Partner

Geoffrey M. Collins

Tax, Tax Controversy & Litigation, International Tax & Transfer Pricing

Übersicht

Geoffrey Collins represents clients in all phases of tax controversy, both in court and before the Internal Revenue Service.

His experience includes major trials and Appellate cases as well as large corporate tax matters before IRS Exam and IRS Appeals. In addition, his experience includes the successful use of alternative-dispute-resolution initiatives such as the Pre-Filing Agreement program. He has represented clients in controversies involving advance pricing agreements, transfer pricing, timing of pension contribution deductions, section 199 domestic production activity deductions, carrybacks of Net Operating Losses and other tax attributes, debt-equity characterization of intercompany advances, deductibility of settlement payments under the False Claims Act, summons enforcement, and the application of economic substance, sham-transaction, and similar substance-over-form doctrines.

Erfahrung

  • Eaton Corp. v. Commissioner, --- F.4th ----, No. 21-1569, 21-2674 (6th Cir. August 25, 2022) (holding that Advance Pricing Agreements were subject to ordinary contract principles and that the IRS invalidly cancelled Advance Pricing Agreements and failed to timely plead penalties)
  • Cross Refined Coal, LLC v. Commissioner, --- F.4th ----, No. 20-1015 (D.C. Cir. August 5, 2022) (holding that refined coal partnership was a bona fide partnership and affirming that, where a partnership undertakes an activity made profitable by tax credits, it engages in legitimate business activity for tax purposes)
  • GSS Holdings (Liberty) Inc. v. United States, No. 1:19-cv-00728 (Federal Circuit) (ongoing case of first impression about the limitations on the IRS’s use of the step transaction doctrine and the application of the party presentation principle)

verwandte Beratungsfelder und Industrien

Ausbildung

  • Cornell Law School, JD, magna cum laude
    Cornell Law Review
  • University of Kansas, BM, magna cum laude

Zulassungen

  • Illinois
  • New York

Sprachen

  • Englisch
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