At Mayer Brown, I represent multinational corporations in the audit and appeals phases of an IRS dispute, as well as in litigation. I have particular experience with controversies arising from complex transactions, typically in a cross-border context, such as leveraged distributions and other repatriations, intercompany debt, worthless stock deductions, and cost sharing arrangements. I have litigated significant cases in Tax Court involving intercompany debt (ScottishPower) and consolidated return (Duquesne Light) issues.I also have many years of experience advising clients on structuring mergers, acquisitions and internal reorganizations, and now regularly advise clients on planning issues arising from the Tax Cuts and Jobs Act.. I am a frequent lecturer on corporate tax issues, and I am an author of the BNA Tax Management Portfolio entitled “Corporate Acquisitions- (A), (B), and (C) Reorganizations." My former positions include co-leader of PwC’s U.S. tax controversy practice, leader of Morgan Lewis’s tax controversy and transactions practice, and Deputy Chief Counsel of the IRS. At the IRS I was in charge of approximately 700 attorneys in the Office of Chief Counsel and had primary responsibility within the IRS for developing its positions on technical tax issues and the issuance of regulations and rulings.Attorney Advertising