Dianne C. Mehany

Dianne C. Mehany: Attorney with Caplin & Drysdale, Chartered
  • Member at Caplin & Drysdale, Chartered (67 Attorneys)
  • One Thomas Circle NW, Suite 1100, Washington, DC 20005
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Dianne C. Mehany is a Member in Caplin & Drysdale's Washington, D.C., office. She joined the firm in 2010.


Ms. Mehany's practice focuses on international tax planning and controversies, including inbound and outbound tax planning, foreign tax credits, tax treaties, tax audits, and FATCA planning and compliance. She also has experience in tax compliance of individuals, companies and financial institutions in the cross-border context, including FATCA reporting, reporting of interests in foreign trusts, and offshore financial accounts and assets.

Ms. Mehany's practice also encompasses income and succession planning for wealthy individuals and families, including pre-immigration planning and expatriations, and foreign trusts.

In addition to advising clients in these areas, Ms. Mehany has extensive experience advising individual and corporate clients in federal civil and criminal tax controversy matters. She guides clients through all stages of IRS disputes, including preparing protests of IRS actions, representing clients at appeals conferences, filing petitions in the Tax Court and complaints in District Court, and assisting with trial matters and settlement discussions. Moreover, Ms. Mehany has counseled individual clients and financial institutions on the U.S. government's investigation of undisclosed foreign assets, particularly with respect to the classification of foundation and trust structures.

Government Experience

Attorney Advisor, U.S. Tax Court, Honorable D. Irvin Couvillion, Washington, D.C., 2004-2006

Law Clerk, Sex Crimes Division, Office of the District Attorney, Baton Rouge, LA, 2002-2003


•Served on the trial team, who achieved a multi-million dollar victory in the Tax Court regarding the deductibility of a termination fee.
•Achieved a summary judgment on research credit for privately-held company.
•Successfully obtained private letter rulings granting Section 9100 relief for changes in accounting method, retroactive applications of registration, and retroactive elections.
•Served on the trial team for Avenell v. Commissioner, T.C. Memo 2012-32, which successfully defended the taxpayer against allegations of fraud by the IRS.
•Member, Wex S. Malone American Inn of Court (one of ten from the graduating class invited for membership due to outstanding performance in LSU Trial Advocacy Program).
•Represented pro bono matters through the Houston Bar Association from 2006-2010.

Awards & Rankings

Super Lawyers, Rising Star, Washington, D.C., 2017-Present
The Legal 500, Recommended, 2016
The American Lawyer's Global Legal Award, Global Dispute of the Year: Investigations, Swiss Tax Settlements, 2015
Nolan Fellowship, American Bar Association, Section of Taxation, 2015-2016

Recent Publications

• The New Voluntary Disclosure Practice: A Fair Compromise?, with Zhanna A. Ziering, Arielle M. Borsos, Scott D. Michel, and Mark E. Matthews, Caplin & Drysdale Client Alert, December 3, 2018

Recent Speaking Engagements

Ms. Mehany speaks before many professional associations and conferences. Her recent engagements include:

