Chris Bowers has left Bingham McCutchen to join Skadden Arps.
He advises clients on all aspects of international tax planning and controversy, representing many of the largest U.S. and international financial institutions, as well as large, multinational companies. He focuses on issues arising in cross-border financings, cross-border mergers and acquisitions, and foreign tax credit planning.
Before joining Skadden in 2014, he was a partner at Bingham McCutchen. Prior to that, he was a partner in the International Corporate Services Group at KPMG LLP’s Washington National Tax Office. Earlier in his career, Mr. Bowers clerked for Supreme Court Chief Justice William H. Rehnquist and the Hon. Pamela Ann Rymer of the U.S. Court of Appeals for the Ninth Circuit.
Mr. Bowers is listed as one of the country’s leading tax practitioners in Chambers USA: America’s Leading Lawyers for Business. He also has been included in The Best Lawyers in America, The Legal 500 U.S. and International Who’s Who of Corporate Tax Lawyers.
Mr. Bowers has co-authored numerous articles on a wide range of international topics that have been published in leading tax journals, including Tax Management International Journal, Tax Notes and Tax Notes International. He also is an adjunct professor at Georgetown University Law Center, where he teaches international taxation, and served as an adjunct professor of law for corporate taxation at the George Mason University School of Law in 2004.
Ernst & Young LLP announced today that Richard McAlonan, Jr. has joined the firm as Director of National Tax Transfer Pricing Controversy in Washington, DC, and will also act as the Americas Director of Advance Pricing Agreements (APAs) after serving as the Director of the IRS’s Advance Pricing and Mutual Agreement (APMA) Program.
As director of the recently formed APMA program, McAlonan led a team of 120 lawyers, economists, accountants and staff. He was tasked with integrating the APA program staff with the Tax Treaty IRS group, improving productivity and efficiency while maintaining the high standards and strong image of the APA and mutual agreement programs. During his tenure, the IRS significantly increased the number of APAs completed.
“Dick’s experience with the new APMA program will bring tremendous value to our clients as they consider the most appropriate opportunities for increased tax certainty,” said Michael Mundaca, co-director of Ernst & Young LLP’s National Tax Department.
Prior to joining the IRS, McAlonan spent two years as an Executive Director for Ernst & Young LLP’s transfer pricing controversy practice, where he advised clients on transfer pricing controversy risk management and resolution (including audit dispute resolution) as well as APAs, competent authority procedures and tax treaties.
He has spoken at industry conferences and authored a series of articles comparing APA procedures in different countries.
McAlonan received his Master in Business Administration from Temple University and his Master of Science in Taxation from Pace University, where he graduated summa cum laude. He is licensed as a Certified Public Accountant in the District of Columbia and Pennsylvania.
Withers London has hired Tessa Lorimer to strengthen its tax disputes and investigation practice. She joins as Special Counsel.
Tessa is a barrister who specialises in both civil and criminal tax fraud investigations and litigation conducted by the Special Investigation and Criminal Investigation departments of HMRC. Tessa has extensive experience in advising the Board of the former Inland Revenue and HMRC in relation to their most complex direct and indirect tax investigations and prosecutions.
Most of Tessa’s work is international in nature and she has considerable experience of mutual legal assistance, extradition, search warrants, judicial review, injunctions, SOCPA production orders and legal professional privilege issues. Tessa has also advised SOCA, HMRC and the SCDEA on sensitive cases involving money laundering and organised crime as well as strategic export control and regulatory offences.
Tessa comments, “Withers has a first-class reputation for assisting clients in regulatory investigations and the international reach of the team is a great platform for me to build my practice around the world. I look forward to putting my experience of working within and across from the tax authorities into effect at Withers.”
Tessa started her career with the CPS and spent 12 years as a Senior Lawyer based in the Thames Vallet. In 2001 she joined the Inland Revenue Solicitor’s Office and spent 4 years as a senior tax lawyer. In 2005 she moved across to the Revenue & Customs Prosecutions Office as a senior tax fraud prosecutor before returning to the CPS in a similar role. In 2012 she moved into practice and worked as a barrister with GSC Solicitors in London.
Daniel Rosen has joined Baker & McKenzie’s Global Tax Practice as partner, boosting the Firm’s capabilities representing multinational clients in tax controversies and litigation matters.
“During his 16-year career with the IRS, Dan was responsible for litigating some of the largest and most complex cases before the United States Tax Court,” said Thomas Linguanti, chair of the Firm’s North America Tax Practice. “His significant trial experience and governmental insight will be invaluable to our clients. We are fortunate that Dan has decided to join us and couldn’t be more pleased to welcome him to the Firm.”
