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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Trademark portfolio management for Golder Associates
Represents Golder Associates, an international environmental consulting company, in protecting, maintaining, and enforcing key brands domestically more
Recapitalization and asset sales for a textile company

The firm represented a Special Committee of the Board of a Virginia textile company in a series of recapitalizations more

Worldwide recordation project for Caesars Entertainment Inc.
Conducted a worldwide recordation project for Caesars Entertainment Inc. to reflect a change of name. more
$30 million senior-secured revolving credit facility to a domestic and international manufacturer and distributor of cellular telephones
Represented a commercial finance company, as agent and lender, in connection with $30 million senior-secured revolving credit facility provided to a more