Jerry Libin, Chair of Sutherland's Tax Practice Group, handles matters involving virtually every aspect of domestic and international corporate taxation for a broad range of U.S. and foreign clients. His principal areas of concentration are tax controversy; tax planning (including transfer pricing); corporate acquisitions, dispositions and restructurings; and financial transactions involving domestic and international tax considerations. Jerry has successfully litigated a number of important federal tax cases. He also handles constitutional challenges to state tax statutes. Jerry has extensive experience in dealing with the U.S. Department of the Treasury in matters such as the revision of proposed regulations and the negotiation of tax treaty provisions. He has handled legislative matters involving presentations to the congressional tax-writing committees and the Joint Committee on Taxation. As a consultant to the American Law Institute International Tax Study Project, Jerry participated in the development of a number of international tax proposals that became part of the Internal Revenue Code of 1986. He has also served as an informal adviser to the staff of the U.S. Senate Finance Committee. Before joining the firm, Jerry served as a law clerk to the Honorable Charles E. Whittaker, Associate Justice of the U.S. Supreme Court. Representative Experience Jerry's extensive representative experience includes: · Representing Kraft Foods before the U.S. Supreme Court in an important case involving the constitutionality of an Iowa taxing statute. · Representing State Farm, AIG, General Electric and other major corporations in various tax controversy matters. · Representing the U.K. Government in tax cases before the U.S. Supreme Court and the Court of Federal Claims. · Advising corporations on both outbound and inbound tax planning issues. · Advising foreign corporations on U.S. tax treaty issues. Professional Honors and Awards · Named Best Lawyers' 2012 Lawyer of the Year in Washington, D.C in the area of Litigation and Controversy - Tax Law · Recognized by Chambers Global: World's Leading Lawyers · Recognized by Chambers USA: Guide to Leading Business Lawyers in the areas of tax and tax controversy · Recognized by The Legal 500 United States in the area of tax controversy · Named to The Best Lawyers in America in the area of litigation and controversy - tax law · Named to the Washington, D.C. Top 100 Super Lawyers by Washington, D.C., Super Lawyers® · Named to the Practical Law Company's Cross-Border Tax on Transactions Handbook · Named to PLC Which Lawyer? Yearbook in the area of tax · Selected for inclusion in Guide to the World's Leading Tax Advisers · Selected for inclusion in International Tax Review World Tax Guide · Selected for inclusion in International Who's Who of Corporate Tax Lawyers Professional and Community Involvement · Former President, International Fiscal Association (IFA), the largest professional organization in the world devoted exclusively to the study of international tax matters (2001-2005) · Former Member of Council and Chair of Special Committee on Standing to Sue, Committee on Integration, Special Projects Committee and Globalization Task Force, Tax Section, American Bar Association · Past Chair, Taxation Division, District of Columbia Bar · Fellow, American College of Tax Counsel · Master of the Bench, American Inns of Court (J. Edgar Murdock Inn, the only Inn of Court dealing with federal tax matters) · Member, Executive Committee, U.S. Branch, IFA Recent Publications and Speaking Engagements · Author, "Should the Internal Revenue Code Include a GAAR?" Toward Tax Reform: Recommendations for President Obama's Task Force, Tax Analysts Compendium (2009) · Author, "Ambiguous Amnesty in the Jobs Creation Act," Executive Counsel (January/February 2005) · Speaker, "Limitation of Benefits: Best Practices - and Worst Practices," 39th Annual Conference of the USA Branch of IFA (February 24-25, 2011) · Speaker, "Tailoring Dispute Resolution Strategies for Tax Positions Involving Multiple Jurisdictions," International Bar Association's Annual Conference (October 3-8, 2010) · Panelist, IFA Congress, Brussels, Belgium (September 2008) · Speaker, TEI: European Chapter Winter Conference (January 2008) · Panelist, IFA Congress, Kyoto, Japan (October 2007) · Speaker, 2006 Tax Education Series (February 2006) News Sutherland Makes Mark in The Legal 500 for 2011 December 1, 2011 Four Sutherland Partners Recognized by Peers as "2012 Lawyers of the Year" October 21, 2011 Nine Sutherland Attorneys Named D.C. Super Lawyers in 2011 May 3, 2011 Sutherland Attorneys, Practices Top Chambers USA 2011 Rankings April 14, 2011 The Legal 500 United States Recognizes Sutherland July 7, 2010 Sutherland Earns Top Chambers USA 2010 Rankings July 7, 2010 Eight Sutherland Attorneys Recognized by Washington DC Super Lawyers March 3, 2010 Q&A With Sutherland's Jerome Libin October 22, 2009 Reprinted with permission Law 360, http://www.law360.com The Legal 500 United States Recognizes Sutherland June 29, 2009 Twelve Sutherland Attorneys Recognized by Washington, D.C., Super Lawyers® April 30, 2009 Sutherland Launches WorkerClassification.com Web Site Addressing the Classification of Today's Workforce April 28, 2009 Chambers Global Recognizes Sutherland Sutherland's practices and attorneys ranked in 2009 edition April 9, 2009 Legal Alerts Legal Alert: LB&I Internal Directive Limits Application of the Economic Substance Doctrine and Related Penalties, but Raises Concerns about Transparency and Consistency of Process July 21, 2011 Legal Alert: Supreme Court Holds Chevron Deference Applicable to "Interpretive" Regulations January 26, 2011 Legal Alert: Supreme Court Resolves "Hot Button" Tax Issue - Holds Chevron Deference Applicable to "Interpretive" Regulations January 20, 2011 Legal Alert: The IRS Adopts Largely Taxpayer-Favorable Changes To Schedule UTP September 28, 2010 Legal Alert: Not Much Substance in IRS Interim Guidance on Codification of the Economic Substance Doctrine September 14, 2010 Legal Alert: IRS Announces It Will Require the Disclosure of Uncertain Tax Positions January 26, 2010 Legal Alert: American Jobs Creation Act of 2004 October 25, 2004 Publications Ambiguous Amnesty in the Jobs Creation Act January/February 2005 Executive Counsel Events TEI New Orleans Chapter Meeting April 17, 2011 TEI Atlanta Chapter - U.S. International Section April 1, 2011 39th Annual Conference of the USA Branch of the International Fiscal Association February 24-25, 2011 International Bar Association's Annual Conference October 3-8, 2010 IFA Congress, Brussels, Belgium September 2008 TEI European Chapter Winter Conference January 28-29, 2008 IFA Congress, Kyoto, Japan October 2007 2006 Tax Education Series February 13, 2006 |