パートナー

Joel V. Williamson

Insurance, International Tax & Transfer Pricing, Litigation & Dispute Resolution

"He is absolutely a star, he has been a father of controversy for decades and is such a luminary in the field."

"Joel is the leading expert in his field. He uses his experience to inform his advice and seems to always be one step ahead because he has dealt with so many situations before. He is superb at what he does."

Chambers USA

概要

Joel Williamson, co-leader of Mayer Brown’s Tax Controversy & Litigation team, is widely acknowledged as one of the nation's leading tax attorneys and litigators. He has litigated over 60 tax cases. His unprecedented experience includes the trial of seven major IRC 482 transfer pricing cases, including Eli Lilly, G.D. Searle, Westreco (Nestlé), Seagate Technology, National Semiconductor, United Parcel Service and Eaton Corporation. Most recently, Joel represented Hyatt and Tribune Media and Chicago Baseball Holdings where both resulted in substantial taxpayer victories. Joel has represented the following clients in tax litigation cases: Nestlé, UPS, Cross Refined Coal (Fidelity), Tyco, Boston Scientific, Consolidated Edison, Intel Corporation and others.

経験

  • Cross Refined Coal, LLC v. Commissioner, 45 F.4th 150 (D.C. Cir. 2022) aff’g T.C. Docket No. 19502-17, Index No. 177 (Aug. 29, 2019), 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)
  • Cross Refined Coal, LLC v. Commissioner, T.C. Docket. No. 19502-17, Index No. 177 (U.S. Tax Ct. Aug. 29, 2019) (finding that refined coal production partnership was a bona fide partnership and that its partners were bona fide partners).
  • Hyatt Hotels Corporation v. Commissioner, T.C. Memo 2023-122 (ruling in taxpayer’s favor on a section 481 change in method of accounting issue that represented about 95% of the total dollars at issue in a dispute concerning the taxation of a loyalty rewards program)
  • EOG Resources, Inc. & Subsidiaries v. Commissioner of Internal Revenue, T.C. Docket No. 012794-17 (alternative minimum tax preference for intangible drilling costs).
  • Tribune Media Company v. Commissioner of Internal Revenue, T.C. Memo. 2021-22 (sustaining use of leveraged partnership). Appeal Docketed, Nos. 23-1135 et al (7th Circuit Jan. 20, 2023).
  • Eaton Corporation v. Commissioner (T.C. Memo 2017-147) (IRC § 482 reallocations and the cancelation of advance pricing agreements; tried in August/September 2015), aff’d 47 Fed.4th 436 (6th Cir. 2022).

受賞

  • Recognized as a "Leading Lawyer" by Chambers USA since 2003 in Nationwide – Tax Controversy and Illinois – Tax.
  • Recognized as a "Leading Lawyer" by Legal 500 for US Taxes: Contentious since 2008 and in 2017 inducted into The Legal 500 Hall of Fame which highlights individuals who have received constant praise by their clients for continued excellence.
  • Recognized as a leading Tax Controversy adviser by International Tax Review for Tax Controversy since 2012.
  • Named "The Best of the Best USA - Transfer Pricing" by Expert Guides.
  • Named "Tax Litigation Attorney of the Year" by ACQ.

学歴

  • Davidson College, BA
  • University of Kentucky College of Law, 法務博士
    University of Kentucky Law Review; Moot Court Board; National Moot Court Team, Order of the Coif

登録

  • Kentucky
  • イリノイ州弁護士

Courts

  • US Supreme Court
  • US Court of Federal Claims
  • US Court of Appeals for the Federal Circuit
  • US Court of Appeals for the Second Circuit
  • US Court of Appeals for the Sixth Circuit
  • US Court of Appeals for the Seventh Circuit
  • US Court of Appeals for the Eighth Circuit
  • US Court of Appeals for the Ninth Circuit
  • US Court of Appeals for the Eleventh Circuit
  • US Court of Appeals for the District of Columbia Circuit
  • US Court of Federal Claims
  • US District Court for the Northern District of Illinois
  • US District Court for the Northern District of Ohio
  • US District Court for the Western District of Pennsylvania
  • Illinois Supreme Court
  • US Tax Court
  • Trial Bar of the US District Court for the Northern District of Illinois

使用言語

  • 英語

社会活動

  • Board of Trustees, Davidson College
  • Board of Visitors, Davidson College
  • Kentucky Bar Association
  • United States District Court Trial Bar, Northern District, Illinois
  • American Bar Association
  • The American Club of Paris
  • The Chicago Club
  • Board of Directors, The Joffrey Ballet, Inc.
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