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John T. Hildy

John T. Hildy

Partner
T +1 312 701 7769
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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.

Tax Litigation: John is an experienced advocate in federal tax disputes faced by multi-national corporations. He has represented clients in some of the most complex tax litigation in the country. The amounts at stake in federal tax disputes can often be staggering. So big, in fact, that it often seems cases become “too big to settle,” as the positions of the tax authorities and taxpayers are separated by hundreds of millions, and even billions, of dollars. John is adept at bridging this gap. Over the course of his career, he has participated in settlements of two disputes in which the dollars at stake reached into ten digits.

IRS Administrative Proceedings: John’s practice emphasizes issue resolution at the earliest stage feasible, not just on the steps of the courthouse. To that end, John has experience using a broad set of alternative dispute resolution tools, including:

  • Tax Court-supervised mediation;
  • IRS Appeals review of docketed issues;
  • Early referral to Appeals
  • Fast Track and Appeals Mediation;
  • Pre-filing Agreements (PFAs); and
  • Competent Authority and Advanced Pricing Agreements (APAs)

John frequently advises clients in addressing the types of evidentiary privileges most commonly encountered by the Tax Department (e.g., attorney-client, tax advisor, work product privileges) and represents taxpayers in associated administrative summons enforcement matters where necessary.

International Tax and Transfer Pricing: The mainstay of John’s controversy practice relates to disputes surrounding international tax matters, especially transfer pricing. As a complement to John’s controversy practice, he also regularly advises clients on how to structure and defend transactions with significant transfer pricing implications, including cross-border transfer pricing of tangible and intangible property, shared headquarter services, and cost sharing arrangements. He has advised both US taxpayers with respect to international tax implications of off-shore operations, as well as non-US taxpayers with respect to the implications of their US activities.

John has been recognized by Chambers USA (Tax Controversy - Illinois) since 2016 and in the International Tax Review’s Tax Controversy Leaders guide since 2011.

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