Henry Cheng focuses his practice on tax controversies and litigation as well as international tax planning and operational structuring. He has successfully represented numerous clients in all aspects of complex civil tax disputes at the federal, state and local levels.
In federal civil tax controversy matters, Henry represents clients in the private letter ruling process, in IRS audits, in protests to the IRS Appeals Office and in litigation and trials in the United States Tax Court. Many of his engagements involve international tax issues, such as sourcing of income, anti-deferral regimes, foreign tax credits, transfer pricing and treaty issues.
In state and local civil tax controversy matters, Henry represents clients in tax disputes with state and local taxing jurisdictions throughout the United States. Many of his engagements include sales and use, transient occupancy, payroll/unemployment taxes, as well as in audits involving residency and income sourcing and allocation issues. Henry also represents clients in tax refund actions in state courts.
Before joining DLA Piper, Henry was a law clerk to the Honorable David Laro of the US Tax Court. As Judge Laro's only law clerk, Henry managed and assisted in the disposition of numerous cases and acted as the trial clerk for a high-stakes case. He actively managed all of the cases before Judge Laro and oversaw pre-trial and discovery practice as well as motion practice. Henry is also an adjunct professor at University of California Hastings College of the Law where he teaches civil tax controversy and litigation. Before he became a tax controversy litigator, Henry was a patent litigator and a patent attorney admitted to practice before the USPTO.
- Chinese (Cantonese)
- Chinese (Mandarin)
- LL.M., Taxation, New York University School of Law
- J.D., University of California, Hastings College of Law
Order of the Coif
Senior Symposium Editor, Hastings Law Journal
magna cum laude
- B.A., University of California at Santa Cruz
My latest insights
The IRS Strategic Operating Plan’s potential impact on taxpayers
4 May 2023 .9 minute read
What’s Enough? Seventh Circuit affirms Tax Court’s disallowance of Section 41 R&E credit...
22 March 2023 .11 minute read