John T Hildy

Practice Areas

John Hildy has represented taxpayers in all stages of federal tax controversy, including pre-audit, audit, administrative appeals, and litigation. John has also advised taxpayers in connection with competent authority negotiations, advance pricing agreements, and other tax treaty matters. John's practice focuses heavily on defending and structuring transactions with significant transfer pricing implications, including cross-border transfer pricing of tangible and intangible property, shared headquarter services, and cost sharing arrangements. He has advised both US taxpayers with respect to international tax implications of off-shore operations as well as non-US taxpayers with respect to the implications of their US activities.