Crowe Clark Whitehill has increased its number of partners working on tax investigations by 100%, welcoming investigations specialist John Cassidy to the team on 2 April.
John, who joins the firm from PKF, is a high profile figure in tax investigations, with wide-ranging experience in the field covering offshore evasion, fraud investigations, the Liechtenstein Disclosure Facility, disputes with HMRC, professional negligence claims and expert witness work. A regular writer and lecturer, he wrote chapters on tax investigations in the Zurich Tax Handbook and ICAEW’s TAXLine Tax Planning, and sits on a number of tax committees.
John joins Crowe Clark Whitehill partner Sean Wakeman, whose team won last year’s Lexis Nexis Best Tax Investigations team award – with John’s team at PKF coming in as hotly-contested runners up.
John says: “I am very pleased to be joining Crowe Clark Whitehill at what is clearly a great time in the firm’s development. I hope that my experience will complement the sterling work done by the tax investigations team, and that my appointment will be beneficial for both the firm and its clients. The Crowe Clark Whitehill team is already of the highest quality as demonstrated by them winning the Lexis Nexis tax award last year, and I hope to add to that.”
Sean Wakeman says: “I am delighted that John and his team are joining us. Their arrival marks another step in our strategy to build on our success by recruiting the very best tax investigations talent. John is at the very top of the tree in terms of his knowledge, experience and ability to deliver first class solutions to clients”.
“John’s recruitment to jointly head the team will help us to continue our positive trajectory. John is a well-known industry figure and a first class tax partner with whom I am looking forward to working for many years to come.”
Tom Cryan recently joined WTAS in McLean, Virginia as Managing Director in the National Tax Office.
Cryan has extraordinary experience in the area of tax controversy. He also has experience and strong technical skills in TEFRA partnership procedures, international information reporting, IRS procedural matters, and periods and methods. Cryan has spent the last 10 years in Deloitte’s National Tax Office and spent the prior 11 years in Arthur Andersen’s National Tax Office. His previous experience also includes 10 years working at the District Counsel and Chief Counsel offices of IRS in Washington, D.C.
WTAS Commercial Practice and National Tax Office Managing Director, Chris Rice commented, “Having Tom join our National Tax Office is a demonstration of our commitment to enhancing and broadening our firm’s technical expertise in areas of tax controversy and IRS procedural matters.”
Cryan received his undergraduate degree in Accounting from Canisius College in Buffalo, his law degree from Boston College and his LLM from University of Miami.
Crowell & Moring LLP has announced the addition of two prominent tax controversy and litigation partners to the firm’s Tax Group in Washington, D.C. David B. Blair and David J. Fischer bring more than 50 years of combined litigation and trial experience, advising domestic and international clients in the areas of federal tax litigation and controversy, with a specific focus on transfer pricing and international tax issues. The additions expand the tax controversy and litigation capabilities of Crowell & Moring’s Tax Group as the firm expands its leading national tax practice. Blair joins from Miller & Chevalier and Fischer joins from Cooley LLP.
“As transfer pricing continues to be a focus of increased IRS audit and litigation scrutiny, both David Blair and David Fischer bring a wealth of credentials and knowledge that will serve our clients well in these and other complex tax controversy matters,” said Harold J. Heltzer, chair of Crowell & Moring’s Tax Group. “In addition, their work involving the application of the economic substance doctrine, partnership-level litigation, and alternative dispute resolution with the IRS, as well as managing the overall tax needs of multi-national corporations, makes them an excellent fit for our group and clients.”
A former trial attorney for the Tax Division of the U.S. Department of Justice, Blair’s experience includes representing Fortune 500 companies in the petroleum, retail, timber, pharmaceutical, cosmetics, government contracting, and chemical industries. He has handled large tax litigation and controversy matters in the areas of transfer pricing, foreign tax credits, partnerships, tax-exempt bonds, consolidated returns, federal excise taxes, employment taxes, tax treaties, and tax accounting issues. Blair also has extensive experience handling tax controversies before Internal Revenue Service (IRS) Exam, IRS Appeals, the IRS National Office, and representing taxpayers before the Advance Pricing Agreement program and Competent Authority (now the Advance Pricing and Mutual Agreement (APMA) office).
Blair is the editor of PLI’s The Transfer Pricing Answer Book and co-author of BNA’s Transfer Pricing: Audits, Appeals, and Penalties. Active in pro bono litigation, Blair represents non-profit organizations and individuals in federal, state, and local tax matters. He is a member of the U.S. Tax Court J. Edgar Murdock Inn of Court. He holds a J.D., magna cum laude, from Cornell University and a B.A. from Georgetown University.