•Speaker, Multistate Allocation of Trust Distributable Net Income: Income Sourcing and Apportionment, Strafford Publications, February 21, 2019
•Panelist, 360 Degree Perspective: U.S. Withholding and Global Information Reporting, ABA Section of Taxation, 2019 ABA Midyear Meeting, January 17, 2019
•Panelist, Calculating Foreign Trust DNI and UNI: Avoiding Throwback Tax on Undistributed Net Income, Strafford Publications, October 31, 2018
•Panelist, Dispute Resolution, ICAP, MAP, OECD International Tax Conference, June 4, 2018
•Presenter, Expatriation Tax, IBC Finance, May 8, 2018
•Panelist, Trust Distributions to Foreign Beneficiaries: Complex Planning and Calculation Challenges, Strafford, February 27, 2018
•Panelist, International Tax Reform, American Bar Association Section of Taxation 2018 Midyear Meeting, February 8, 2018
•Speaker, The Future of US Cross-Border Criminal Tax Enforcement, Cross Border Planning for the Private Client - Asia, August 16, 2017
•Panelist, U.S. Tax Compliances for Americans Living in India and Remedial Measures for Non-Compliance, Grant Thornton and Caplin & Drysdale, June 14, 2017
•Panelist, The Pressures on Offshore Jurisdictions, TransTrusts: International Forum 2017, May 5, 2017
•Panelist, Innovation - The Key to a Strong Economy: A Discussion of Immigration and Tax Policies to Encourage the Development of an Innovative Economy, American Bar Association Section of International Law, April 27, 2017
•Speaker, Subpart F Income Tax: Its Scope and Application to US Shareholders, ABA Tax Section, January 19, 2017
•Speaker, Trust Distributions to Foreign Beneficiaries, Strafford, January 5, 2017
•Speaker, Mastering Form 3520: Reporting Foreign Trust Activities on U.S. Income Tax Returns, Strafford, July 14, 2016
•Speaker, FATCA: How It Affects Every Practice, American Academy of Attorney-CPAs, June 23, 2016
•Speaker, Aetna International Customer Forum, Aetna International, November 3, 2015
•Panelist, Residence: Beyond the Basics, American Bar Association, 2015 Joint Fall CLE Meeting, September 18, 2015
•Seminar H: The Taxation of Global Families, International Fiscal Association, Basel 2015, September 2, 2015
•Navigating U.S. Tax Requirements and Strategic Methods of Coming into Compliance, Caplin & Drysdale, Chartered and Ham, Langston & Brezina LLP, U.S. Tax Requirements and Compliance Seminar, March 11, 2015
•Panelist, A Primer on Tax Treaties, American Bar Association, 2015 Midyear Meeting, January 31, 2015
•Panelist, How Many Shades of Grey? Current Ethical Issues for Tax Professionals, 66th Annual Virginia Conference on Federal Taxation, June 11, 2014
•Moderator, First Time on the Bench: Perspectives from Tax Court Judges, American Bar Association, 2014 May Meeting, May 9, 2014
•Panelist, Meeting the Ethical Challenges of Inbound Controversies, American Bar Association, 2014 May Meeting, May 9, 2014
•Panelist, Nuts & Bolts Series: International Tax Enforcement: FBARs, FATCA, and More, American Bar Association, 2014 May Meeting, May 8, 2014
•Panelist, Issue Spotting Across the Globe for Expatriate Executive Packages, American Bar Association, Joint Committee on Employee Benefits Webinar, December 17, 2013
•Speaker, Advising Clients with International Tax Issues: Form Numbers, PFIC and More, American Law Institute (ALI) CLE, Hot Topics for Accountants & Tax Lawyers: Tax Returns, Advice, & Examination, December 16, 2013
•Panelist, Leaving the U.S. - It's Very Different from Leaving Las Vegas. Tax Planning for U.S. Persons Living and Working Abroad, American Bar Association, 2013 Joint Fall CLE Meeting, September 20, 2013
•Panelist, Coping With FATCA If You're Not a Foreign Financial Institution, American Bar Association, 2013 May Meeting, May 10, 2013
•Speaker, The Ethical Framework - Duties of the Tax Practitioner to the Client and to the System, University of Virginia Tax Foundation, 64th Annual Conference on Federal Taxation, June 7, 2012
•Speaker, The Road Less Traveled: Exploring Niche Tax Practices, American Bar Association, 2012 May Meeting, May 1, 2012
•Moderator, The New Application of Transferee Liability, American Bar Association, 2011 Midyear Meeting, January 21, 2011
•Moderator, Tax Consequences of Disasters, American Bar Association, 2010 Joint Fall CLE Meeting, September 24, 2010
•Speaker, Four Actions Explained in Forty Minutes, American Bar Association, 2009 Fall Joint Meeting, September 24, 2009
•Speaker, Forever Ought to be Worth a Lot: Defending Perpetual Conservation Easements, Chamberlain Hrdlicka Law Firm, 2008 Annual Tax Forum, December 17, 2008
•Panelist, Getting the Most Out of Your Expert Witness in Tax Cases, American Bar Association, 2008 Joint Fall Meeting, September 22, 2008

Recent News

•Dianne Mehany Comments on Ireland-U.S. Deal Affecting Sponsoring-Entity Issue within FATCA Reporting, Bloomberg Law, Daily Tax Report, March 29, 2019
•WSJ Quotes Dianne Mehany on Meghan Markle and Tax Obligations of U.S. Expats Who Have Children Overseas, The Wall Street Journal, March 15, 2019
•Caplin & Drysdale Honors the Women of the Firm, Caplin & Drysdale, March 8, 2019
•10 Caplin & Drysdale Attorneys Contribute to ABA's Annual Section of Taxation Midyear Meeting, January 3, 2019
•Bloomberg Quotes Dianne Mehany on Cross-Border Tax Disputes Project, Bloomberg Law, Daily Tax Report, June 6, 2018
•Tax Notes Quotes Dianne Mehany on Risks Identified in International Compliance Assurance Program, Tax Notes, June 6, 2018
•Law360 Quotes Dianne Mehany on Concerns Countries May Use ICAP to Target Multinationals for Audit, Law360, June 4, 2018
•Dianne Mehany Speaks to Law360 on 5 Tax Considerations When Marrying a Foreign Prince, Law360, May 25, 2018
•18 Caplin & Drysdale Attorneys Recognized by Super Lawyers in D.C., April 23, 2018
•Wall Street Journal Talks to Dianne Mehany on Meghan Markle's U.S. Tax and Reporting Obligations, The Wall Street Journal, April 13, 2018

