Represented a global manufacturer in a case involving a highly controversial “listed transaction” being challenged by the IRS.  The listed transaction at issue, which initially was undertaken by many corporate taxpayers, involved the client claiming deductions for contributions to its 401k plans prior to the year that employees performed the services giving rise to the contributions. While the weight of authority supported this deduction in the taxpayer's circumstances, the IRS challenged the deduction, labeling it abusive. The team filed a Motion for Partial Summary Judgment, asking the Tax Court to dismiss the IRS's proposed deficiencies relating to the 401k deductions. The IRS agreed to concede the case, dropping its proposed assessments of tax and penalties exceeding $25 million.

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Economic development of PRA International
Represented PRA International, a leading global clinical research organization, in its headquarters relocation to Raleigh, including negotiating more
Alternative dispute resolution for a Las Vegas-based developer
Represented a Las Vegas-based developer/owner in a complex $85 million arbitration with its general contractor. The dispute arose out of the more
Construction legal services for the American University in Cairo
Represented the American University in Cairo, Egypt with regard to its construction of a new $400 million, 2 million square foot campus near more
Generated content contest aligned with Super Bowl for well-known job search and career management Internet site
Advised well-known job search and career management Internet site on all sweepstakes, contest, and copyright/user generated content law aspects of more