Associado

Jeremy D. Himmelstein

Tax, Tax Controversy & Litigation, International Tax & Transfer Pricing

Geral

Jeremy Himmelstein advises multinational corporations, partnerships, and high net-worth individuals in all stages of federal tax controversy, including trial. Jeremy has experience preparing witnesses, navigating contentious evidentiary issues, and drafting motions and post-trial briefs. He was recently part of a Mayer Brown team that represented a client in a three-week trial in the US Tax Court.

Jeremy also supports clients through IRS audits, administrative appeals, and competent authority proceedings. He has experience with transfer pricing, substance over form and related judicial doctrines, privilege disputes, income characterization and deductibility questions, and penalty issues. He is also a contributor to Best Methods, Mayer Brown’s blog on transfer pricing law and policy.

Before joining Mayer Brown, Jeremy clerked for Judge Albert G. Lauber on the US Tax Court and Judge Stuart R. Berger on the Maryland Court of Special Appeals. He uses these experiences to guide clients through complex tax and procedural issues in a variety of forums. Jeremy holds an LLM in taxation from Georgetown University Law Center, where he attended on a full merit scholarship. He received his JD, with honors, from the University of Maryland School of Law.

Experiência

Anadarko Petroleum Corp. et al. v. Commissioner of Internal Revenue, T.C. Dkt. Nos. 23018-18, 23019-18 (Ongoing case challenging the IRS’s determination that a settlement payment is not deductible)

Serviços e Indústrias Relacionadas

Serviços

Publicações e Apresentações

Publicações
Ver Todos os Conteúdos
- Artigo
  Creating Chaos: Can the IRS Revive a Dead Theory to Target Partnership Abuse
  julho 08 2024
- Artigo
  A Bug or a Feature? Foreign Tax Credits for Offset Earnings
  junho 17 2024

Reconhecimento

Formação Acadêmica

Georgetown University Law Center, LLM in Taxation with Distinction
Dean’s List, Graduate Tax Scholar
University of Maryland, BA
University of Maryland School of Law, JD, cum laude
Executive Technology Editor, Journal of Business & Technology Law

Registros

District of Columbia
Maryland

Courts

US Court of Federal Claims
US Tax Court