David Colker concentrates his practice on tax disputes and tax planning. He is the head of DLA Piper's global tax practice.

In the area of tax disputes, Mr. Colker has more than 30 years of experience beneficially resolving federal, state and local tax disputes. He has successfully represented numerous clients in more than 200 tax cases, effectively evaluating government claims and identifying inherent weaknesses and winning defenses. Mr Colker has discovered and successfully implemented strategies to turn tax deficiency claims into tax refunds, achieving extremely favorable results for clients.

In the area of tax planning, Mr. Colker is highly experienced in establishing, improving and evaluating business structures to achieve beneficial tax consequences. He has helped clients better prepare for government reviews of their business structures based on extensive experience in handling tax controversy matters and developed sound and realistic client-focused tax planning solutions based on client business operations and activities.

The respected research publication Legal 500 recognizes Mr. Colker for his international work, commenting on his "high-level practice." Chambers USA: America's Leading Lawyers for Business cites Mr. Colker, noting that he is "particularly noted for his expertise in complex tax disputes and tax planning."

Mr. Colker has been named a Northern California Super Lawyer, and in 2004 the Super Lawyer survey published in San Francisco magazine cited him as one of Northern California's Top 100 tax attorneys. In 2006, he was recognized as one of the top tax lawyers in the Bay Area in a study published in Bay Area Lawyer magazine.

Recent Matters

• Federal income tax: Reached a negotiated settlement with the IRS concerning an assessment of tax, interest and penalties of over US$200 million involving several "buy-in" transfer pricing issues for a high technology company; the negotiated settlement resulted in the payment of less than US500,000 by our client
• Federal income tax: Reached a negotiated settlement with IRS appeals concerning an assessment of tax and interest of US$150 million involving cost sharing and service transfer pricing issues for a high technology company; the negotiated settlement resulted in the payment of a small refund to our client
• California local tax: Obtained trial court victories in several cases holding that certain local "fees" were illegal taxes as a matter of California law under Proposition 218
• Federal income tax: Converted a US$5 million transfer pricing dispute into a $10 million refund for a large international company
• Federal income tax: Reduced a US$25 million tax deficiency in connection with an international income tax withholding claim to zero
• California income tax: Obtained a US$5 million refund for a large publicly traded company
• Property tax: Obtained the largest property tax refund in the history of San Francisco for a large publicly traded company – US$20 million
• Developed and implemented international structures for the reduction of taxes
• Helped client reduce foreign taxes and its overall effective tax rate through a revision of transfer pricing arrangements
• Implemented tax planning opportunities in connection with the California worldwide unitary tax system. Attorney-client privileged audits of risks and exposures associated with international tax structures. Reviewed multi-state nexus issues for sales and income tax purposes