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.
Buchanan Ingersoll & Rooney has announced the addition of two highly regarded tax attorneys, Shareholder Susan E. Seabrook and Counsel Caroline C. Setliffe, to the firm’s Washington, D.C. office. Both join from Morgan, Lewis & Bockius.
Seabrook and Setliffe will round out Buchanan’s Tax Group, focusing their practices on tax controversy and tax planning with regard to the financial, insurance and health care industries.
“We’re thrilled to have attorneys of Susan and Carol’s caliber joining the firm’s Tax Practice. Susan’s impressive background combined with Carol’s keen perspective will bring a depth of experience to our clients,” stated Bruce I. Booken, chair of the firm’s Tax Section.
“Carol and I were initially drawn to Buchanan by the passionate people and enthusiasm to invest in the future of the firm. Their highly-regarded Tax team continues to impress us with their evident business sense in the industry and continual commitment to client service.” Seabrook commented. “Buchanan’s presence and profile in Washington, D.C. was a critical factor for us and we are eager to hit the ground running.”
Seabrook advises clients in connection with mergers, acquisitions, dispositions and restructurings, and represents clients at all levels of tax administration and in litigation. She has experience resolving matters involving complex technical and procedural issues, high profile IRS initiatives, and those involving the IRS’s invocation of judicial doctrines and anti-abuse provisions.
She previously served as a trial attorney for the IRS and as an attorney advisor in the National Office of Chief Counsel, Financial Institutions and Products. Seabrook is a three-time recipient of the IRS’s Special Act Award, once for significant issue litigation, and twice was honored for her superior performance with the IRS’s Performance Award. She served as acting assistant district counsel and was designated a special assistant U.S. attorney by the United States Attorney General. She earned her Master of Laws in Taxation from the University of Denver College of Law, her law degree from Gonzaga University School of Law and her bachelor of arts degree from University of Colorado at Boulder.
Setliffe’s Tax Controversy Practice includes advising clients in connection with IRS examinations, technical advice requests, protests, IRS Appeals proceedings and refund claims, as well as representing insurance companies in tax litigation in various forums.
She has experience in both domestic and international tax planning and offers advice in connection with insurance company mergers and acquisitions, cross border transactions, offshore insurance arrangements and the tax implications of creating or operating captive insurance companies. She earned her Master of Laws in Taxation from Georgetown University Law Center, her law degree from Syracuse and her B.A. from Virginia Polytechnic Institute and State University.
International law firm McDermott Will & Emery has hired three leading tax lawyers to the Firm’s partnership. M. Todd Welty, Mark P. Thomas and Laura L. Gavioli join the Firm to expand McDermott’s Tax Controversy practice, which was named “Tax Litigation Firm of the Year” by U.S. News & Best Lawyers in 2014.
Under Welty’s leadership, the three join McDermott from Dentons, where they represented a broad range of multinational clients in international and national tax controversy and litigation matters. They will be based in McDermott’s Dallas office.
“The integration of this group with our USIT practice further solidifies McDermott’s position as one of the few go-to tax groups for bet-the-company tax controversies,” said McDermott co-chair Peter J. Sacripanti. “Looking toward the future, this group’s established reputation for excellence and their combination of experience and gravitas positions us to capitalize upon the many opportunities that are emerging in this fast-growing area of law.”
“We are thrilled to have Todd, Mark, and Laura join us,” said McDermott co-chair Jeffrey E. Stone. “This distinguished group of attorneys brings strategically significant experience, prestige and enthusiasm to McDermott’s partnership our clients.”
Welty is a veteran tax lawyer with two decades of experience representing Fortune 100 companies, large non-US multinational companies, closely held businesses, ultra-high-net-worth individuals and tax advisors on US and international tax controversies. Prior to joining McDermott, Welty led the Tax Controversies group at a global law firm, where he was recognized as an outstanding litigator for securing strategic resolutions to high-stakes tax matters at all stages of dispute. Along with Jean Pawlow, Welty will co-chair McDermott’s Tax Controversy Practice.
Throughout his career, Welty has built a solid reputation among his peers. He is recognized as a leading practitioner by Chambers, theInternational Tax Review Guide, Law360, and The Best Lawyers in America, among others.
Mark Thomas has worked alongside Welty on Tax Controversy matters for many years, focusing on all aspects of taxation, including complex civil and criminal tax controversies and litigation, transfer pricing and domestic and international tax planning. His practice is comprehensive and includes significant experience with foreign tax authorities as well as a deep understanding of Organization for Economic Co-operation and Development (OECD) principles and treaty interpretation issues. He has also done significant work in the structuring of domestic and foreign mergers and acquisitions, corporate reorganizations and divestitures, venture capital and private equity transactions, business formations, cross-border financing arrangements and complex joint venture and partnership arrangements.
