Leads the Federal Tax Controversy group at Morrison & Foerster. He represents domestic and international clients in audit, appeals and litigation on all Federal tax issues. As a trial attorney of the Department of Justice Tax Division he litigated numerous tax refund cases. Some recent matters he has handled involved transfer pricing, subpart F and ECI issues, financial products issues, a variety of information reporting issues, penalties, privilege and work product issues.
Author, U.S. chapter of The Tax Disputes and Litigation Review and Transfer Pricing Review.