Michael has experience handling a variety of complex tax issues, including partnership audit procedures under the Tax Equity and Fiscal Responsibility Act of 1982 (TEFRA) and the Bipartisan Budget Act of 2015 (BBA), international tax and Report of Foreign Bank and Financial Accounts (FBAR) compliance, reportable transactions, transfer pricing, debt equity classifications, foreign tax credits and excise tax on reinsurers. He also advises on questions relating to the attorney-client and work product privileges arising in tax matters.

After law school, Michael served as a term law clerk for the Honorable Karen L. Hayes of the US District Court for the Western District of Louisiana. He also served as a judicial intern for the Honorable Dolores K. Sloviter of the US Court of Appeals for the Third Circuit during law school. And, while earning his LLM in Tax from NYU, he served as a legal extern for the Internal Revenue Service’s (IRS) Office of Chief Counsel and Large Business and International Division in New York.

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• Advised a Fortune 100 multinational corporation in restructuring its global tax department to optimize compliance with domestic and global reporting requirements and maintain confidentiality for sensitive, privileged materials*
• Advised a multinational pharmaceutical company regarding its captive insurance program*
• Successfully represented taxpayers before the IRS relating to the examination of Employee Retention Credits*
• Obtained full concession from the IRS in a US Tax Court matter affirming a taxpayer’s position that $50 million in proceeds from litigation funding was properly characterized as long-term capital gain*
• Successfully negotiated the resolution of a New York sales tax examination on behalf of a multinational company, its subsidiary and its executives as purported responsible persons*
• Obtained favorable resolution for a taxpayer regarding a criminal tax investigation into New York City’s unincorporated business tax*
• Successfully quashed a series of summonses served on US financial institutions pursuant to the United States-Russia tax treaty and at the request of the Russian Federation*
• Was part of a trial counsel team in a Tax Court case involving a large multinational hedge fund advisory firm that was to determine whether the fund was “engaged in a US trade or business” and was effectively generating connected income as result of its investment activities and whether the fund was subject to withholding under IRC Section 1446*
• Represented a large estate in a complex Tax Court case involving the valuation of an estate comprised of original works of art and the calculation of the appropriate blockage discount*
• Represented employers in worker classification issues and for participation in the IRS Voluntary Classification Settlement Program*

*Matter handled prior to joining McDermott.

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