Overview
Susan E. Ryba focuses her practice on federal tax controversy matters and tax litigation, particularly advising clients in the technology, healthcare and pharmaceutical sectors, as well as high-net-worth individuals.
Susan has substantial experience in all stages of federal tax controversies, including audits, administrative appeals, alternative dispute resolution proceedings and litigation. She has resolved most of her matters through the Internal Revenue Service’s Independent Office of Appeals (IRS Appeals) and other dispute resolution forums. Susan advises clients on a broad range of domestic and international tax issues, including transfer pricing, effectively connected income, Subpart F, Section 965, the IRS’s economic substance and other related doctrines, worthless stock and debt deductions, withholding tax, foreign tax credits, summons enforcement and penalties.
She is a frequent speaker at seminars sponsored by the Tax Executives Institute and also teaches trial skills for the National Institute for Trial Advocacy.
Results
- Resolved several multibillion-dollar tax controversies at the IRS Appeals for technology and pharmaceutical companies involving transfer pricing issues, including intercompany licenses of intangible property, intercompany services and platform contribution transactions*
- Obtained a full concession by the IRS examination team of a withholding tax issue for a European multinational corporation*
- Litigated the first transfer pricing case in Mauritius for a technology company*
- Resolved a $500 million worthless stock issue at the IRS Appeals for a manufacturing company*
*Matter handled prior to joining McDermott.
Recognitions
- Crain’s Chicago Business, Notable Woman in Law, 2022
- International Tax Review, World Tax, 2015 to 2023
Community
Credentials
Education
The Ohio State University Moritz College of Law, JD, magna cum laude, Order of the Coif, 2006
Cornell University, BS, magna cum laude, 2003
Courts/Agencies
US Tax Court
US District Court for the Northern District of Illinois
US Court of Appeals for the Second Circuit
