John T Hildy

For over 25 years, clients have relied on John Hildy for advice in high-value federal tax disputes. Both in the courtroom and at the administrative stages, John’s background in both accounting and law makes him uniquely positioned to address complex tax controversies that require a deep understanding of a client’s business model and financial data, such as accounting method and transfer pricing issues.

Tax Litigation: John represents clients in some of the most complex tax litigation in the country. For instance, he recently led the legal team during a three-week trial in the US Tax Court on behalf of Hyatt Hotels Corporation, in a case involving the IRS’s attempt to change accounting methods for a guest loyalty program. Notably, he also led the team representing Boston Scientific Corporation in litigating over $4 billion of transfer pricing and related adjustments before the Tax Court.

IRS Administrative Proceedings: John is adept at bridging the gap between tax authorities and taxpayers, advising clients in dispute settlements in which the dollars at stake often reach into ten digits. John focuses on issue resolution at the earliest stage possible, not just on the steps of the courthouse. To that end, John works with clients to implement a broad set of alternative dispute resolution tools, including Tax Court-supervised mediation, traditional IRS Appeals and Appeals review of docketed issues, Early Referral to Appeals, Fast Track and Appeals Mediation, Pre-filing Agreements (PFAs), and Competent Authority and Advance Pricing Agreements (APAs). He frequently counsels corporate taxpayers on transfer pricing audits using the IRS’s transfer pricing “roadmap.”