Tyler M. Johnson

Tyler Johnson advises clients facing high-stakes tax disputes. Clients rely on Tyler to represent them in all phases of tax controversies, including pre-audit planning, examination, administrative appeal, competent authority procedures, litigation, and trial.

Tyler—with a background in accounting, finance, and law—helps clients navigate complex disputes that demand a deep comprehension of financial and economic data, such as transfer pricing, international tax, and accounting methods. And Tyler brings an insider’s perspective on trial preparation and presentation from his experience clerking at the US Tax Court.

Tax Litigation: Tyler represents clients in some of the most complex tax litigation in the country. For example, he recently played a critical role in a case in which the US Tax Court ultimately ruled in the taxpayer’s favor on a change in method of accounting issue that represented nearly all of the amounts in dispute related to the taxation of a loyalty rewards program.

IRS Administrative and Competent Authority Proceedings: Tyler has represented clients in all stages of IRS examination and Appeals administrative proceedings. Tyler has also represented clients to resolve transfer pricing and other tax treaty issues through competent authority bilateral and unilateral mutual agreement procedures (MAP) on favorable terms that avoid double taxation.

Transfer Pricing: Tyler regularly counsels multinationals on the transfer pricing of related-party transactions, including the transfer and use of intangible property and intercompany services. Tyler has guided clients through the advance pricing agreement (APA) process with IRS APMA Program to secure them tax certainty on their most complex, highest value intercompany transactions. Tyler has also assisted clients to successfully settle transfer pricing disputes at IRS Appeals, and to prepare for potentially contentious IRS audits. He is also co-editor and a regular contributor to Best Methods, Mayer Brown's blog on transfer pricing law and policy.

• Represented Hyatt Hotels Corporation in US Tax Court case involving a change in method of accounting issue that represented nearly all of the amounts at issue in a dispute about the taxation of its loyalty rewards program (Hyatt Hotels Corporation v. Commissioner).
• Represented offshore oilfield service provider in case involving intangible property transfer pricing adjustments that was successfully resolved at IRS Appeals.
• Advised logistics company seeking multiple APAs through IRS APMA Program to govern transfer pricing of intercompany services and license of intangible property in multiple jurisdictions.
• Represented logistics company through competent authority MAP procedures in disputes over the transfer pricing of intangible property, intercompany services, and withholding taxes.

• Northwestern University Pritzker School of Law, JD, cum laude
  
  • Articles Editor, Northwestern University Law Review
• Northwestern University Pritzker School of Law, LLM in Taxation, with honors
• University of Maryland, BS, Finance
• University of Maryland, BS, Accounting
• Certified Public Accountant, Licensed in District of Columbia and Virginia

• Illinois
• District of Columbia

• Editor and frequent contributor to Best Methods, Mayer Brown's blog on Transfer Pricing Law and Policy
• Co-author, chapter of Mayer Brown's Electronic Discovery Deskbook, published by the Practicing Law Institute
• American Bar Association, Transfer Pricing Committee