Overview

Jeremy Himmelstein advises multinational corporations, partnerships, and high net-worth individuals in all stages of federal tax controversy, including trial. Jeremy has experience preparing witnesses, navigating contentious evidentiary issues, and drafting motions and post-trial briefs. He was recently part of a Mayer Brown team that represented a client in a three-week trial in the US Tax Court.

Jeremy also supports clients through IRS audits, administrative appeals, and competent authority proceedings. He has experience with transfer pricing, substance over form and related judicial doctrines, privilege disputes, income characterization and deductibility questions, and penalty issues. He is also a contributor to Best Methods, Mayer Brown’s blog on transfer pricing law and policy.

Areas of Focus

Practices

Experience

  • Anadarko Petroleum Corp. et al. v. Commissioner of Internal Revenue, T.C. Dkt. Nos. 23018-18, 23019-18 (Ongoing case challenging the IRS’s determination that a settlement payment is not deductible)

Perspectives

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Education

Georgetown University Law Center, LLM in Taxation with Distinction
Dean’s List, Graduate Tax Scholar

University of Maryland, BA

University of Maryland School of Law, JD, cum laude
Executive Technology Editor, Journal of Business & Technology Law 

Admissions

  • District of Columbia
  • Maryland

Court

  • US Court of Federal Claims
  • US Tax Court