Morgan Lewis is expanding its capabilities in the areas of tax litigation, tax controversy and R&D tax credits with the addition of partner Alex E. Sadler, a former US government trial lawyer. Mr. Sadler, who will be resident in the Washington, DC, office, joins Morgan Lewis from Ivins, Phillips & Barkera, a leading law firm specializing in tax and employee benefits matters.
Mr. Sadler is recognized by Chambers USA in the area of tax controversy and litigation. He is a former trial lawyer with the US Department of Justice’s Tax Division, Northern Region, where he received the Attorney General’s Distinguished Service Award and the Tax Division’s Outstanding Attorney Award.
“Alex offers our clients a unique background as a seasoned government trial lawyer, tax litigator, and adviser to companies and individuals seeking to resolve tax issues and maximize the benefits available to them under the law,” said Firm Chair Jami McKeon. “His arrival further expands our capabilities to offer clients a full range of tax-related services.”
Mr. Sadler has developed a significant practice involving the research and development tax credit provided under Section 41 of the US Internal Revenue Code, a credit with broad application to businesses and industries of all sizes. He is the author of Legal Guide to the Research Credit, a treatise published by Thomson Reuters Legal Solutions, and he is a frequent speaker on tax litigation and research and development tax credit issues.
Mr. Sadler has handled numerous major tax litigations for the transportation, chemical, pharmaceutical, and hospitality industries, among others, and he has served as lead counsel in approximately 50 US Tax Court cases involving the consequences of a multiple employer welfare benefit trust. He also has resolved tax controversies at the administrative level. Mr. Sadler is chair of the DC Bar Tax Section’s Tax Audits and Litigation Committee. In addition to Chambers, he has been recognized by publications such asWashingtonian magazine.
The arrival of Mr. Sadler continues Morgan Lewis’s expansion of its tax-related legal services. Earlier this year, international tax partner Peter Daub joined the firm, following the additions of tax litigation and tax controversy partners Sheri Dillon and Jennifer Breen last spring.
“As a top-notch litigator and a national leader in the area of tax credits, Alex will be perfectly positioned to assist our clients, including those on the cutting-edge of innovation who require advice on how to take proper advantage of the tax incentives open to them,” said Barton Bassett, head of Morgan Lewis’s tax practice. “We are proud of our ability to assist clients in all stages of their growth, and whatever their needs, and Alex adds an important new component to our team.”
Ronan Daly Jermyn and Dublin-based law firm JM Burke Tax Solicitors (“JM Burke”) will merge with effect from April 4, 2016.
Richard Martin, Managing Partner at Ronan Daly Jermyn said,
“We are delighted to be joined by JM Burke which is a unique practice offering specialist tax litigation advice and brings with it a depth of experience dealing with a full range of contentious tax issues.” He continued, “Julie and her team will be a valuable addition to our tax practice and the firm overall. They have extensive specialist knowledge and experience of Revenue law and the tax investigations process. They also, similar to our existing tax practice, have significant experience in advising at all stages of tax appeal hearings, including District, Circuit, Court of Appeal, High Court tax cases and in negotiating settlements with Revenue.”
“We are excited to join Ronan Daly Jermyn’s national team,” said Julie Burke, Managing Partner of JM Burke, who becomes a Partner in Ronan Daly Jermyn’s Tax Group. “With a full service offering and offices in locations strategically important to our clients, such as Dublin, Cork and Galway, we now offer a more robust platform and critical mass to handle the most complex contentious tax matters and litigation.”
Pictured above; in front Julie Burke, Tax Partner, Richard Martin, Managing Partner and behind (left to right) Mark Barrett, Chartered Tax Adviser and John Cuddigan, head of Ronan Daly Jermyn’s Tax Practice.
John Cuddigan, Head of Ronan Daly Jermyn’s Tax Practice, said “The merger of the two tax practices comes at a time when the new tax appeals procedures are about to come into force on 21 March, 2016. The Act introduces a new appeals process, one aspect of which is that appeals against a decision or determination of the Appeal Commissioners can only be made to the High Court and then on points of law. This fact alone will mean that tax appeals will require greater technical resources to be applied at an earlier stage given the increased importance of the first stage of the appeal process. Our Tax Group now, through the merger, has the combined skills, resource and experience to provide such services to a wider client base on a national basis. Additionally, in relation to the increased activity in Revenue investigations and audits, I am delighted to note that we will now have two of the foremost experts in this area – Mark Barrett and Julie Burke – working in the one firm. ”
JM Burke is a niche solicitors practice specialising in largely contentious tax work. Julie Burke and Clare McGuinness will join Ronan Daly Jermyn as Partners and Caitriona Moran as an Assistant Solicitor. Julie is a Fellow of the Irish Tax Institute and is well-known as a tax author and lecturer. In 2015, she was the chairperson of the Irish Government’s Tax Administration Liaison Audit Committee. Julie was the only lawyer on the Government’s 2003 Revenue Powers Group and the 2008 Commission on Taxation. She is the current editor of Irish Tax Review and she is also the editor of the Irish Tax Institute’s publication “Revenue Audits and Investigations – the Professional Handbook” the second edition of which is co-authored by Mark Barrett and Clare McGuinness. Julie and Clare are also currently co-authoring a new edition of the publication “Revenue Investigations and Enforcement”, published by Bloomsbury Professional, which is the only publication of its type in Ireland.
