Joel V Williamson

Practice Areas

Joel Williamson is widely acknowledged as one of the nation's leading tax attorneys and litigators. He has litigated over 60 tax cases. His unprecedented experience includes the trial of seven major IRC 482 transfer pricing cases, including Eli Lilly, G.D. Searle, Westreco (Nestlé), Seagate Technology, National Semiconductor, United Parcel Service and Eaton Corporation. Eaton, which also involved the cancellation of two Advanced Pricing Agreements, was decided by the US Tax Court on July 26, 2017, and resulted in a rare 100% transfer pricing taxpayer victory. In April 2022, Joel served as trial attorney in the Hyatt case. He also served as trial counsel in the Guidant LLC Tax Court case involving IRC 482 issues. In 2019, Joel litigated a debt equity issue for Chicago Tribune and Chicago Baseball Holdings. Previously, Joel was the lead trial lawyer in the debt equity case which involved Nestlé's acquisition of Carnation. Additionally, in 2019, Joel was one of the lead counsel in Mayer Brown’s virtually unprecedented favorable Bench Opinion in Cross Refined Coal LLC for Fidelity. Cross involved the taxpayer’s entitlement to refined coal production tax credits. Joel has also litigated numerous cases involving economic substance of transactions, including the United Parcel Service case noted above, as well as the Saba Partnership (Brunswick) case, and Mukerji (Comdisco), an important test case for tax-advantaged computer leasing transactions involving Comdisco. More recently, Joel litigated ConEd which involved an international Lease-In-Lease-Out transaction and Flextronics which involved an international merger and acquisition transaction. Both ConEd and Flextronics witnessed IRS arguments of economic substance and generic tax doctrines including substance over form and step transaction. In 2015, Joel litigated Exelon which involved a like-exchange of utility assets that the IRS challenged on economic substance and substance over form grounds.