Gary Wilcox is a partner in Mayer Brown’s Washington DC office and a member of the Tax Controversy and Transfer Pricing practices. Gary recently joined Mayer Brown, after serving as a co-leader of PricewaterhouseCoopers’ (PwC) US tax controversy practice. Previously, Gary led the tax practice at another international law firm. Prior to that, he served as the deputy chief counsel of the US Internal Revenue Service (IRS), where he was in charge of approximately 700 attorneys in the Office of Chief Counsel and had primary responsibility within the IRS for developing its positions on technical tax issues and the issuance of regulations and rulings.
Gary’s practice focuses on tax and transfer pricing planning, and tax controversies.
Tax controversies. Gary represents multinational corporations in the audit and appeals phases of an IRS dispute as well as in litigation. He has particular experience with controversies arising from complex transactions, typically in a cross-border context, such as leveraged distributions and other repatriations, intercompany debt, worthless stock deductions, and cost sharing arrangements. He has litigated significant cases in tax court involving intercompany debt (ScottishPower) and consolidated return (Duquesne Light) issues.
Tax planning. Gary has many years of experience advising clients on structuring mergers, acquisitions and internal reorganizations. He is a frequent lecturer on corporate tax issues, and is an author of the BNA Tax Management Portfolio entitled “Corporate Acquisitions- (A), (B), and (C) Reorganizations." Today, he uses this controversy and planning experience to advise clients at the transaction planning stage on how best to prepare for a potential future IRS audit. His advice is aimed having an audit ready defense file, addressing the “soft doctrines” such as substance-over-form and step transaction, and identifying privileged documents.
Gary has been repeatedly recognized by the International Who’s Who of Corporate Tax Lawyers and the International Tax Review Tax Controversy Leaders Guide. Gary is a council director of the American Bar Association’s Tax Section and a fellow of the American College of Tax Counsel.
