Partner

John T. Hildy

Tax Controversy & Litigation

"Experienced, practical and a strong business partner."
Chambers USA

Overview

For over 25 years, clients have relied on John Hildy for advice in high-value federal tax disputes. Both in the courtroom and at the administrative stages, John’s background in both accounting and law makes him uniquely positioned to address complex tax controversies that require a deep understanding of a client’s business model and financial data, such as accounting method and transfer pricing issues.

Tax Litigation: John represents clients in some of the most complex tax litigation in the country. For instance, he recently led the legal team during a three-week trial in the US Tax Court on behalf of Hyatt Hotels Corporation, in a case involving the IRS’s attempt to change accounting methods for a guest loyalty program. Notably, he also led the team representing Boston Scientific Corporation in litigating over $4 billion of transfer pricing and related adjustments before the Tax Court.

Experience

  • Hyatt Hotels Corporation v. Commissioner, T.C. Docket No. 13858-17 (tax consequences of customer loyalty program).
  • Eaton Corporation v. Comm'r, (T.C. Memo 2017-147). (IRC 482 reallocations and the cancelation of advance pricing agreements).
  • Guidant LLC v. Commissioner of Internal Revenue, T.C. Docket No. 5501-12 (IRC 482 reallocations).
  • Cardiac Pacemakers, Inc. v. Commissioner of Internal Revenue, T.C. Docket No. 5502-12 (IRC 482 reallocations).
  • Boston Scientific Corporation v. Commissioner of Internal Revenue, T.C. Docket No. 26876-11 (IRC 482 reallocations).

Recognition

  • Recognized for Tax Controversy – Illinois, and “A very impressive lawyer… [an] experienced, practical and a strong business partner” - Chambers USA
  • Listed in the International Tax Review’s Tax Controversy Leaders guide
  • A “leading lawyer” - Legal 500
  • “A very impressive lawyer… [an] experienced, practical and a strong business partner.” – Chambers USA

Education

  • Northwestern University School of Law, JD
  • University of Illinois, BA, finance, with distinction
  • Certified Public Accountant, Illinois

Admissions

  • Illinois

Courts

  • US District Court for the Northern District of Illinois
  • US Court of Federal Claims
  • US Tax Court
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