July 9, 2020

Volume X, Number 191

Joel V. Williamson

Joel Williamson is a co-leader of Mayer Brown's Tax Controversy practice. He has litigated over 60 tax cases which have resulted in judicial opinions. He has been consistently ranked as a top tier lawyer by leading rating services such as Chambers, Legal 500 and International Tax Review. Joel was inducted into the prestigious Legal 500 Hall of Fame in March, 2017. 

Joel Williamson is widely acknowledged as one of the nation's leading tax attorneys and litigators. He has litigated over 60 tax cases. His unprecedented experience includes the trial of seven major IRC 482 transfer pricing cases, including Eli Lilly, G.D. Searle, Westreco (Nestlé), Seagate Technology, National SemiconductorUnited Parcel Service and Eaton CorporationEaton, which also involved the cancellation of two Advanced Pricing Agreements, was decided by the US Tax Court on July 26, 2017, and resulted in a rare 100% transfer pricing taxpayer victory. Recently, Joel served as trial counsel in the Guidant LLC and Eaton cases, each involving IRC 482 issues. Joel has also litigated numerous cases involving economic substance of transactions, including the United Parcel Service case noted above, as well as the Saba Partnership (Brunswick) case, and Mukerji (Comdisco), an important test case for tax-advantaged computer leasing transactions involving Comdisco. More recently, Joel litigated ConEd which involved an international Lease-In-Lease-Out transaction and Flextronics which involved an international merger and acquisition transaction. Both ConEd and Flextronics witnessed IRS arguments of economic substance and generic tax doctrines including substance over form and step transaction. Recently, Joel litigated Exelon which involved a like-exchange of utility assets that the IRS challenged on economic substance and substance over form grounds.

In the international tax area, Joel has litigated Subpart F, constructive triangular dividend, R&D Moratorium, Brazilian and other foreign tax credit for banks, including Bankers Trust and Riggs Bank, as well as Iranian loss investment in U.S. property (IRC 956) and foreign-versus-domestic-source income (IRC 863(b)) questions. He has litigated two significant captive insurance cases involving Humana, Inc. and Gulf Oil Corporation. In addition, Joel has litigated IRC 338 corporate acquisition related issues, including goodwill, intangible and inventory valuations and second-tier allocations involving Nestlé's acquisition of Carnation.

Joel litigated the Tribune Company case, which dealt with whether a divestiture of a subsidiary qualified as a tax-free corporate reorganization. He has litigated significant tax accounting issues, including unbilled revenue and cap interest rate loan questions. Joel has also litigated significant procedural questions, including the proper role of IRS trial counsel in the audit examination process. He is also experienced in summons enforcement actions for both foreign and domestic records. 

Articles in the National Law Review database by Joel V. Williamson



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