As a special trial attorney with the Internal Revenue Service, Office of Chief Counsel, Mr. Rosen gained considerable trial experience litigating dozens of cases over a 16-year span. During his career, he worked closely with the US Department of Justice, Tax Division on several major cases and advised IRS Large Business and International Division executives, managers, and examiners on tax controversy matters, including settlement initiatives. In addition to his courtroom experience, Mr. Rosen has substantial knowledge of alternative dispute resolution processes and techniques.
“Dan’s experience both in the courtroom and with alternative dispute resolution forums will be a great asset to our clients and complements the Firm’s leading team of tax controversy attorneys,” said James Colihan, managing partner of the Firm’s New York office.
Baker & McKenzie’s Global Tax Practice Group is one of the most highly rated and recommended among law firms worldwide. With a team of more than 850 tax practitioners, economists and financial analysts in 47 countries, the practice provides a strong network of tax professionals offering complete tax planning and dispute resolution services to multinational corporations. In North America, the tax practice was recently recognized by U.S. News & World Report and Best Lawyers as the 2014 “Tax Law Firm of the Year” and by Law360 in its inaugural listing of “Tax Practice Groups of the Year.”
Mr. Rosen is the latest in a series of partners to join the Tax Practice in North America. Earlier this year, Alex Pankratz and Peter Clark joined the Firm in Toronto and Marc Kushner joined the Firm in Chicago.
“Baker & McKenzie has an unsurpassed reputation in the tax controversy and litigation area,” said Mr. Rosen. “I am delighted to join the Firm and look forward to working with my colleagues around the world.”
Mr. Rosen was a key participant in the drafting of published guidance and administrative directives involving judicial doctrines for the IRS Large Business and International Division. While at the IRS, he was awarded the Treasury Legal Division Research and Writing Award, the National Outstanding Litigator Award, the National Litigation Team Award, and the Commissioner’s Award.
Mr. Rosen is a recognized and frequent speaker on a wide variety of domestic and international tax issues, including for George Washington University School of Law, the Practising Law Institute, Tax Executives Institute (“TEI”), and the American Bar Association. Additionally, Mr. Rosen is an adjunct professor of law at New York Law School. He received his Bachelor of Arts from Hofstra University in 1991 and his JD in 1996 from Hofstra University School of Law, where he served on the Editorial Board of the Hofstra Law Review.
Steven Kempster is leaving TaylorWessing to join Withers with effect from July 2014.
Steven joined Taylor Wessing in 2008 from Herbert Smith, to develop and lead the firm’s Contentious Trusts and Estates Group. In September 2011, the group won “Contentious Trusts and Estates Team of the Year” at the annual STEP Awards.
Steven specialises in the resolution of disputes relating to the formation or administration of trusts and estates in a UK and international context. Recent cases have included disputes relating to trusts and estates in the UK, Channel Islands, Isle of Man, Switzerland, Gibraltar, Liechtenstein, Cayman Islands and Bermuda. Steven’s practice also encompasses advising high net worth individuals, private banks and trust companies on trust structuring and succession planning issues, particularly where there is an international element. He also advises on charity law matters, including dispute resolution where UK charities are involved.
Steven speaks regularly on issues relating to trust and estates disputes at conferences in London, the Channel Islands, Switzerland, the Cayman Islands and the United States. He also runs a number of in-house training workshops for private banks and trust companies. Steven is one of the editors and contributing authors to Oxford University Press’s ‘International Trust Disputes’ published in hardback in January 2012. He is also a contributing author to ‘International Trust Precedents’ published by Longmans.
Commenting on his move, Steven said ” I am very excited about the international platform that Withers have, and the strength in depth in key areas of private wealth legal services. In particular, the leading
family law practice that Withers has will be very complementary to my own practice, and vice versa. My core focus will remain on complex international trusts and estates disputes and on maintaining Withers’
pre-eminence in the field.”
Sidley Austin LLP announced that Matthew D. Lerner has joined the firm’s Washington, D.C. office as a partner and a co-global coordinator of the Tax Controversy practice.
Mr. Lerner has nearly 30 years of experience practicing in the area of federal taxation, with substantial experience in civil and criminal tax controversies and civil litigation related to tax strategies, as well as business planning and advice. His experience broadly covers all stages of the Internal Revenue Service’s administrative audit and appeals processes, as well as litigation in Tax Court, the Court of Federal Claims and federal district courts. He is experienced in handling tax controversies for corporations, partnerships and individuals, and has significant experience with many of the IRS alternative dispute resolution procedures. He also regularly advises on pre-audit issues regarding document organization, retention practices and disclosure obligations. Mr. Lerner also handles state and local tax controversies.
