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Joel V. Williamson

Joel V. Williamson

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Tax Controversy Team of the Year

The Legal 500 US Awards recognized Mayer Brown as Team of the Year for Tax Controversy for the second consecutive year. The award honors the best private practice teams over the past 12 months.

"A dean of the tax controversy Bar, revered for his 'spectacular courtroom manner and skills.'"

Chambers USA 2010

Joel Williamson 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. Eaton, which also involved the cancellation of two Advanced Pricing Agreements, was decided by the US Tax Court on July 26, 2017, and resulted in a rare 100% transfer pricing taxpayer victory. Recently, Joel served as trial counsel in the Guidant LLC and Eaton cases, each involving IRC 482 issues. Joel has also litigated numerous cases involving economic substance of transactions, including the United Parcel Service case noted above, as well as the Saba Partnership (Brunswick) case, and Mukerji (Comdisco), an important test case for tax-advantaged computer leasing transactions involving Comdisco. More recently, Joel litigated ConEd which involved an international Lease-In-Lease-Out transaction and Flextronics which involved an international merger and acquisition transaction. Both ConEd and Flextronics witnessed IRS arguments of economic substance and generic tax doctrines including substance over form and step transaction. Recently, Joel litigated Exelon which involved a like-exchange of utility assets that the IRS challenged on economic substance and substance over form grounds.

In the international tax area, Joel has litigated Subpart F, constructive triangular dividend, R&D Moratorium, Brazilian and other foreign tax credit for banks, including Bankers Trust and Riggs Bank, as well as Iranian loss investment in U.S. property (IRC 956) and foreign-versus-domestic-source income (IRC 863(b)) questions. He has litigated two significant captive insurance cases involving Humana, Inc. and Gulf Oil Corporation. In addition, Joel has litigated IRC 338 corporate acquisition related issues, including goodwill, intangible and inventory valuations and second-tier allocations involving Nestlé's acquisition of Carnation.

Joel litigated the Tribune Company case, which dealt with whether a divestiture of a subsidiary qualified as a tax-free corporate reorganization. He has litigated significant tax accounting issues, including unbilled revenue and cap interest rate loan questions. Joel has also litigated significant procedural questions, including the proper role of IRS trial counsel in the audit examination process. He is also experienced in summons enforcement actions for both foreign and domestic records.

Chambers, a leading professional directory, consistently recognizes Joel as "a dean of the tax Bar" and an industry leader. Chambers USA has praised Joel throughout the year as:

  • "Absolutely superb."
  • "A top-notch litigator; he has a lot of experience in significant tax cases and helps to manage our expectations; he couldn't do any better." Among his many honors, he is known as "the godfather of transfer pricing litigation."
  • A "fantastic individual" and adding: "If you know the IRS is going to go to the net and alternative dispute resolution is not attainable, you want Joel on your side."
  • "Joel is one of the most successful controversy attorneys in the USA...his experience is almost unrivaled...[he is an] 'obvious standout' in the national tax market...[and is] 'especially adept at arguing the most technical issues.'"
  • "'Probably has more experience in litigating cases than any lawyer in the USA'...'enormous presence and stature' [with] 'long history with transfer pricing litigation'"
  • "Leading light"
  • "Great strategist and tactician" who "takes the role of service provider very seriously"
  • "A dean of the tax controversy Bar, revered for his 'spectacular courtroom manner and skills'"
  • "Unparalleled battleground experience"
  • "Constantly on top of his game"
  • "Exhaustive preparation"
  • "Fearless and tireless"
  • "Much admired in the profession for his ability to identify the issues at hand quickly and incisively"

Joel is proud to have been recognized by Chambers USA as: "Leading Lawyers," 2003-2004, 2004, 2005, 2006, 2007, 2008, 2009, 2010, 2011, 2012, 2013, 2014, 2015, 2016, 2017 and 2018. In addition, he was recognized by Legal 500 as a "Leading Lawyer" in 2008, 2011, 2012, 2013, 2014, 2015 and 2016, describing Joel as a, "highly skilled trial attorney possessing great judgment."  In 2017, Joel was inducted into The Legal500 Hall of Fame which highlights individuals who have received constant praise by their clients for continued excellence. He is also further recognized as a leading Tax Controversy adviser in the 2012, 2013, 2015 and 2016 International Tax Review "Tax Controversy Leaders Guide," as well as a leading Transfer Pricing advisor in Expert Guides "The Best of the Best USA 2013 - Transfer Pricing." Joel was also named "2015 Tax Litigation Attorney of the Year" by ACQ.

Mayer Brown was named “Tax Controversy Team of the Year” for the second consecutive year in 2015 in the Legal 500 United States Awards. "Mayer Brown is 'among the best' and fields a large team…dedicated exclusively to tax controversy and transfer pricing," said Legal 500 and its sources in the US edition. The firm is "regularly seen in the most high-profile controversy cases before the US Tax Court" and produced "yet another impressive run of work" in 2014.

Joel served as an officer in the United States Army from 1970 to 1972, assigned to the Offices of the Staff Judge Advocate, 12th Support Brigade, Ft. Bragg, NC, and subsequently to Saigon Support Command, the Republic of South Vietnam. After his return from Vietnam in 1972, Joel joined the Chief Counsel's Office, US Department of Treasury. In 1978, he was appointed one of 20 Special Trial Attorneys located throughout the United States. Joel joined Mayer Brown in 1986 and was named partner that same year.

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