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.
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.”