• Nike, Inc. & Subsidiaries v. Commissioner, T.C. Docket No. 16869-16
  • Nike, Inc. & Subsidiaries v. Commissioner, T.C. Docket No. 10776-15
  • First Data Corp. v. Commissioner, T.C. Docket No. 7042-09 (Petition filed 20 March 2009)
  • Represented clients in all aspects of transfer pricing disputes, including pre-audit planning, during audit, before IRS Appeals, and in litigation
  • Secured IRS concession on a section 41 research credit matter covering over 10 years and nearly US$1 billion in qualified research expenditures
  • Assisted a Europe-headquartered software company on structuring US and global operations
  • Represented Swiss banks during internal investigation and non-prosecution agreement negotiation in connection with US Department of Justice disclosure program
  • Advised US-based multinationals on restructuring their international operations to manage subpart F exposure and foreign tax credit utilization opportunities