Julie, Clare and Caitriona will be based in Ronan Daly Jermyn’s Dublin office at 3, Harbourmaster Place.
Sergio Arellano has left the IRS to join PwC’s Tax Controversy Regulatory Services practice as a Managing Director. He is based from the Chicago office and joined in October.
PwC’s TCRS practice assists companies to proactively prevent, efficiently manage, and favorably resolve tax audits and disputes.
Mr Arellano has over 31 years’ experience in the area of Compliance. From 2012 to 2014 he was Executive Director in the International Business Compliance division of the IRS. In May 2014 he was promoted to Deputy Commissioner in LB&I, overseeing 3,500 employees and implementing strategic changes.
Dentons has recruited James Mastracchio as partner in the Firm’s Global Tax practice. Based in Washington, DC, Mastracchio will also serve as chair of Dentons’ US Tax Controversy and Criminal Tax practices.
Mastracchio’s work focuses on advising clients facing civil and criminal tax investigations. His work in civil tax disputes includes a wide range of civil tax reporting issues and defense of structured products and tax driven structures and their promotion. In the criminal tax arena, Mastracchio represents clients facing tax fraud and evasion, conspiracy, obstruction, mail/wire fraud and monetary structuring charges.
“Tax controversy work is now being viewed as a multi-jurisdictional service, with major multi-nationals turning to one firm to handle their audit and controversy matters in the major economic jurisdictions,” said Mike McNamara, US Managing Partner at Dentons. “Jim’s wealth of experience in the civil tax arena, as well as his significant representations involving the US government’s pursuit of criminal tax investigations of foreign banking institutions, their clients and advisors, allows us to provide our clients an even broader range of services in this growing area.”
Mastracchio previously served as an Independent Examiner for a major Swiss banking institution, advised foreign financial institutions on the implementation of FATCA and OECD reporting standards, represented hundreds of US persons in the IRS Voluntary Disclosure Programs, and currently represents foreign financial institutions facing criminal tax investigations and prosecutions.
He received his JD, summa cum laude, and an LLM in Taxation from New York University School of Law. He holds a BS in Accounting, summa cum laude, and an MS in Taxation, from the State University of New York at Albany.
Crowell & Moring has announced the addition of prominent tax controversy partner Dwight N. Mersereau to the firm’s Tax Group.
Mersereau has more than 20 years’ experience in tax dispute matters and has served inside the Internal Revenue Service (IRS) as attorney advisor to the Office of Chief Counsel. He has been involved in shaping tax policy through legislation, U.S. Department of the Treasury regulation projects, revenue rulings, and private letter rulings. Mersereau joins the firm from McDermott Will & Emery.
Based in the firm’s Washington, D.C. office, Mersereau represents large, multinational corporations in high-stakes policy, planning, and federal controversy matters, typically involving complex tax accounting issues. He has represented individual clients, industry associations, and client coalitions before Congress, the U.S. Department of the Treasury, and the IRS. Mersereau also advises clients on capitalization issues relating to the tangible property “repair regulations.”
“Dwight offers his clients an unparalleled understanding of complex tax accounting issues gained through years of experience working with the IRS, including serving in the Office of Chief Counsel,” said David B. Blair, Chair of Crowell & Moring’s Tax Group. “Our corporate clients will benefit from Dwight’s experience on both sides of tax controversies, which allows him to navigate the federal tax code and regulations and identify solutions to the most challenging IRS controversies and tax accounting issues.”
Mersereau began his career as an appellate and trial lawyer in the Office of the Judge Advocate General, U.S. Navy. In addition to briefing dozens of cases, he argued ten cases before the U.S. Court of Appeals for the Armed Forces and the Navy-Marine Corps Court of Military Review. Mersereau served as Head Trial Counsel at the Charleston Naval Base and was the lead prosecutor in more than 50 felony cases. While in the Office of Chief Counsel, IRS, Mersereau was awarded the Technical Guidance Award for his publication of procedures for making accounting method changes.
“Crowell & Moring has a leading reputation for its ability to serve the tax needs of large, multinational corporations. I am proud to be part of this well respected and dynamic team, and I am confident that my experience will serve the firm’s clients well,” said Mersereau.