Laura Gavioli focuses her practice on the defense of individuals and corporations in white collar prosecutions, civil tax cases, US Internal Revenue Service (IRS) controversies and complex financial litigation. Her prior engagements include an extensive list of high-stakes tax litigation matters, including the successful defense of a U.S. taxpayer in a $1 billion distressed debt case that was the first of its kind to be brought to trial.
“Todd, Mark and Laura are an outstanding team of lawyers,” said Lowell D. Yoder, Firmwide head of the U.S. & International Tax Practice Group. “Their reputations in the legal community and among their clients and their impressive experience and knowledge of the industry will make them great assets to our clients.”
EY announced today that Laura M. Prendergast joined its Tax Controversy and Risk Management Services (TCRMS) group as an Executive Director located in the Iselin, NJ office. Prendergast brings 36 years of federal service, including senior executive and top-level management experience at the Internal Revenue Service (IRS), most recently as Acting Deputy Commissioner (Domestic) of the Large Business & International (LB&I) Division.
At EY, Prendergast will assist clients on working effectively with the IRS to help resolve disputes and mitigate future controversy, along with assisting with pre-filing options.
“Laura’s extensive IRS experience in the LB&I Division is a significant addition to our strong team of tax controversy professionals and will benefit our clients as they interact with the IRS,” said Eric Solomon, co-director of EY’s National Tax Department. “She brings knowledge of the IRS organization, practices and procedures, including audit and issue management strategies.”
Prior to her leadership role with LB&I, as Acting Deputy Commissioner (Domestic), Prendergast held many positions at the IRS, including Industry Director overseeing examinations for Heavy Manufacturing and Pharmaceuticals (HMP) and Heavy Manufacturing and Transportation (HMT); assistant to Deputy Commissioner of Service and Enforcement for the Offshore Voluntary Disclosure Initiative; and Large and Mid-Size Business (LMSB), director of Field Specialists. Prendergast was the Executive Lead for several initiatives, most notably the new Information Document Request (IDR) process and the implementation for Uncertain Tax Positions (UTP) and the Quality Examination Process (QEP).
Prendergast holds a Bachelor’s Degree in accounting from Kean University and a Master’s Degree in taxation from Seton Hall University. Prendergast is a certified public accountant licensed in New Jersey.
KPMG Australia has announced the hiring of senior lawyers from Maddocks’ tax controversy practice.
The move represents a significant investment by KPMG Legal and Tax Services and confirms its position as the premier practice in Australia for tax controversy services.
The team joining KPMG is led by Angela Wood, a senior tax controversy partner at Maddocks. Ross Hocking and Angelina Lagana, also senior tax controversy lawyers at the firm, have decided to come to KPMG with Angela. The team have worked with each other for over 10 years, building what has become one of the leading tax controversy teams in Australia, with significant expertise in transfer pricing.
Nationally, with the recruitment of the new team, KPMG Legal and Tax Services will grow to a practice of nine partners and special counsel, specializing in tax controversy services, with dedicated offices in Sydney, Melbourne and Brisbane.
Gary Wingrove, CEO of KPMG Australia, said “This team hire reflects KPMG’s investment-led growth agenda, and demonstrates our commitment to investing across all parts of our business. Companies are increasingly demanding specialist expertise and by meeting their needs we will achieve growth both for our own firm and for our clients. This recruitment will confirm KPMG’s position as the premier tax controversy practice in Australia.”
Rosheen Garnon, KPMG National Managing Partner – Tax, said: “We are seeing increasing interest in tax controversy, and in particular disputes with a cross-border element, including transfer pricing issues where the team has substantial expertise. The KPMG Legal and Tax Services practice has expanded rapidly over the past 12 months attracting leading professionals and the recruitment of renowned experts such as Angela, Ross and Angelina will give it real further momentum.”
She added: “Unlike other professionals in the field, who typically only act for taxpayers, Angela, Ross and Angelina offer clients a distinctive proposition and perspective, having represented the ATO for a number of years in leading tax cases. Applying this experience, they can offer clients a unique insight into how to manage their interaction with the ATO and formulate the most appropriate strategy to avert or achieve early resolution of any tax dispute.
