Representative Experience

  • Saved a client more than $500 million in federal income taxes in a high-profile transfer-pricing case by showing the lack of merit of IRS proposed adjustments.
  • Achieved through an advanced pricing agreement a favorable transfer-pricing methodology, which was rolled back to resolve more than 10 years of potential issues on a favorable basis.
  • Resolved three cycles of domestic and international issues for a foreign multinational operating in the U.S. through a number of U.S. subsidiaries.

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  • Transfer Pricing
    • Successfully resolved the only transfer-pricing dispute brought to arbitration through the Tax Court’s Arbitration.
    • Assisted a large U.S. microchip fabrication company through obtaining a “Fast Track” resolution of profit split computation issues.
    • Represented a large U.S. publishing outsourcing company in connection with a substantial dollar transfer-pricing adjustment proposed by IRS.
  • IRS
    • Saved a client more than $500 million in federal income taxes in a high-profile court case by showing the lack of merit in nearly every IRS position taken.
    • Represented a large U.S. staffing organization in negotiation of a 95 percent reduction in significant-dollar proposed IRS adjustments.
    • Following more than three years of negotiations, prevailed for large Japanese electronics firm in transfer-pricing dispute with the IRS, convincing IRS to withdraw proposed adjustments of $50 million+ in back taxes and interest.
    • Represented a United Kingdom multinational telecommunications company with a major debt vs. equity issue involving proposed adjustments exceeding $400 million in first IRS challenge to a multinational standard centralized cash management practice. 
  • Swiss Banks
    • Structured unprecedented settlements between Swiss financial institutions and U.S. prosecutors, enabling clients to avoid potentially billions of dollars in exposure under U.S. tax laws and avoid criminal prosecution.
    • Represented several Swiss banks in probes by the DOJ and Internal Revenue Service into offshore U.S. related accounts.
    • Representing one of largest government-owned Swiss banks, a cantonal bank outside Geneva, and its private banking subsidiary, in historic DOJ Program for Non-Prosecution Agreements or Non-Target Letters for Swiss Banks.
    • Assisting Swiss banks in conducting internal investigation, working closely with outside forensic accountants to extract and analyze years of U.S. client account records to meet DOJ Program demands.
    • Engaging in continuing dialogue with DOJ on behalf of Swiss bank clients regarding interpretation of the Non-Prosecution Program provisions and negotiations regarding assessment of substantial fines against participating banks.
  • Wealth Management / Estate Planning
    • Serving as co-trustee of ongoing trusts and charitable foundation with assets in excess of $2 billion and providing strategic advice on matters involving cultural institutions and long-range tax planning.
    • Representing high-net-worth real estate investor widow, contributed essential advice that saved the client hundreds of millions of dollars in tax.
    • Represented high-net-worth investor’s widow in negotiating confidential settlement believed to be among 2014’s largest litigated estate matters. Case presented novel, complex conflicts of law, state taxation and multistate residence issues.

Practice Area Highlights

  • Received American Lawyer’s 2015 “Global Dispute of the Year” Award in the area of Investigations for achievements in guiding multiple Swiss banks through the DOJ’s Swiss Bank Program.
  • Ranked among nation’s top Tax Litigation practices by Chambers USA, clients say Pillsbury is “fantastic at IRS audits and appeals” and “understand[s] where you want to go and [gets] you there.”
  • Received top-tier recognition from U.S. News & World Report nationally for tax litigation and ranked for excellence in handling tax controversies by The Legal 500 US.

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  • Pillsbury’s tax team is ranked by the International Tax Review—California and New York.