Hogan Lovells has hired leading tax disputes partner Rupert Shiers into its London tax team. Rupert will join the firm next week on Monday 24 June.
Rupert will lead the direct tax disputes practice and has been a partner since 2007, most recently at Herbert Smith Freehills, from where he joins Hogan Lovells.
Rupert advises on the resolution of HMRC enquiries and investigations and has led tax litigation in the UK Tax Tribunal, English Courts and European Court of Justice. Clients he has advised in successful complex and high-value litigation include Philips and Legal & General. He also advises high net-worth individuals and is an expert on the legislation and case law governing dealings with HMRC.
Rupert’s appointment will complement Hogan Lovells’ pre-eminent indirect tax disputes practice, led by Michael Conlon QC, to offer tax dispute resolution services with specialist expertise in both direct and indirect tax, the only global law firm to do so.
Commenting on Rupert’s arrival, Fulvia Astolfi, global Co-Head of Hogan Lovells tax group said:
“Hogan Lovells has a first class global tax practice and hiring Rupert reflects our continuing commitment to grow and strengthen this team. Rupert’s skills and experience in conducting tax disputes speaks for themselves and he is a great fit with our practice, complementing perfectly our indirect tax disputes practice led by Michael Conlon QC. With the high level of scrutiny of tax arrangements in the UK, the demand for tax disputes advice is set to increase. In addition, the ever growing legal structure to Tribunal appeals means the role played by tax disputes lawyers is increasingly significant. We are very excited that Rupert is joining us”.
Rupert Shiers said:
“Hogan Lovells offers both a top performing global litigation practice and first class tax advisory practice which, combined, make the firm a perfect fit for my tax disputes expertise and provide an excellent global platform to really develop a direct tax disputes practice. I am very pleased to be joining the team here in London”.
Shiers holds 1st class law degrees from both Oxford and Cambridge.
Graham Aaronson and Joe Hage have formed a new litigation boutique named Hage Aaronson. Graham Aaronson QC is currently with Pump Court Tax Chambers but will join the new firm as a partner when he is allowed to do so by the Bar Council. Hage is also a barrister and has a reputation for advising on litigation issues for ultra HNWIs.
The Lawyer has reported that 3 former Dorsey & Whitney tax partners will be joining the tax litigation team….Michael Anderson, Simon Whitehead and Paul Farmer. Anderson joins from KPMG where he has been Head of Direct Tax Litigation for the past 6 months.
The firm’s website states that “The firm seeks to provide the best qualities of a law firm and the bar, combined into one practice”.
Miller & Chevalier Chartered announced today that it has elected a new Member.
Steven R. Dixon practices in the area of federal income taxation with a focus on tax litigation and controversy. Mr. Dixon has represented clients in trials at the U.S. Tax Court and in federal district court. He has also represented clients before the IRS. Mr. Dixon’s tax work has involved a broad range of issues, including tax accounting, basis and valuation, abandonment losses, transfer pricing, interest netting, statutes of limitations, the validity of Treasury Regulations, and the deductibility of settlement payments. He holds a J.D. from Harvard Law School, an M.A. (Philosophy) from the University of Wisconsin-Milwaukee, and a B.A. (Philosophy), magna cum laude, from the University of Toledo.
George M. Clarke has rejoined Baker & McKenzie’s renowned Tax Practice as a partner, adding 12 years of experience in a range of tax dispute resolution matters.
Based in Washington, DC, Mr. Clarke has extensive experience with all facets of the tax dispute resolution process including litigation of civil and criminal tax matters. He is also active in white collar and internal investigations. His most prominent work includes civil tax litigation and criminal tax defense but he also regularly advises clients on the defense of non-tax federal criminal matters.
“George is set to be a key player in our market-leading tax dispute resolution practice,” said Len Terr, Chair of the North American Tax Practice Group. “He is well known within the tax community in Washington and throughout North America, and clients value his extensive experience and record of success in tax disputes.”
Mr. Clarke also has substantial experience advising on the defense of foreign tax and non-tax criminal investigations and their United States implications, including with respect to U.S. tax liability accrual provisions under FIN 48.
“George’s wealth of experience in tax litigation matters is a great fit for our exceptional tax dispute resolution team,” said Elizabeth Espin Stern, Managing Partner of the Firm’s Washington, DC office. “We are delighted that he has rejoined Baker & McKenzie.”
“Baker & McKenzie’s tax practice is world-renowned and I’m excited to have returned home,” said Mr. Clarke.
Mr. Clarke is the latest in a series of prominent hires for the Tax Practice in North America during the last year. Partner Rafic Barrage, an experienced international tax planning attorney, joined the Firm’s DC office in September 2012. Partners Josh Odintz, a former Senior Advisor for Tax Reform to the Assistant Secretary at the US Department of the Treasury, and Mary Bennett, the former head of the Tax Treaty, Transfer Pricing & Financial Transactions Division of the Organisation for Economic Cooperation and Development’s Centre for Tax Policy & Administration (CTPA), recently joined the Firm’s DC office. The practice also recently welcomed Partner Anne Batter (employee benefits) to the Firm’s DC office, Partner Patricia Rexford (tax controversy) to the Chicago office, and Partner Jacques Bernier (tax controversy) to the Toronto office.
Michael Anderson has been appointed as head of direct tax litigation at KPMG in the UK.
He joins from US law firm, Dorsey & Whitney, where he was a partner in their top rated tax litigation team, having specialised in this area for nearly 10 years. In this newly-created role, Michael Anderson will be responsible for launching a direct tax litigation practice in the UK, to complement KPMG’s existing tax dispute resolution and investigations practice and its indirect tax litigation team.
