Gary's practice focuses on tax controversies and tax planning. He represents multinational corporations in the audit and appeals phases of an IRS dispute as well as in litigation. Gary has particular experience with controversies arising from complex transactions, typically in a cross-border context, such as leveraged distributions and other repatriations, intercompany debt, worthless stock deductions, and cost sharing arrangements. He has litigated significant cases in U.S. Tax Court involving intercompany debt (ScottishPower) and consolidated return issues (Duquesne Light).
Gary also has many years of experience advising clients on structuring mergers, acquisitions and internal reorganizations, and now regularly advises on planning issues arising from the Tax Cuts and Jobs Act. He is a frequent lecturer on corporate tax issues, and is an author of the BNA Tax Management Portfolio entitled "Corporate Acquisitions- (A), (B), and (C) Reorganizations."
Gary is ranked by Chambers USA in the Tax – District of Columbia category in 2026. Chambers USA has said “Gary is a very valuable resource. He has consistently and effectively resolved issues and provided stellar counsel on tax matters. He communicates clearly and is timely with responses.” Gary has also been recognized by International Tax Review World Tax. He is ranked for Tax controversy, Highly Regarded: District of Columbia. Gary is also recognized as a top practitioner in Lawdragon’s 2026 “500 Leading Global Tax Lawyers.”
For many years Gary has been recognized as a leading tax controversy lawyer in the International Tax Review Controversy Leaders Guide and named among the World’s Leading Tax Advisors (Euromoney) and the “Best Tax Lawyers” in Washington DC by Washington Post Magazine, Gary is a former council director of the American Bar Association's Tax Section and a fellow of the American College of Tax Counsel.
