Übersicht

Will McGarrity is a partner in Mayer Brown's Chicago office. He advises clients navigating complex tax and regulatory issues with an eye towards delivering practical solutions. When controversies arise, he represents clients in examinations, administrative appeals, and litigation. His work encompasses issues related to tax-exempt governance and compliance, transfer pricing, competent authority, valuation, debt-equity characterization, economic substance, subpart F, and administrative procedure as applied to the IRS regulatory process.

Audit Preparation, Administrative Proceedings, and Litigation: Will has experience resolving contentious, high-value examinations and litigating major corporate cases. Notable cases include Altera, the Tyco debt-equity litigation, and the Guidant/Boston Scientific transfer pricing litigation. Throughout these litigation matters, Will has worked extensively with leading trial experts in the fields of economics, finance, and forensic accounting.

Not-for-profit Organizations: Will is a trusted advisor to foundations and other not-for-profit organizations on matters of governance, tax qualification, voluntary disclosures, grant making, and litigation. Recognizing the varied legal needs of such organizations, Will routinely works with Mayer Brown lawyers across disciplines to provide comprehensive advice to boards, trustees, and managers.

Transfer Pricing, Tax Advice, and Risk Assessment: Will’s experience also encompasses advising clients on novel issues arising in tax planning, including transfer pricing documentation and structuring. In this planning work, Will draws on his controversy experience to anticipate potential legal pitfalls and expert arguments.

Sprachkenntnisse

  • Englisch

Erfahrung

  • Altera Corporation v. Commissioner of Internal Revenue, 145 T.C. No. 3 (2015), 15-0 reviewed Tax Court opinion, holding invalid section 482 regulations requiring cost sharing participants to share amounts attributable to stock-based compensation.
  • 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).
  • Guidant LLC v. Commissioner of Internal Revenue, T.C. Docket No. 5989-11 (IRC § 482 reallocations).
  • Cardiac Pacemakers, Inc. v. Commissioner of Internal Revenue, T.C. Docket No. 5990-11 (IRC § 482 reallocations).
  • Cardiac Pacemakers, Inc. v Commissioner of Internal Revenue, T.C. Docket No. 10985-11 (IRC § 367 allocations).
  • Tyco Electronics Corp., as successor in interest to Tycom Simplex Holdings, Inc. & Subsidiaries v. Commissioner of Internal Revenue, T.C. Docket No. 16651-13 (debt-equity characterization).
  • Covidien LP, f.k.a. Tyco Healthcare Group, LP, Covidien Holding Inc., f.k.a. SWD Holding, Inc. I, Tax Matters Partner v. Commissioner of Internal Revenue, T.C. Docket No. 16663-13 (debt-equity characterization).
  • ADT Holdings, Inc. & Subsidiaries v. Commissioner of Internal Revenue, T.C. Docket No. 19556-13 (debt-equity characterization).
  • Tyco Electronics Corp., formerly known as AMP, Inc., & Subsidiaries v. Commissioner of Internal Revenue, T.C. Docket No. 16654-13 (debt-equity characterization).
  • Tyco Electronics Corporate Holdings, Inc., as successor in interest to Tyco Holdings, Inc. & Subsidiaries v. Commissioner of Internal Revenue, T.C. Docket No. 16661-13 (debt-equity characterization).
  • Tyco Electronics Corp., as successor in interest to Tyco International (PA), Inc. & Subsidiaries v. Commissioner of Internal Revenue, T.C. Docket No. 16659-13 (debt-equity characterization).
  • Tyco Electronics Corp., as successor in interest to TSSL Holding Corp. & Subsidiaries v. Commissioner of Internal Revenue, T.C. Docket No. 16655-13 (debt-equity characterization).
  • Tyco Electronics Corporate Holdings, Inc., as successor in interest to Tyco (US) Holdings, Inc. & Subsidiaries v. Commissioner of Internal Revenue, T.C. Docket No. 16658-13 (debt-equity characterization).
  • Tyco Electronics Corp., as successor in interest to Tycom (US) Holdings, Inc. & Subsidiaries v. Commissioner of Internal Revenue, T.C. Docket No. 16662-13 (debt-equity characterization).
  • United States Surgical Corporate & Subsidiaries v. Commissioner of Internal Revenue, T.C. Docket No. 16664-13 (debt-equity characterization).
  • ADT Holdings, Inc. v. Commissioner of Internal Revenue, T.C. Docket No. 16656-13 (Withholding Tax).
  • Sherwood Medical Company I v. Commissioner of Internal Revenue, T.C. Docket No. 16652-13 (Withholding Tax).
  • Covidien Group S.A.R.L., f/k/a Tyco Group S.A.R.L. v. Commissioner of Internal Revenue, T.C. Docket No. 16653-13 (IRC § 881).
  • Tyco Electronics Corp., as successor in interest to Tyco International (PA), Inc. v. Commissioner of Internal Revenue, T.C. Docket No. 16657-13 (Withholding Tax).
  • Tyco Electronics Corporate Holdings, Inc., as successor in interest to Tyco (US) Holdings, Inc. v. Commissioner of Internal Revenue, T.C. Docket No. 16660-13 (Withholding Tax).

Ausbildung

Harvard Law School, JD, cum laude

University of Cambridge, LLM

University of Michigan, BBA, with high distinction

Zulassung

  • Illinois

Gericht

  • US Tax Court
  • US Court of Federal Claims
  • US Court of Appeals for the Ninth Circuit
  • US District Court for the Central District of Illinois