Overview

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 consists of tax counseling and litigation for U.S. and foreign multinational corporations.

Tax controversy practice includes 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 includes 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 includes extensive experience with respect to all aspects of intercompany transfer pricing compliance, including documentation strategies, foreign tax credit planning and FIN 48 analysis.

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Thought Leadership

Speaking Engagements

Frequent speaker at seminars and conferences regarding international taxation and tax litigation.

Memberships & Affiliations

Director, International Tax Forum

Member of the Tax Advisory Group for the American Law Institute Project Regarding International Aspects of United States Income Taxation.

Credentials

Admissions & Qualifications

  • 1967, Missouri (inactive)
  • 1973, Illinois

Education

  • Washington University in St. Louis, School of LawJ.D.1967
  • New York UniversityLL.M.1972
  • Washington University in St. LouisB.A.1964