Sócio

Co-leader of Tax

Thomas Kittle-Kamp

Tax Controversy & Litigation, International Tax & Transfer Pricing, Tax Transactions & Planning

“He has a great command of the courtroom and an incredible understanding of tax law.”

“He is outstanding at executing strategy in a way the whole trial team can get behind and the judge can understand.”

Chambers USA

Geral

Tom Kittle-Kamp represents corporate clients in high-dollar tax controversies involving novel federal income tax issues.

Tom has litigated and tried cases involving a wide array of tax issues, including transfer pricing, a core competence of Mayer Brown; international tax, including subpart F; transactions governed by subchapter C and subchapter K; issues involving the development, exploitation, and transfer of intellectual property and intangible assets; and tax common law doctrines, such as substance over form and economic substance.

Experiência

  • Anadarko Corp. and Kerr-McGee Corp. v. Commissioner of Internal Revenue, T.C. Docket Nos. 23018-18, 23019-18 (deductibility of settlement payment) (tried May 2022) (decision pending).
  • Tribune Media Company v. Commissioner of Internal Revenue, T.C. Memo. 2021-22 (sustaining use of leveraged partnership).
  • Hyatt Hotels Corp. v. Commissioner of Internal Revenue, T.C. Memo. 2023-122 (tax consequences of customer loyalty program).
  • Altera Corporation v. Commissioner of Internal Revenue, 145 T.C. No. 3 (2015) (in 15-0 reviewed Tax Court opinion, holding invalid section 482 regulations requiring cost-sharing participants to share amounts attributable to stock-based compensation), rev'd, 926 F.3d 1061 (9th Cir. 2019) (2-1 vote), reh'g denied, 941 F.3d 1200 (9th Cir. 2019) (three judges dissenting from denial of rehearing).

Reconhecimento

  • "Thomas is an outstanding tax lawyer. He is very knowledgeable and forward-thinking." Tax: Controversy client USA
  • "Thomas is an excellent dispute lawyer." Tax: Controversy client USA
  • "He is an impressive trial lawyer with unique communication skills." – Chambers USA
  • "Extremely confident and persuasive in the courtroom and a pleasure to work with." – Chambers USA
  • "He is a great lawyer - very smart, very thoughtful and he has the respect of the government." – Chambers USA
  • "Has extensive experience, a lot of common sense and the ability to deal with whatever's thrown at him." – Chambers USA
  • "Extremely smart and well prepared," "very meticulous in his preparation" and a "very thoughtful practitioner who works well with clients." – Chambers USA
  • "A very rare combination—a subtle courtroom advocate and a real tax expert," as well as "clever, very likeable, unassuming but very impressive in court." – Legal 500

Formação Acadêmica

  • Northwestern University School of Law, JD, cum laude

    Associate Editor, Law Review; Order of the Coif

  • Bradley University, BA, summa cum laude

Registros

  • Illinois

Courts

  • US Tax Court
  • US Court of Federal Claims
  • US District Court for the Northern District of Illinois
  • US Court of Appeals for the Seventh Circuit
  • US Court of Appeals for the Ninth Circuit
  • US Court of Appeals for the Tenth Circuit
  • US Court of Appeals for the Eleventh Circuit

Atividades

  • Board of Trustees, Court Theatre, University of Chicago
  • Law Board, Northwestern University Pritzker School of Law
  • Co-author of Federal Income Taxation of Intellectual Properties and Intangible Assets (Thomson Reuters WG&L Tax Series 1997), updated twice a year
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