“Joining KPMG will enable Angela, Ross and Angelina to work together with specialist tax partners to deliver complete solutions to clients, under one roof, whether it is preparing for tax audits, dispute resolution, or, if necessary, assisting with representation in court.”
KPMG has a focused growth strategy offering niche legal services focusing on tax. Tax dispute resolution is an area the firm has targeted for particular attention, as companies are increasingly looking for specialist advice to prevent and resolve tax audits and disputes.
Rosheen Garnon added: “A recent survey by KPMG International showed that 75 percent of tax executives globally were involved in a tax examination or dispute with a tax authority. In Australia the firm is seeing a rise in disputes with a cross-border element, which is why we are busy recruiting specialist tax lawyers who can help companies operating both domestically and internationally. The Maddocks lawyers joining will be of tremendous assistance in this respect.”
DLA Piper announced yesterday that Kathryn Keneally is joining the firm’s global Tax practice as chair of its Civil and Criminal Tax Litigation group. She arrives in October as partner in the New York office.
Recognized as a national leader in the tax and criminal defense bar, Keneally served as Assistant Attorney General for the Tax Division of the US Department of Justice from 2012–2014, where she was responsible for the work of over 350 attorneys. During her tenure, she developed a groundbreaking program to redress past wrongdoing by foreign banks, and she worked closely with federal and state regulators on a precedent-setting prosecution of a large financial institution. She also developed and implemented a comprehensive approach to civil and criminal tax enforcement. Attorney General Eric G. Holder recognized her achievements by awarding her the Edmund J. Randolph Award for outstanding service to the Department of Justice and the nation, the highest honor that the Attorney General may award to a department employee.
“We are pleased to welcome Kathy, who served as the nation’s top tax prosecutor, to our tax and white collar teams,” said Heidi Levine, co-managing partner of DLA Piper’s New York office. “Her impressive accomplishments in government and private practice will be an asset to the firm and our clients here and around the world.”
Prior to her service at the Department of Justice, Keneally represented businesses and individuals before the IRS and other government agencies. She was the lead trial counsel in a precedent-setting gift tax case, and has litigated extensively in the Tax Court and before state and federal courts in tax, litigation, and criminal matters. She has served as a Vice Chair of the American Bar Association Section of Taxation, and chaired two of the Section of Taxation’s Committees – the Committee on Civil and Criminal Tax Penalties, which addresses matters relating to civil and criminal tax litigation, and the Committee on the Standards of Tax Practice, which addresses ethics standards for tax practitioners. She is currently a chair of the National Institute on Criminal Tax Fraud and the National Institute on Tax Controversy.
“Kathy’s in-depth tax and enforcement background uniquely positions her to handle the most complex matters, from both regulatory and litigation perspectives,” said David Colker, global and US chair of DLA Piper’s Tax practice. “She is an ideal fit for our global platform and will be a great asset for a broad range of international matters.”
Keneally earned her LL.M. in Taxation from NYU School of Law, her J.D. from Fordham University School of Law, and her B.S. from Cornell University.
Photo source: Paul Caron: http://taxprof.typepad.com/taxprof_blog/2014/05/kathryn-keneally-.html
Jeffrey Goldman has joined Holland & Knight’s Chicago office as a partner in the firm’s Tax Controversy practice. He has worked on a number of high-profile tax matters in a variety of industries, including pharmaceutical, healthcare, manufacturing, insurance and automotive. Previously, he was a partner at Husch Blackwell in Kansas City, Mo.
“We are extremely pleased that Jeff is coming to Holland & Knight,” said Jenny Johnson, head of the Tax Controversy and Litigation team at the firm. “He will be an excellent fit for our current work representing clients with offshore financial interests and who may be facing controversy or criminal matters. Our practice continues to grow in this area, and his experience handling significant tax controversies will greatly benefit our ability to continue attracting more complex cases.”
Mr. Goldman has represented Fortune 500 companies as well as mid-sized and smaller companies on both tax and compliance issues. He has a great deal of experience advising U.S. and foreign-based insurers on tax and state regulatory matters, and in captive insurance. His background includes working with the Foreign Account Tax Compliance Act, foreign bank account reporting and voluntary disclosures, and other international tax issues, including tax treaties, taxation of expatriates, foreign tax credits, transfer pricing and debt/equity issues.
“I am so happy to become a part of the team at Holland & Knight,” said Mr. Goldman. “The depth of the tax controversy practice as well as the variety of matters the lawyers handle attracted me. I can see how my work developing offshore referrals will enhance what Holland & Knight is already doing regarding tax compliance internationally.”