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Provided by Charles Rettig
Criminal Tax Defense
Estate & Income Tax Planning & Estate Administration
Family Office
State and Local Tax Controversy & Planning
Tax
Tax Controversy & Litigation
Tax Planning & Business Transactions
Charles “Chuck” Rettig, a Shareholder at Chamberlain Hrdlicka in the Firm's Tax Controversy & Litigation practice and other Tax and Trust & Estate practices, served as Commissioner of the Internal Revenue Service (IRS) from 2018 through 2022.
As a member of Chamberlain Hrdlicka’s Tax Controversy & Litigation Practice, he draws on both his extensive background representing taxpayers and his deep knowledge of the IRS organization, operations and procedures in work for his clients. His practice focuses on tax, federal and state tax controversies and investigations, including sensitive issue examinations, administrative appeals, civil tax litigation, and representation in criminal tax investigations and prosecutions.
As IRS Commissioner, Chuck presided over the nation’s tax system, which collected more than $4.9 trillion in tax revenue in FY22, representing about 96% of the total gross receipts of the United States. He managed an agency of about 83,000 employees and a budget of more than $14.1 billion. During his tenure, he focused on improving service to the nation’s taxpayers, balancing appropriate enforcement of the nation’s tax laws while respecting taxpayer rights, with a particular focus on traditionally underserved communities. In recognition of his leadership of the IRS, Chuck received the Alexander Hamilton Award from Treasury, the highest honor for individuals selected by the Secretary, whose performance and leadership demonstrate the highest standards of and dedication to public service benefiting our country.
Chuck came to the IRS from a background of defending taxpayers in tax controversies, and he put those insights to use while at IRS. He was often referred to as the “straight shooting” Commissioner, who worked closely with his Division Commissioners in Criminal Investigation, Large Business & International, Small Business/Self Employed, Wage & Investment, and Tax-Exempt & Government Entities to build new enforcement programs and decide how to allocate enforcement resources. A senior Senator on the U.S. Senate Finance Committee once stated “Although we didn’t always agree, Rettig called balls and strikes fairly.”
Before heading the IRS, Chuck spent 36 years with an esteemed tax law firm in Beverly Hills, California, where he represented high net-worth individuals, businesses, and corporate taxpayers before the IRS, the Department of Justice Tax Division, federal and state courts and state taxing authorities. Significantly, he earned a reputation for helping his clients resolve disputes with taxing authorities. Although Chuck mounted vigorous defenses for clients and would go to court when necessary, he was adept at resolving matters without litigation, enabling his clients to move their businesses and lives forward as quickly as possible.
Internal Revenue Service, Commissioner (2018-2022)
California Franchise Tax Board, Advisory Board (1998 – 2018)
California State Board of Equalization, Advisory Council (2011 – 2014)
IRS Advisory Council (IRSAC – Past Chair, 2010-2011)
Chambers USA, the only Eminent Practitioner in the category “Tax Fraud – Nationwide” (2015-2018)
NYU Institute on Federal Taxation (Chair, Tax Controversies, 2007-2018, 2024)
USC Annual Institute on Taxation, Executive Committee (2003-2018, 2024)
ABA Annual National Institute on Criminal Tax Fraud and Tax Controversy, Institute Co-Chair (2010-2018)
UCLA Extension Annual Tax Controversy Institute (Chair, 1997-2018)
NYU Annual Tax Controversy Forum, Planning Committee Member (2009-2013)
American Bar Association, Section of Taxation (Past Vice-Chair, Administration)
American College of Tax Counsel (President, 2018)
United States Tax Court Judicial Conference, Invited Participant (1999-2015)
Taxation Section of the State Bar of California (Past-Chair)
Beverly Hills Bar Association, Taxation Section, Chair (2001-2003)
NYU University School of Law, National Board of Advisors, Graduate Tax Program (LL.M. in Taxation –1999-2008)
California CPA Education Foundation, Board of Trustees (2007 – 2011)
Society of Trust and Estate Practitioners (STEP, 2009- 2018)
American Tax Policy Institute
U.S. Court of Federal Claims Bar Association
Golden Gate University, Graduate School of Taxation, Advisory Board (2006-2015)
Chapman University School of Law, Graduate Tax Program, Advisory Board (2004-2008)
"Managing Private Placement Life Insurance Risk," Family Office Magazine
"IRS Staff Exodus Expected to Curb Future Hiring Efforts," Tax Notes
“Turnover on Downs: The IRS’s Rejection of NIL Collectives as Tax-Exempt Entities,” Sports Business Journal
“Turnover Is Coming to the Justice Department Tax Division,” Tax Notes
