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Reeves Westbrook

Reeves Westbrook concentrates on the needs of large corporate taxpayers, including both counseling and tax controversies.

Reeves has provided counseling on international asset transfers and tax optimal corporate structures, acquisitions and dispositions, cross-border transfer pricing, cross-border financings, tax credit planning, foreign and domestic joint ventures and partnerships.  Reeves also counsels clients on regulatory and legislative issues and matters before the national office of the Internal Revenue Service.

Reeves's controversy experience includes audits, administrative appeals and litigation.  Reeves has handled controversies in a broad spectrum of subject matter areas, including foreign tax credits, accounting and capitalization, valuations and purchase price allocations, research and development credits and deductions, income and expense reallocations under Section 482, foreign tax credits, accounting and capitalization, valuations and purchase price allocations, research and development credits and deductions, treatment of corporate reorganizations and restructurings, computation of allowable FSC benefits, treatment of items under the consolidated return regulations, allocations under Section 861, partnership issues, allowance of losses on subsidiary stock, form over substance and Subpart F inclusions. 

Reeves is a former Co-Chair of the International Bar Association’s Taxes Committee and has chaired its Transfer Pricing and Litigation Subcommitttee.  He also served as Program Vice-chair for the 2010 IBA annual meeting in Vancouver, and recently co-chaired a panel titled, "The New Focus on Tax and Development: What Does it Mean for Multinational Business?" at the Europe/USA Tax Strategies Conference sponsored by the ABA, IBA, and IFA.

Today the United States Court of Appeals for the Sixth Circuit sided with taxpayers in affirming the decision of a district court that certain severance payments that qualify as supplemental unemployment compensation benefit payments (or “SUB” payments) for federal income tax purposes are not subject to tax under the Federal
Continue Reading Severance Pay for Layoffs Not Subject to FICA Tax, Sixth Circuit Rules