Mr. Barge’s practice is a unique blend of domestic and cross-border corporate and business tax planning and transactional expertise coupled with a robust tax controversy and litigation practice. His deep experience spans multiple industries in which he has negotiated and structured acquisitions, dispositions, expansions, contractions, restructurings, and financing transactions for corporate and pass-through entities in the United States and abroad and has resolved tax controversies at the audit, appeal and litigation stages. Mr. Barge’s transactional work focuses not only on pre-transaction design and execution but also on post-transaction integration structures that obtain maximum tax benefits and preserve favorable tax attributes while balancing non-tax issues of other stakeholders. He has prepared and received numerous private rulings from the IRS National Office and foreign taxing authorities. Mr. Barge is experienced in virtually all aspects of United States federal taxation that affect business activities and brings a practical and collaborative approach to the most sophisticated issues facing taxpayers in the United States taxing regimes.
Articles in the National Law Review database by J. Stephen Barge