“Ex-IRS Head Rettig Warns of Agency Funding Cut Effects,” Daily Tax Report – Bloomberg Tax
"How To Litigate ERC Refund Claims," Forbes
Tom Cullinan, with Chuck Rettig, Contributes to Forbes
July 1, 2024
IRS Staff Exodus Expected to Curb Future Hiring Efforts, 2025
What to Expect from Newly Announced LB&I Compliance Campaigns, 2017
TIGTA Evaluation of the IRS Whistleblower Program, 2016
IRS High Wealth Industry Group, 2013
Why the Ongoing Problem with FBAR Compliance?, 2016
In a Tax Practice, Everything Is Fine, Until It’s Not!, 2016
The Panama Papers and Lessons Learned from Years of Offshore Leaks, 2016
IRS Audit Selection and Classification Processes, 2016; Evaluating the IRS Wealth Squad, 2015
Basic Overview: The Kovel Accountant and Privileged Communications, 2015
Handling the Sensitive Issue IRS Audit, 2015; NEW IRS Guidance Limits FBAR Penalties! 2015
Determining “Reasonable Cause” for Nonwillful FBAR Violations, 2015
Overview: Trust Fund Recovery Penalty, 2015
Overview: IRS Examination Process, 2014
Overview: Indirect Methods of Determining Taxable Income, 2014
IRS LB&I Revised IDR Enforcement Process, 2014
GAO to IRS: Pursue Quiet Disclosures and First Time FBAR Filers, 2013
IRS Offshore Voluntary Disclosure Program: Opt-Outs, a Revised FBAR and Rescissions of Pre-Clearance Letters by Criminal Investigations, 2013
Whistleblower Awards and the Bank Secrecy Act: Mutually Exclusive?, 2013
Form 8300: Reporting Domestic Currency Transaction, 2013; A Temporary and Transitory Visit with California Residency, 2013;
Innocent Spouse: Separating the Marital Liability, CCH Journal of Tax Practice and Procedure, August-September 2012
IRS Provides Updated Guidance Regarding Offshore Voluntary Disclosure Program, CCH Journal of Tax Practice and Procedure, June-July 2012
Overview of Tax Practice and Procedure, CCH Journal of Tax Practice and Procedure, April-May 2012
IRS Whistleblower Program: Making Money the Old Fashioned Way! CCH Journal of Tax Practice and Procedure, April-May 2012
Practice Tips from the Tax Trenches, CCH Journal of Tax Practice and Procedure, December 2011 - January 2012
IRS Voluntary Classification Settlement Program, CCH Journal of Tax Practice and Procedure, October- November 2011
Evaluation of an IRS Undisclosed Offshore Account IDR, Tax Notes Column, November 2011
A Fresh Start for Struggling Taxpayers, CCH Journal of Tax Practice and Procedure, June-July 2011
Enhancing Voluntary Compliance Through the Administration of Civil Tax Penalties, CCH Journal of Tax Practice and Procedure, April-May 2011
The Last, Best Chance to Disclose Foreign Financial Accounts and Assets -The 2011 Offshore Voluntary Disclosure Program and Beyond!, CCH Journal of Tax Practice and Procedure, February-March 2011
Basic Audit Techniques: Taxpayer Interviews, CCH Journal of Tax Practice and Procedure, August-September 2010.
FOIA Requests, Tax Notes Column, August 2010
IRS Return Preparer Strategy: Leveraging Limited Tax Enforcement Resources Through the Registration and Education of the Return Preparer Community, CCH Journal of Tax Practice and Procedure, February-March 2010
Meet the New Director of the Office of Professional Responsibility: An Interview with Karen L. Hawkins, CCH Journal of Tax Practice and Procedure, August-September 2009
Practitioner Penalties: Potential Pitfalls in the Tax Trenches, Tax Notes, April 2009
Counseling Corporations Involved in Government Investigations and the Principles of Federal Prosecution of Business Organizations, Corporate Business Taxation Monthly, February 2009
Update: Estate Planners as Return Preparers - Increased Penalty Exposure and the New Final Regulations, CCH Estate Planning Monthly, February 2009
Currency Reporting Requirements: Everyone into the Pool! CCH Journal of Tax Practice and Procedure, June-July 2007
Civil and Criminal Tax Considerations in a Marital Dissolution, Hawaii State Bar Journal, July 2007
Tax Practitioners Guidebook: Picking Up Scraps From the Table, Tax Analysts - Tax Practice, 2007
Non-Filers Beware: Who’s That Knocking at Your Door? CCH Journal of Tax Practice and Procedure, October-November 2006
Identity Theft: Phishing on the Internet, KALA Hawaii Society of CPA’s, July 2005
Bar Admissions:
California
Hawaii
Arizona (Inactive)
Court Admissions:
United States Court of Appeals for the Ninth Circuit
United States Court of Appeals for the Fifth Circuit
United States Court of Federal Claims
United States District Court, Hawai’i
United States District Courts - CD Cal, SD Cal, ND Cal, ED Cal
United States Tax Court
University of California at Los Angeles
Bachelors
Pepperdine University
J.D.
New York University School of Law
LL.M.
Provided by Chambers
Charles Rettig is the former Commissioner of the IRS and has recently rejoined private practice as a shareholder at Chamberlain Hrdlicka. Rettig is renowned and widely respected in the market for his expertise in tax controversy and litigation.