“Crowell & Moring has a great heritage of successful tax litigation work,” said Blair. “I look forward to being a part of this growing group, which encompasses an impressive mix of substantive technical tax experts and litigators, partnered with a solid transactional practice.”
Focusing his national practice on tax controversy work, Fischer represents Fortune 500 companies, publicly traded corporations, and high net-worth individuals in tax matters. His clients include companies in the semiconductor, software, petroleum, mining, automotive, and banking and finance industries. With extensive experience handling IRS alternative dispute resolution procedures, Fischer has worked on accelerated appeals and mediation matters before the IRS Appeals office, and counseled clients on numerous IRS examinations, including coordinated examination audits, the Fast Track Settlement program, and the Industry Issue Resolution program. He also has supervised the litigation of coordinated industry issues, partnership-level cases, and test cases.
Fischer has extensive transfer pricing experience, currently focusing on buy-in royalty payments in connection with cost-sharing arrangements and other related issues. His cases include tax-sensitive leasing, partnership issues, foreign currency, commodity, option and stock trading issues, and amortization of sports player contracts.
Co-author of the Aspen Publishers Examination and Appeals Chapter of A Practical Guide to U.S. Transfer Pricing, Fischer has also been an editorial advisor to The Tax Advisor and is a frequent speaker on tax topics. He is a director of the Anglo-American Charitable Foundation, Ltd. and represents charities before the IRS as part of his pro bono practice. He holds a J.D., with honors, from George Washington University and a B.A., with high honors, from Michigan State University.
“With its deep roots in Washington, D.C., Crowell & Moring’s Tax Group has an impressive platform that will allow my tax controversy practice to continue to grow,” said Fischer. “I am thrilled to be joining a firm committed to growth that has such strong regulatory and litigation practices already in place.”
Mayer Brown, a leading global law firm, announced today that Shawn R. O’Brien has joined the firm’s Tax Controversy practice in the Houston office. Previously, Mr. O’Brien managed the Tax Controversy Practice Group at Jackson Walker LLP, where he was a partner in Houston.
“Shawn has a proven track record of handling complex, cutting-edge tax disputes, and he represents clients on various significant tax issues before the IRS as an advocate in trial and appellate litigation,” said partner Joel Williamson, co-leader of Mayer Brown’s Tax Controversy practice. “His experience with a wide range of tax controversy issues and tax transactions, particularly within the energy industry, further expands the reach of Mayer Brown’s prominent Tax Controversy and Transfer Pricing practices to Texas, one of the most important markets in the United States.”
Referencing the firm’s global platform, Mr. O’Brien said, “As tax laws rapidly evolve, Mayer Brown’s geographic scope and exceptional Tax practice capabilities will enable me to offer multinational companies a superior level of experience with cross-border tax issues. I look forward to applying my deep knowledge and experience to solve tax disputes and transactional tax issues for clients facing aggressive enforcement by worldwide taxing authorities.”
Mr. O’Brien represents clients in all types of civil and criminal tax controversies and in every kind of dispute resolution with taxing authorities on the state and federal levels. He routinely advises clients on various tax issues before the IRS during examinations, in appeals and as an advocate in trial and appellate litigation before the US Tax Court, US District Courts and US Court of Federal Claims. Mr. O’Brien’s tax controversy and litigation experience spans a broad range of areas, including transfer pricing controversies, advance pricing agreements, “tax shelter” disallowances, estate and gift tax valuations, research and development tax credits and change of accounting methods.
He also advises corporations, partnerships, and LLCs seeking corporate and tax advice in connection with various types of transactions, including mergers and acquisitions, restructurings, divestitures, leveraged buyouts, structured financings and oil and gas transactions.
“Shawn’s arrival establishes a local presence for Mayer Brown’s highly regarded Tax practice,” said Neil Wasserstrom, Partner-in-Charge of the Houston office. “His extensive experience representing energy companies on tax-related matters and deep understanding of the Houston and Texas markets are significant assets to the firm.”
Prior to joining Jackson Walker, Mr. O’Brien was a tax partner with Fulbright & Jaworski LLP.
Mr. O’Brien received an LLM degree from New York University School of Law, a JD degree from Loyola Law School and a BBA degree in accounting from Millsaps College.