outside tax counsel to the National Football League, Major League Baseball, the National Basketball Association, the National Hockey League, Major League Soccer, and the UFC.
  • Having previously served in the Treasury Department’s Office of International Tax Counsel, Dirk Suringa is a member of the executive committee of the IFA, USA Branch, and recently testified before Congress on the Foreign Account Tax Compliance Act (FATCA) and international tax reform.
  • Former U.S. Supreme Court clerk Emin Toro is a member of the Inns of Court and has co-authored “Examination and Appeals,” Practical Guide to U.S. Transfer Pricing, Third Edition (December 2014).   
  • Sean Akins is lead tax counsel in a number of pending Tax Court cases, including the Boston Bruins’ case, and is a co-author of Kafka, Cavanagh & Akins, Litigation of Federal Civil Tax Controversies, Second Edition (2015).
  • Howard Berger is a former Senior Adviser to the Director of Transfer Pricing Operations and Special Counsel to the Assistant Chief Counsel (International) at the IRS.

Our lawyers have in-depth expertise in international tax planning for both U.S. and non-U.S. based companies. We develop tailored, tax-efficient structures that help meet our clients’ goals and that can be integrated in their current business operations. To address tax issues involving multiple jurisdictions, we rely on our own experience, and on our network of correspondent firms (including top tax advisory firms in each country) or on our clients’ regular foreign advisors.

Covington’s tax controversy experience includes very large case audits; advance pricing agreements, private letter rulings, and competent authority proceedings; fast track settlements, administrative appeals, and post-IRS appeals mediation; Administrative Procedure Act challenges; and U.S. Tax Court and other litigation involving a broad array of subject matter areas. We understand that efficient resolution of tax controversies requires creativity and a complete understanding of the impact of the controversy and potential resolutions on our clients and their operations.

Working from our Washington, New York, and London offices, our tax lawyers play an integral part in the firm’s M&A and corporate transactions practice and regularly counsel clients on major corporate and partnership transactions. Our expertise includes advising clients on various acquisition structures in public and private mergers and acquisitions, spin-offs and distributions, tax-efficient capitalization of new and existing subsidiaries, and joint venture and fund formation.

Through our practice in the taxation of financial products and investment funds, we regularly advise a diverse group of clients on tax issues raised by new financial transactions and products, including credit derivatives, structured debt, and hedging strategies.

Members of Covington’s tax legislative and regulatory advocacy group regularly represent clients before the U.S. Treasury Department, the IRS, and Congress. Members of our group have extensive and high-level government experience in the legislative, executive, and judicial branches of the federal government, and bring unparalleled understanding of the policy-making process.

Covington’s tax practice as a whole, and our tax lawyers individually, have been ranked as among the best in the United States and internationally, receiving honors from multiple leading publications.

  • Chambers USA (2017) nationally ranked in the tax corporate and finance category and leading DC tax practice.
  • Legal 500 US (2017) ranked in Tax: Financial Products, International Tax, and U.S. Taxes (Contentious and Non-contentious) categories.