Tax Controversy and litigation:
John has represented taxpayers in all stages of federal tax controversy, including pre-audit, audit, administrative appeals, and litigation. He is also experienced in representing taxpayers during IRS "Fast Track" proceedings and in court-supervised mediation. John has also advised taxpayers in connection with competent authority negotiations, advance pricing agreements, and other tax treaty matters.International tax and transfer pricing:
John's practice focuses heavily on defending and structuring 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 (e.g., Subpart F manufacturing, section 936), as well as non-US taxpayers with respect to the implications of their US activities. Tax procedure:
John has extensive experience defending against civil and criminal tax penalties and in addressing evidentiary privileges in the tax controversy context, including the attorney client privilege and work product protection in the modern business environment in light of IRS policies concerning tax accrual work papers and FASB Interpretation ("FIN") No. 48.
John has been recognized as a leading tax controversy adviser in the International Tax Review
2011-2014 Tax Controversy Leaders guide.
Mayer Brown was recently named Tax Controversy Team of the Year for the second consecutive year 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.