Ernst & Young LLP announced today that Executive Director of the Multistate Tax Commission (MTC) Joe Huddleston has joined as an Executive Director in the firm’s National Indirect Tax group.
“Joe’s broad range of high-level government experience, coupled with his work on high-profile commercial business transactions, will be especially valuable to clients with US state tax controversy matters as well as the entire government services sector,” said Jeffrey Saviano, Director of Indirect & State and Local Tax Services, Ernst & Young LLP.
Huddleston served as Executive Director of the Multistate Tax Commission for 10 years. In that role, he interacted regularly with the commissioner of revenue for almost every state to coordinate and administer programs such as the MTC’s audit and voluntary disclosure programs. During his tenure, Huddleston led a number of uniform law initiatives and recently introduced a significant transfer pricing program that has the potential to transform state corporate income tax audits. Before joining the MTC in 2005, he was a national state and local tax partner at Grant Thornton. He has also served as the Commissioner for the Tennessee Department of Revenue and as CFO for the Metropolitan Government of the City of Nashville and Davidson County.
In 2012, Huddleston received the award for Outstanding Achievement in State and Local Taxation from New York University. He was named by Tax Analysts as one of the top 10 individuals who influence state tax policy and practice in 2011. He graduated from the University of South Carolina with a B.A. in Political Science, earned his J.D. from the Nashville School of Law, and was awarded the Doctor of Laws degree from the University of South Carolina.
He is a nationally recognized speaker, a founding trustee of multiple tax forums and serves on various advisory boards for state and local tax issues. Huddleston is based in EY’s Washington, DC office.
Ernst & Young has announced that Heather Maloy, currently the IRS Commissioner for the Large Business & International (LB&I) Division, will join the National Tax Department as Tax Controversy Leader.
“Tax controversy continues to grow in importance as US and foreign tax administrators focus on the activities of US companies,” said Michael Mundaca, co-leader of the National Tax Department of Ernst & Young LLP. “Heather’s background and experience, both at the IRS and in the private sector, will enable her to advise clients to ensure they are able to proactively anticipate and address both the procedural and technical aspects of tax issues.”
While serving as the LB&I Commissioner, Maloy was responsible for driving innovative resolution approaches to compliance matters, including reinvigorating the Industry Issue Resolution Program, making the IRS’s Compliance Assurance Program permanent and providing examiners with guidance on important technical topics.
In addition to her most recent role, Maloy has a deep and varied history of service at the IRS, having worked in the Office of Chief Counsel as the leader of the Income Tax & Accounting and the Passthroughs & Special Industries divisions. She also has significant private-sector experience, most recently at Skadden, Arps, Slate, Meagher & Flom, where she represented clients in both examinations and appeals on IRS tax controversy matters with regard to complex issues of corporate, partnership, S corporation, individual and international income taxation.
Maloy earned her BBA in Accounting from Emory University, her JD from Cornell University Law School, and her LLM in Taxation from the University of FloridaCollege Of Law – where she also served as a Visiting Assistant Professor.
Morgan Lewis has expanded its tax controversy and litigation team with the additions of Sheri A. Dillon and Jennifer Breen as partners in the Washington, DC office.
Ms. Dillon joins from Vinson & Elkins, where she led the DC tax controversy and litigation team. Ms. Breen, who will officially start at the end of the month, joins from Mattel, Inc., where she was director of tax controversy.
Ms. Dillon’s market-leading practice focuses on federal tax controversy and tax-planning matters. She guides clients through IRS examination and appeals and the administrative claims process. In addition, she litigates tax cases in US Tax Court, US district and appellate courts, and the US Court of Federal Claims. On the tax-planning side, she advises on matters involving acquisitions, dispositions, combinations, and debt restructuring and reorganizations, with a special focus on partnership transactions and closely held businesses. Ms. Dillon’s diverse client list includes corporate taxpayers, partnerships, and partners in the financial services, private equity, real estate, energy, manufacturing, and consumer products industries as well as global, high-wealth individual taxpayers.
She is a regular speaker at the Tax Executives Institute, Federal Bar Association, ABA Section of Taxation, and the DC Bar Section of Taxation, among others. She also helped found the Low-Income Taxpayer Clinic, a program providing legal services to low income taxpayers, at the David A. Clarke School of Law.
Ms. Breen led Mattel’s ongoing federal, state, local, and international tax audits and controversies as director of tax controversy. Prior to joining Mattel, she spent eight years in PricewaterhouseCoopers’ national tax controversy practice and five years in the Office of the Chief Counsel at the IRS. In her career Ms. Breen has obtained more than 100 private letter rulings, technical advice memoranda, and formal IRS determinations.