Sócio
Co-leader of Tax
Thomas Kittle-Kamp
Tax Controversy & Litigation, International Tax & Transfer Pricing, Tax Transactions & Planning
“He has a great command of the courtroom and an incredible understanding of tax law.”
“He is outstanding at executing strategy in a way the whole trial team can get behind and the judge can understand.”
Geral
Tom Kittle-Kamp represents corporate clients in high-dollar tax controversies involving novel federal income tax issues.
Tom has litigated and tried cases involving a wide array of tax issues, including transfer pricing, a core competence of Mayer Brown; international tax, including subpart F; transactions governed by subchapter C and subchapter K; issues involving the development, exploitation, and transfer of intellectual property and intangible assets; and tax common law doctrines, such as substance over form and economic substance.
Experiência
- Anadarko Corp. and Kerr-McGee Corp. v. Commissioner of Internal Revenue, T.C. Docket Nos. 23018-18, 23019-18 (deductibility of settlement payment) (tried May 2022) (decision pending).
- Tribune Media Company v. Commissioner of Internal Revenue, T.C. Memo. 2021-22 (sustaining use of leveraged partnership).
- Hyatt Hotels Corp. v. Commissioner of Internal Revenue, T.C. Memo. 2023-122 (tax consequences of customer loyalty program).
- Altera Corporation v. Commissioner of Internal Revenue, 145 T.C. No. 3 (2015) (in 15-0 reviewed Tax Court opinion, holding invalid section 482 regulations requiring cost-sharing participants to share amounts attributable to stock-based compensation), rev'd, 926 F.3d 1061 (9th Cir. 2019) (2-1 vote), reh'g denied, 941 F.3d 1200 (9th Cir. 2019) (three judges dissenting from denial of rehearing).
Reconhecimento
- "Thomas is an outstanding tax lawyer. He is very knowledgeable and forward-thinking." – Chambers USA
- "Thomas is an excellent dispute lawyer." – Chambers USA
- "He is an impressive trial lawyer with unique communication skills." – Chambers USA
- "Extremely confident and persuasive in the courtroom and a pleasure to work with." – Chambers USA
- "He is a great lawyer - very smart, very thoughtful and he has the respect of the government." – Chambers USA
- "Has extensive experience, a lot of common sense and the ability to deal with whatever's thrown at him." – Chambers USA
- "Extremely smart and well prepared," "very meticulous in his preparation" and a "very thoughtful practitioner who works well with clients." – Chambers USA
- "A very rare combination—a subtle courtroom advocate and a real tax expert," as well as "clever, very likeable, unassuming but very impressive in court." – Legal 500
- Named to Legal 500’s list of Hall of Fame lawyers for US Taxes: Contentious
Formação Acadêmica
- Northwestern University School of Law, JD, cum laude
Associate Editor, Law Review; Order of the Coif
- Bradley University, BA, summa cum laude
Registros
- Illinois
Courts
- US Tax Court
- US Court of Federal Claims
- US District Court for the Northern District of Illinois
- US Court of Appeals for the Seventh Circuit
- US Court of Appeals for the Ninth Circuit
- US Court of Appeals for the Tenth Circuit
- US Court of Appeals for the Eleventh Circuit
Atividades
- Board of Trustees, Court Theatre, University of Chicago
- Law Board, Northwestern University Pritzker School of Law
- Co-author of Federal Income Taxation of Intellectual Properties and Intangible Assets (Thomson Reuters WG&L Tax Series 1997), updated twice a year