co-heads Mayer Brown’s Tax Controversy and Transfer Pricing practice and has a deep track record of successfully resolving high-stakes and sophisticated tax disputes. Brian achieved a rare bench opinion for Cross Refined Coal LLC and its partners, Fidelity Investments, Schneider Electric and AJ Gallagher, in the US Tax Court. He also secured a taxpayer victory for Eaton Corporation in the first case involving a court’s consideration of an IRS decision to retroactively cancel an advance pricing agreement. Having clerked at the US Tax Court, he brings an insider’s perspective to trial preparation and presentation. Brian frequently speaks on, and authors articles, about substantive and procedural tax issues.
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