Christine Hooks is an associate in the Tax Controversy practice of the Washington office. She represents taxpayers in all stages of federal tax controversies, drawing upon her decade of litigation experience in district courts, US Tax Court, US Court of Federal Claims, and bankruptcy courts. She has substantive experience in a wide variety of complex issues, including transfer pricing, advance pricing agreements, the valuation of intangibles, prepayment of intercompany royalties, the research tax credit, foreign tax credits, economic substance and substance over form issues, and the calculation of overpayment interest. Since joining Mayer Brown, Christine has represented multinational corporate taxpayers in tax litigation involving issues related to intercompany transactions, including transfer pricing and economic substance.
Christine’s significant government experience brings a unique perspective to resolving tax controversies, both at and prior to trial. Christine previously served as counsel to the Deputy Assistant Attorney General for Civil Trial Matters and practiced as a trial attorney with the Department of Justice, Tax Division. As a trial attorney Christine represented the government as lead counsel in approximately one hundred tax-related matters in the US district and bankruptcy courts. This experience incorporated extensive motion practice, including successfully moving for judgment on the pleadings on a $450 million claim for overpayment interest. Christine also negotiated numerous settlements and represented the government as lead counsel at depositions and trial. Prior to her tenure with the Tax Division, Christine served as a law clerk to the Honorable Nancy B. Firestone of the US Court of Federal Claims.
Christine also has particular experience litigating summons enforcement actions and privilege claims, including serving as lead trial counsel in the widely-reported case Valero Energy Corp. v. United States, involving the tax shelter exception to the tax practitioner privilege. Since joining Mayer Brown she has drawn upon this experience to represent taxpayers in summons enforcement actions and motions involving issues of privilege. Christine is a recognized member of the tax controversy community. She is the Chair-Elect of the Federal Bar Association Section on Taxation and was recently selected as a “Rising Star” in the 2015 edition of Washington, DC Super Lawyers. While at the Tax Division she was awarded an Outstanding Attorney Award and two Special Commendations. She is also a frequent speaker on issues related to tax controversy, and has presented to such organizations as the Tax Executives Institute, the American Bar Association, the Federal Bar Association, and the D.C. Bar.