Practice/Industry Group Overview
Sutherland handles intricate federal, international, and state and local tax matters, providing custom solutions to address our clients’ tax needs.
Sutherland serves as tax counsel to many of the world’s most prominent corporations—including more than 35 of the Fortune 100—in every area of federal, international, state and local tax law. Our prominence in legal tax services dates back to the firm’s founding nearly a century ago. More than 100 tax lawyers represent taxpayers in federal, international, employee benefits, insurance, tax exempt, and state and local tax matters. By virtue of the size of our tax practice and our varied client base, we are active in every area of taxation—from planning the most complex corporate tax transactions to representing taxpayers in administrative and judicial tax controversies.
Our tax practice counsels in domestic and international tax planning, tax controversy, insurance taxation, joint ventures and partnerships, tax accounting, state and local tax, employee benefits, executive compensation and wealth management. Our tax attorneys apply a cross-disciplinary, cross-office approach to uncover new opportunities and develop creative solutions.
Our tax lawyers are recognized for their skills and acumen with appointments to national leadership positions in government and the private sector. Our firm has produced two IRS commissioners, one IRS Chief of Appeals and one IRS chief counsel. Further, our tax team includes attorneys who have held other positions at the IRS, the Treasury Department, and the Tax Division of the Justice Department. Members of our team have also served as leaders in the American Bar Association’s Section of Taxation, the Internal Revenue Service Advisory Council, the American College of Tax Counsel, the International Fiscal Association and the Council On State Taxation.
Deep tax knowledge. More than 100 attorneys focus their practices on federal, international, state and local tax law.
Collaborative approach. We partner with corporate in-house teams to develop effective strategies for tax planning, transactions and disputes that serve the client’s tax and business objectives.
Connections. Many of our tax attorneys, including our tax litigators, served in federal, state or local government positions. This gives our tax team an understanding of the authorities' view of tax matters that can facilitate resolution of issues.
Success. Our clients recognize the results we achieve across all areas of our broad-based tax practice.
Firmwide support. Our tax lawyers are part of a much bigger and more diverse law firm. They can draw on the talents and experience of other attorneys with a vast range of understanding and knowledge—from energy to financial services.
Nuts and Bolts
Our key experience includes:
- Federal taxation
- International taxation
- State and local taxation
- Tax controversy and litigation
- Joint ventures and reorganizations
- Mergers, acquisitions, dispositions and spinoffs
- Employee benefits and executive compensation
- Income taxes, property taxes, and sales and use taxes
- Partnership tax
- Audits and disputes
- Inbound and outbound tax planning
- Transfer pricing
- Withholding and information reporting
- Wealth management
- Tax accounting
If you have a need for deeply experienced tax counsel and pragmatic, efficient tax solutions, our tax attorneys can help.
Sutherland acts as tax counsel in $25 billion spinoff.
Sutherland acts as tax counsel to Mondelez International in its approximately $25 billion spinoff of Kraft Foods Group.
Sutherland represents international insurance company in tax litigation regarding $306 million tax refund.
Sutherland represents an international insurance company in a refund suit that it filed for its 1997 tax year, seeking the return of approximately $306 million in tax, penalties and interest. The case involves a number of issues, including whether the company is entitled to certain foreign tax credits that it claimed in various cross-border financing transactions.
W. L. Gore retains Sutherland in complex state tax litigation.
Sutherland is representing W. L. Gore in landmark litigation regarding the state taxation of holding companies.
Articles Authored by Lawyers at this office:
Impact of International Tax Reform Proposals on U.S. Insurance Companies
Dennis L. Allen,Thomas A. Gick,Jerome B. Libin,Jeffrey H. Mace,Michael R. Miles, November 27, 2013
On November 19, retiring Senate Finance Committee Chairman Max Baucus (D-Mont.) released a “Discussion Draft” setting forth his international tax reform proposals. Of note, the Discussion Draft includes several proposals that target the international operations of U.S. insurance...
