Christopher W. Campbell
1999 Avenue of the Stars, 7th Floor
Los Angeles, CA, 90067
Phone: +1-310-246-8459
Fax: +1-310-246-6779
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Bob Eccles
1625 Eye Street, NW
Washington, DC, 20006
Phone: +1-202-383-5363
Fax: +1-202-383-5414
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Robert Rizzi
1625 Eye Street, NW
Washington, DC, 20006
Phone: +1-202-383-5322
Fax: +1-202-383-5414
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Gary Tell
1625 Eye Street, NW
Washington, DC, 20006
Phone: +1-202-383-5315
Fax: +1-202-383-5414
PROFESSIONALS
- Related Practices
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Tax Controversy
In today’s corporate governance and tax compliance environment, it is imperative that upper management have a precise understanding of complicated tax rules and how they are applied to business transactions. The response to the recent wave of corporate accounting scandals and abusive corporate tax shelters has increased management’s compliance burdens (e.g., Sarbanes-Oxley, Circular 230, FIN 48), while federal and state tax auditors have become especially aggressive in scrutinizing corporate transactions and return positions. Early involvement of experienced tax litigation counsel with access to specialists is a prudent step to minimize risk, develop the issues under examination, prevent unintended waiver of privilege, and determine the best strategy for resolution. O’Melveny's tax lawyers are recognized as authoritative advocates for our clients. Informed by decades of experience in private and government practice, O’Melveny lawyers handle complex federal and state audit issues and guide clients through administrative appeals and litigation when necessary. Our effectiveness in the tax controversy field is enhanced by our tax litigators’ collaboration with expert tax specialists and experienced business litigators. Ranked among the top law firms for complex and bet-the-company litigation, O’Melveny’s approach to tax controversy provides a strong advantage that the IRS, Department of Justice, and other taxing authorities do not have.
Key Facts
- Tax partners Bob Eccles, Gary Tell, and Robert Blashek were recognized in Chambers USA: America’s Leading Lawyers for Business (2008).
- O’Melveny includes in its ranks partners who were previously trial lawyers with the US Department of Justice’s Tax Division and the US Department of Labor.
- Several O’Melveny tax lawyers were selected for inclusion in The Best Lawyers in America, widely regarded as the preeminent referral guide to the legal profession in the United States.
- Among O’Melveny’s tax lawyers are university professors and respected panelists, nationally sought after for tax advice. They have spoken at events sponsored by the American Bar Association, Practising Law Institute, USC Tax Institute, New York City Bar, Edison Electric Institute, Tax Executives Institute, Thomson LegalWorks, Investment Management Consults Association, and Professional Liability Underwriting Society.
Practice Strengths
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Bankruptcy Tax Litigation
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Our tax lawyers provide full-service tax support to the Firm’s top-tier bankruptcy and restructuring practice. In addition to providing structuring advice, we handle mixed tax-bankruptcy issues such as determining the priority of tax claims, and settling—or, when appropriate, objecting to and litigating—tax claims filed by various taxing authorities.
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Coalitions of major corporations
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O’Melveny is experienced with the representation of coalitions on industry-wide issues.
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ERISA Litigation
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Our lawyers have represented clients in numerous precedent-setting suits under ERISA’s fiduciary duties provisions.
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Issues of First Impression
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Our tax litigation practice frequently involves novel or unprecedented issues that affect an entire industry and are of national concern.
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State Tax Audits and Litigation
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Clients seek our counsel for their most difficult state and local tax matters, such as defending the make-up of their unitary group, appealing and litigating deficiency determination following sales and use tax or income tax audits, and challenging taxes on constitutional grounds, e.g., discriminatory taxes or assertion of tax without nexus.
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US Supreme Court Proficiency
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Because of our renowned appellate practice, clients frequently turn to us as advocates to take cutting-edge federal and state tax and ERISA matters to the US Supreme Court. For example, in 2007 we were asked to draft petitions for writ of certiorari in two cases presenting the issue of whether the US Constitution’s Commerce Clause permits a state to tax the income of an out-of-state corporation that has no in-state physical presence, when the only connection (or “nexus”) with the state is the presence of income-producing intangible property or customers.
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Leading California Developer
International Equities Broker
Top US Health Insurer
Fortune 500 Energy Company
Fortune 500 Media Company
Large Mortgage Finance Company
Educational Services Group
International Restaurateur
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