Mike Linter, partner and head of people services tax at KPMG in the UK, said: “We have a well established tax dispute resolution and investigations team together with a successful indirect tax litigation practice and we see direct tax litigation as a natural extension to this.”
Michael Anderson said: “Tax litigation sits naturally within a wider tax advisory practice. Having this new direct tax litigation capability will enable KPMG to provide clients with a seamless service, should they need to resolve a dispute with HMRC in the Tribunal or higher courts. I see the challenge of establishing this new direct tax litigation service line here at KPMG as an enormously exciting opportunity. I am looking forward to working with my new tax colleagues to build a successful new and complementary business area.”
Frank Strachan has joined Edwin Coe from LSG Solicitors.
He leads the tax disputes team which specialises in advising clients who are subjected to challenges by the tax authorities, as well as advising high-net-worth clients and families wishing to ensure that their tax affairs are suitable for their needs.
Frank is recognised as one of the leading practitioners in this specialised field and works closely with other members of the Private Client Group to offer a comprehensive service to private clients. He is ably supported within the tax team by Sean Bannister and Ashley Fletcher.
Frank has 20 years’ experience in tax dispute matters and is an experienced tax dispute resolution practitioner. His detailed knowledge of HMRC’s practices and procedures means that he is able to achieve excellent settlement terms for clients.
With a wide breadth of experience in representing both personal and corporate clients subject to enquiry, Frank’s investigations experience covers cases ranging:
Prosecution defence work
Special Investigations – Code of Practice 9/CDF
Specialist Investigations – Code of Practice 8
Complex Personal Return team investigations
Ultra High Net Worth Unit investigations
Status enquiries
National Minimum Wage investigations
Local tax district enquiries
In addition to working in the UK, Frank has spent many years working in offshore jurisdictions advising offshore service providers and their clients in respect of challenges from HMRC. The length of time spent overseas advising clients provides Frank with a market leading understanding of the offshore market both in respect of the advisors but also their clients. Frank is regularly introduced by offshore wealth providers to their clients who are seeking a better understanding of their UK tax requirements.
In more recent years, Frank has become one of the UKs foremost practitioners in representing clients who are considering applying for one of HMRC’s offshore amnesties. Frank has successfully advised many clients who wished to enter into the Offshore Disclosure Facility (ODF); the New Disclosure Opportunity (NDO), and the Liechtenstein Disclosure Facility (LDF).He has also been party to consultation discussions with HMRC regarding the Swiss/UK tax agreement.
Applying a practical approach to resolving often complex matters has meant that Frank has successfully negotiated many settlements for clients subject to detailed investigations in respect of their residence and domicile positions. He has represented numerous high profile clients in the sports and media world. Managers and agents trust Frank to resolve matters quickly and practically whilst ensuring that the utmost discretion is afforded to their client’s affairs.
Frank is an active member of ICAEW’s Tax Investigations Practitioners Group. He is also a regular conference speaker on tax dispute matters and is widely quoted in both the national and trade press on tax related matters.
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.”
Ryan Law, a national firm specializing in corporate tax litigation, today announced that Mark W. Eidman has joined the Firm as a Senior Partner based in the Austin, Texas office. He will also maintain his position as Principal at Ryan, LLC, a leading global tax services firm headquartered in Dallas, Texas. Mr. Eidman is one of the leading tax attorneys in the United States and has built one of the most successful tax practices in the nation. He has represented corporate clients in hundreds of administrative appeals and court cases and has successfully litigated some of the largest state and local tax cases in the country. He has significant experience in franchise, income, insurance, motor fuel, motor vehicle, property, sales and use, and severance taxes. He has also advised numerous companies in the structuring of transactions and has worked to draft or implement legislation for the transportation, financial services, leasing, petrochemical, retail, semiconductor, and telecom industries. During his 35-year career, Mr. Eidman has been involved in administrative proceedings and court cases in more than 40 states and currently has the largest volume of pending tax cases before the State of Texas.
Prior to joining Ryan Law, Mr. Eidman was a Partner at an Austin, Texas trial law firm, where he led the Tax Practice. He also previously served as Director of the Hearings Division of the Texas Comptroller of Public Accounts, supervising all of the contested tax assessments in Texas. Mr. Eidman has achieved industry recognition as a strategic thought leader and is a frequent speaker on a variety of tax topics for the Council On State Taxation (COST), the Institute for Professionals in Taxation (IPT), the Tax Executives Institute (TEI), and many other tax-industry associations. He has served as Chairman of the Texas Comptroller’s Industry Liaison Group and has been honored as a Super Lawyer in the area of tax. Mr. Eidman is a graduate of The University of Texas at Austin and The University of Texas School of Law.
“Mark’s unparalleled success handling corporate tax disputes will be a tremendous asset to our clients,” said Kory L. Ryan, Managing Partner of Ryan Law. “Having the foremost tax attorney in Texas join our Firm represents a significant milestone in our strategy to acquire and retain the industry’s top legal talent.”
“I am proud to join Ryan Law’s impressive team of innovative tax lawyers in support of their mission to build the preeminent tax law firm in North America,” said Mr. Eidman. “I look forward to continuing to provide our clients first-rate legal services and unsurpassed results.”
About Ryan Law
Ryan Law is headquartered in Austin, Texas, with offices in Dallas and Chicago. Founded by tax and trial lawyers from some of the top law firms in Texas and the nation, the Firm handles a variety of complex tax litigation matters, with an emphasis on all levels of tax recovery, audit defense, and tax appeals for many Fortune 500 companies.