(additional coverage in Dow Jones Institutional News ; Harper's Bazaar ; and Brides )

•VIDEO: Dianne Mehany Discusses New Tax Law's Impact on U.S. Taxpayers Who Own Foreign Corporations, Bloomberg Tax, March 1, 2018
•Dianne Mehany Quoted on Application of Offshore Earnings Transition Tax, Tax Notes, February 12, 2018
•Dianne Mehany Comments on Taxing U.S. Shareholders of Foreign Corporations, Tax Notes, February 12, 2018
•MEDIA ADVISORY: Will the IRS Know What Gifts Prince Harry Gives Meghan Markle for Christmas?, Caplin & Drysdale, Chartered, November 30, 2017
•Washington Post Quotes Dianne Mehany: Meghan Markle's U.S. Citizenship Could Cause Tax Headaches for British Royal Family, The Washington Post, November 29, 2017
•Dianne Mehany Explains Tax Consequences of a Chinese National Buying Residential Property in the U.S., Mansion Global, November 23, 2017
•Dianne Mehany Comments on U.S., OECD Tax Evasion Crackdown Causing Headaches for Banks and High-Net-Worth Families with Trusts and Closely Held Businesses, Bloomberg BNA, June 8, 2017
•Caplin & Drysdale Lawyers Listed Among D.C.'s Most Prominent Practitioners, Super Lawyers, April 27, 2017
•Washington Post Quotes Dianne Mehany on Britain's Foreign Minister Boris Johnson Owing U.S. Taxes, The Washington Post, July 14, 2016
•Caplin & Drysdale Recognized for Cutting Edge Advice, The Legal 500, June 16, 2016
•CNNMoney Quotes Dianne Mehany on Rise in Expatriations and How the U.S. Government has Raised Costs, CNNMoney, February 19, 2016
•Dianne Mehany Quoted: Law Yanking, Denying Passports for Tax Delinquency Criticized, Bloomberg BNA, December 15, 2015
•Dianne Mehany Speaks with Tax Notes on U.S. Expatriation Numbers, Tax Notes, September 9, 2015
The American Lawyer Names Caplin & Drysdale Global Legal Award Recipient for Swiss Tax Investigations, The American Lawyer, July 31, 2015
•Dianne Mehany and Zhanna Ziering Talk to CNS Business: There's No Hiding from Uncle Sam, CNS Business, March 13, 2015
•CNS Business Features Dianne Mehany and Zhanna Ziering on Seminar to Help U.S. Taxpayers in Cayman, CNS Business, March 3, 2015
•Dianne Mehany Receives the ABA's Nolan Fellowship, American Bar Association, February 2, 2015
•Caplin & Drysdale Elects Three New Members, Caplin & Drysdale, February 2, 2015
•CNNMoney Quotes Dianne Mehany on Costs of Renouncing U.S. Citizenship, CNNMoney, December 10, 2014
•Law360 Quotes Dianne Mehany on Tax Tips for U.S. Expatriates, Law360, January 27, 2014
•Tax Notes Today Quotes Dianne Mehany: Facebook Expat Is Latest Billionaire Without Borders, Tax Notes Today, May 21, 2012

Areas of Practice (3)

  • Private Client
  • International Tax
  • Tax Controversies

Education & Credentials

Contact Information:
(202) 862-5068  Phone
University Attended:
Southern Arkansas University, B.A., 2001
Law School Attended:
Louisiana State University Law Center, LL.B., 2004; Louisiana State University Law Center, J.D., Chancellor's List; Senior Associate, Louisiana Law Review, 2004; Georgetown University Law Center, LL.M. in Taxation, 2006
Year of First Admission:
U.S. District Court for the Southern District of Texas; U.S. Tax Court; Not a member of the District of Columbia Bar (practicing under the direct supervision of a D.C. Bar member); California; 2007, Texas

Other Professional Affiliations

Member, American Bar Association, Section of Taxation

Member, U.S. Council for International Business

Volunteer, Christian Medical & Dental Associations


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