Mr. Lerner has been recognized for his accomplishments and is nationally ranked inChambers USA and America’s Leading Business Lawyers. He regularly publishes on tax issues and is a frequent speaker at tax conferences, including the prestigious Tax Executive Institute.
“I have known Matt professionally and personally for many years,” said Jay Zimbler, global coordinator of Sidley’s Tax Controversy practice. “He has a broad range of experience and deep understanding of tax controversy issues, as well as high intellect and integrity. We are excited that he has joined our team of lawyers providing counsel to clients in federal and state tax disputes nationwide.”
“Matt’s depth of knowledge on various tax issues and litigation skills will be a valuable asset to our clients and an excellent complement to the firm’s global practice,” said Mark Hopson, managing partner of Sidley’s Washington, D.C. office and member of the firm’s Management Committee. “We look forward to working with Matt to serve our clients.”
Mr. Lerner was ranked by Chambers USA in 2012 and 2013 for America’s Leading Business Lawyers, Tax Controversy: Nationwide. The Best Lawyers of America recognized Mr. Lerner in 2012, 2013 and 2014 for Tax Litigation and Controversy. Additionally, Legal 500 US 2013 recommended Mr. Lerner for Tax: Controversy and Domestic Tax: East Coast.
Withers Bergman has hired two experienced tax controversy partners. Both join from Hass & Hecht/WeiserMazars with Moise being based in New York and Cohen in New Haven.
Seth Cohen represents individuals and entities in tax controversies, including federal,
state and local tax examinations and appeals; criminal tax matters; tax litigation; and voluntary disclosure agreements (both offshore and domestic). Additionally, assisting clients in relation to tax collection procedures, including tax liens and levies, as well as collection administrative appeals, installment agreements and offers in compromise.
He is also Adjunct Professor at the University of New Haven.
David Moise has over 25 years of experience providing services in the tax procedure and controversy area. He specializes in federal, state and local tax examinations and appeals, tax court litigation, and voluntary disclosure agreements. In addition, David has extensive experience in relation to Tax Collection procedures, including tax liens and levies, as well as collection administrative appeals, installment agreements and Offers in Compromise.
David is an attorney admitted to practice law in the State of New York and before the United States Tax Court. David received his B.A. at Syracuse University, his J.D. at Pace University School of Law, and an LL.M. in Taxation at Boston University.
alliantgroup has announced the appointment of Kathy Petronchak, former IRS Commissioner of Small Business/Self- Employed Division (SB/SE), as the firm’s Director of IRS Dispute Resolution. Petronchak brings with her 34 years of experience in directing IRS compliance activities and providing tax controversy services. In her new role, Petronchak will be reaching out to CPAs and American businesses, helping alliantgroup’s clients navigate IRS procedures and the U.S. tax code.
“I am excited for the opportunity to join this exceptional team,” Petronchak said. “I am looking forward to serving as an advisor for our clients and in helping CPAs and U.S. businesses better understand the options available to them in resolving disputes with the IRS.”
In a career that includes service within both the federal government and the private sector, Petronchak has worked with a countless number of businesses in examination from both the government’s perspective and in the position of audit defense. In her 29 years with the IRS, she has held a number of roles within the Service, including her time as IRS Commissioner of SB/SE from 2006-2008, a role in which she worked directly with small and mid-sized businesses and practitioners on compliance with IRS standards. She was also appointed Chief of Staff under former IRS Commissioner and current alliantgroup Vice Chairman,Mark W. Everson, and was highly praised for the leadership she brought to this position.
“It is a privilege to be working again with Kathy Petronchak,” Everson said. “The judgment Kathy brings from her extensive experience across different IRS operations will be a real asset to alliantgroup and the businesses we serve.”
Petronchak has served as the Chair of the AICPA IRS Practice and Procedures Committee and currently serves as the immediate past chair. She has also been a frequent speaker for AICPA tax controversy conference events. Most recently, Petronchak was a Director at Deloitte Tax LLP, where she specialized in the area of tax controversy services, providing support for clients in their issues with the IRS. In her new role, Petronchak will be advising businesses of all sizes in their dealings with the Service, helping them identify options for resolving disputes.
“I am thrilled to have Kathy join our team here at alliantgroup,” said alliantgroup COO Shane T. Frank. “Her experience with the IRS and knowledge of the Service’s standards will serve our clients well in navigating IRS waters.”