Morgan Lewis today welcomes Thomas V. Linguanti, a leading federal court tax controversy trial lawyer, as a partner. Mr. Linguanti, a former trial and appellate attorney in the Tax Division of the US Department of Justice, was the leader of the North American tax practice at his previous global law firm. His arrival brings additional recognition to the firm’s already top-ranked, market-leading tax practice.
Mr. Linguanti advises individual and corporate clients worldwide in developing strategies in disputes with the US Internal Revenue Service during audits, alternative dispute resolution proceedings, and trial and appellate litigation. He has represented tax clients before numerous federal courts and the US Tax Court and was the lead lawyer in Medtronic Inc. v. Commissioner, in which the court’s ruling slashed the medical device company’s tax deficiencies from $1.36 billion to $14 million in a transfer pricing dispute involving its Puerto Rico operations. The case is on appeal to the US Court of Appeals for the Eighth Circuit, with Mr. Linguanti as lead counsel.
“Tom’s well-respected practice and aggressive advocacy on behalf of clients complements our standing as a provider of elite tax controversy and transfer pricing services,” said Firm Chair Jami McKeon. “This practice is a priority for our firm, as evidenced by our Band 1 ranking by Chambers USA and Tier 1 designation by The Legal 500 US for tax controversy. Tom’s arrival further solidifies our competitive advantage in this area.”
Mr. Linguanti speaks frequently on federal tax controversy issues and negotiation strategies. He is also a faculty member of the National Institute for Trial Advocacy, teaching advocacy skills to government, public interest, and private firm lawyers.
“Tom is widely recognized as a top tax controversy lawyer, and we are excited to have him join our team,” said Barton W.S. Bassett, leader of the firm’s tax practice. “Our clients turn to us because they have problems of significant size and complexity and need counsel with highly specialized and significant experience. Adding Tom and lawyers of his caliber to our already preeminent team adds to the deep bench that has led our clients to trust us with these important matters.”
The top-ranked global tax practice at Morgan Lewis represents clients in all stages of tax-related issues: planning, transactional-related tax work, and tax controversy and litigation matters. It includes lawyers with high-level service in the US Department of the Treasury and the US Department of Justice, and advises on international as well as US federal, state, and local tax exposures associated with pending transactions and ongoing business operations.
The firm’s Chicago office is a gateway to the US Midwest, providing regional and global clients with advice in a broad range of service areas including litigation, labor, employment, intellectual property, securities enforcement, investment management, and corporate transactions.