Partner, Kirkland & Ellis
LLP, 1978–2006
Chief Tax Officer, General
Motors Corporation, May 2006–September 2009.
Responsibility for management of General Motors' worldwide direct and
indirect taxes.
Private practice at Kirkland
& Ellis consisted of tax counseling and litigation for U.S. and foreign
multinational corporations.
Tax controversy practice
included extensive experience in international tax matters including
face-to-face negotiations for clients with foreign tax authorities (including
competent authorities) of Canada, Mexico, United Kingdom, Belgium, The
Netherlands, Germany, Japan and Australia. Extensive experience representing clients in
the U.S. before the IRS Appeals Office, District Counsel and National Office.
Litigation experience included cases in the Tax Court, Courts of Appeal and the Supreme Court. Lead trial counsel in a number of litigated
cases, including (i) General Motors Corporation v. Commissioner, 112
T.C. No. 19 (1999), (ii) CF Industries Inc. v. Commissioner, 68 T.C.M.
2397 (1994), 995 F.2d 101 (7th Cir. 1993) affirming
62 T.C.M. 1249 (1991) and (iii) Keystone Consolidated Industries, Inc. v.
Commissioner, 113 S.Ct. 2006 (1993) reversing
951 F.2d 76 (5th Cir. 1992), affirming
60 T.C.M. 1423 (1990).
Tax counseling private practice
included extensive experience with respect to all aspects of intercompany
transfer pricing compliance, including documentation strategies, foreign tax
credit planning and FIN 48 analysis.