No Longer at Sea: IRS Finalizes Safe Harbor Reduction Regulations
, November 25, 2013
On November 14, 2013, the Internal Revenue Service (IRS) issued final regulations that permit employers to suspend or reduce safe harbor nonelective contributions under a 401(k), 401(m), or 403(b) plan during the plan year. The final regulations also revise the requirements that apply to mid-year...
IRS Issues Final Regulations Regarding Transfers of Derivative Contracts
Robert S. Chase,Daniel R.B. Nicholas,Amish M. Shah,Rich Sun, November 15, 2013
On November 5, 2013, the Internal Revenue Service (IRS) issued final regulations relating to the transfer or assignment of certain derivative contracts. The final regulations, which are provided as Treas. Reg. § 1.1001-4, address:
IRS Modifies “Use-It-Or-Lose-It” Rule for Health FSAs
, November 08, 2013
In Notice 2013-71 (Notice), the Internal Revenue Service (IRS) relaxed its longstanding “use-it-or-lose-it” rule for health flexible spending accounts (Health FSAs). Employees may now be permitted to carry over up to $500 of their unused Health FSA balances to the following plan year to...
IRS Issues Draft FATCA FFI Agreement and Announces Positive New Rules for Insurance Companies
Dennis L. Allen,Jeffrey H. Mace,Michael R. Miles,M. Kristan Rizzolo,Carol P. Tello, November 04, 2013
On October 29, the Internal Revenue Service (IRS) issued Notice 2013-69, which includes guidance to foreign financial institutions (FFIs) entering into FFI agreements with the IRS and a draft FFI agreement. The Notice also describes some of the changes the IRS intends to make to the recently...
Illinois Click-Through Nexus Law Preempted by the Internet Tax Freedom Act
, October 25, 2013
In a 6-1 decision, the Illinois Supreme Court affirmed an Illinois Circuit Court holding that Illinois Public Act 96-1544 (The Click-Through Nexus Act), requiring out-of-state retailers to collect and remit use tax, violates the Internet Tax Freedom Act (ITFA). Performance Marketing Ass’n v....
OECD Summarizes Transfer Pricing Documentation Questions Ahead of November Consultation
Robert S. Chase,Mikka Gee Conway,Jennifer B. Molnar,Carol P. Tello,H. Karl Zeswitz, October 11, 2013
The Organisation for Economic Co-operation and Development (OECD) has issued a memorandum in connection with the planned overhaul of transfer pricing documentation rules under its action plan to address base erosion and profit-shifting. The memorandum follows the OECD’s July 30 “White...
IRS Updates Renewable Energy Tax Credit Beginning of Construction Guidance
, September 26, 2013
On September 20, 2013, the Internal Revenue Service (IRS) issued Notice 2013-60, which provides additional guidance that will help developers and purchasers of renewable energy facilities meet the beginning of construction requirement for the renewable energy section 45 production tax credit (PTC)...
BATSA Up: Congress Once Again Considers Nexus Legislation
Andrew D. Appleby,Zachary T. Atkins,Madison J. Barnett,Marlys A. Bergstrom,Jonathan A. Feldman, April 27, 2011
Would Thomas Jefferson approve of Congress imposing its will on state efforts to collect income tax from out-of-state companies? That was the question posed by Rep. Steve Cohen (D-TN) to two sponsors of the Business Activity Tax Simplification Act of 2011 (BATSA) (H.R. 1439) who both happen to be...
ACLU Sues North Carolina Over Its Sales/Use Tax Audit Practice
Michele Borens,Jeffrey A. Friedman,Stephen P. Kranz,Marc A. Simonetti,Eric S. Tresh, July 15, 2010
The aggressiveness of some states to assert tax jurisdiction over out-of-state retailers (or to enforce tax against their customers) took another turn last week. On June 23, 2010, the American Civil Liberties Union (ACLU) filed a complaint in U.S. Federal District Court against Kenneth Lay in his...