Geoffrey Collins is a partner in Mayer Brown’s Tax Controversy practice.
Geoffrey Collins represents clients in all phases of tax controversy, both in court and before the Internal Revenue Service. His experience includes major corporate tax matters before IRS Exam and IRS Appeals. In addition, his experience includes the successful use of alternative-dispute-resolution initiatives such as the Pre-Filing Agreement program and major litigation in the United States Tax Court. His experience includes controversies regarding advance pricing agreements, transfer pricing, carrybacks of Net Operating Losses and other tax attributes, debt-equity characterization of intercompany advances, deductibility of settlement payments under the False Claims Act, summons enforcement, and economic substance, sham-transaction, and similar substance-over-form doctrines.
Geoffrey received his JD magna cum laude from Cornell Law School where he was Order of the Coif and an Editor of the Cornell Law Review. Before joining Mayer Brown, he served as law clerk and attorney advisor to Hon. Richard T. Morrison of the United States Tax Court.
- Cross Refined Coal, LLC v. Commissioner, T.C. Docket. No. 19502-17, Index No. 177 (U.S. Tax Ct. Aug. 29, 2019) (finding that refined coal production partnership was a bona fide partnership and that its partners were bona fide partners).
- Eaton Corporation v. Commissioner of Internal Revenue, T.C. Memo. 2017-147 (finding that the IRS’s cancellation of Advance Pricing Agreements was an abuse of discretion).
- Guidant LLC, et. al., v. Commissioner of Internal Revenue, T.C. Docket Nos. 5989-11, 5990-11, 10985-11, 26876-11, 5501-12, 5502-12 (IRC § 482 reallocations).
- United States v. Eaton Corporation, Nos. 1:13-mc-102, 1:13-mc-111, 1:13-mc-112 (N.D. Ohio 2014); 2:13-cv-01825 (W.D. Pa. 2014); 3:13-cv-01956 (D.P.R. 2014) (summons enforcement litigation).
- United States v. Eaton Corporation, Nos. 1:12-mc-24, 1:12-mc-25, 1:12-mc-26, 1:12-mc-27, 2012 WL 3486910 (N.D. Ohio Aug. 15, 2012) (summons enforcement litigation).
- Eaton Corporation v. Commissioner, T.C. Docket No. 28040-14. (Transfer pricing and sub-part F adjustments).
- Tyco Electronics Corp., et. al v. Commissioner of Internal Revenue, T.C. Docket Nos. 16651-13, 16652-13, 16653-13, 16654-13, 16655-13, 16656-13, 16657-13, 16658-13, 16659-13, 16660-13, 16661-13, 16662-13, 16663-13, 16664-13, and 19556-13 (debt-equity characterization).
- Keeling v. Commissioner, T.C. Docket No. 020806-11L (trust-fund recovery penalties).
Cornell Law School, JD, magna cum laude
Cornell Law Review
University of Kansas, BM, magna cum laude