Henry Cheng

Tax; Tax Controversy and Disputes

Henry Cheng is a tax controversy and litigation partner in the firm’s San Francisco office. Before joining DLA Piper, Henry was a law clerk to the Honorable David Laro of the U.S. Tax Court.

Henry has more than a decade of experience successfully representing businesses and multinationals in all aspects of complex civil tax disputes at the federal, state and local levels, as well as in cross-border tax controversy matters. He represents clients across industries and sectors, including high tech and emerging growth, real estate development, travel and hospitality, telecommunications, consumer products, international shipping and logistics, financial services, and investment funds. Henry has consistently obtained favorable results for his clients in administrative hearings, litigation, and trials.

In federal civil tax controversy matters, many of his engagements involve international tax issues, such as sourcing of income, anti-deferral regimes, foreign tax credits, U.S. trade or business and permanent establishment, transfer pricing, and treaty issues.

In state and local civil tax controversy matters, Henry has represented clients in matters involving sales and use tax, transient occupancy tax, payroll/unemployment tax, property tax as well as residency and income sourcing and allocation issues. Henry also represents clients in tax refund actions in state courts.

Henry is also an adjunct professor at University of California College of Law San Francisco (formerly UC Hastings) where he teaches tax procedures and tax controversy. He frequently speaks at conferences on current tax controversy issues and topics. Before he began pursuing his tax practice, Henry was a patent litigator. He is a registered patent attorney admitted to practice before the USPTO and is therefore well versed in all issues relating to technology and IP law.