Fred T. Goldberg, Jr.
Fred Goldberg is co-head of the firm’s Tax Group and global co-chair of the firm’s Diversity Committee. Mr. Goldberg first joined Skadden in 1986, following two years as chief counsel of the Internal Revenue Service. From 1989 until 1992, Mr. Goldberg served as commissioner of the IRS, and during 1992 he served as assistant secretary of the Treasury for Tax Policy. He returned to Skadden in December 1992.
Working with his Tax Department colleagues in Skadden’s Washington, New York, Chicago, Los Angeles and overseas offices, Mr. Goldberg’s practice during the past several years has focused on advising clients as special tax counsel on sensitive matters, and representing clients on tax controversies and IRS administrative and regulatory proceedings. Mr. Goldberg also has advised many REITs, including timber and other non-traditional asset REITs, in obtaining private letter rulings from the IRS and handling REIT controversy matters.
Mr. Goldberg advises clients as special counsel on a wide range of complex transactional and compliance matters. In addition to advice regarding novel tax administration issues, he has directed compliance and management reviews on behalf of senior executives and boards of directors of various companies. On a selective basis, Mr. Goldberg counsels clients on legislative matters. Mr. Goldberg has represented clients and groups of companies on issues of industry-wide significance in administrative proceedings before the IRS and the U.S. Department of Treasury, including on behalf of companies in the following industries: airline, automotive, banking, consumer products, health care, heavy manufacturing, insurance, investment, pharmaceutical, professional services, telecommunications and utilities.
Mr. Goldberg represents business, tax-exempt and individual clients during all phases of civil audit, administrative appeals and litigation. In recent years, a primary focus of Mr. Goldberg’s practice has been working with clients on innovative and high stakes dispute resolution efforts in disputes with the IRS. Among the controversy matters he has worked on are tax accounting issues, transfer pricing, IRS challenges to R&E and energy tax credit claims, placed in service issues, IRS challenges to various capital market transactions, the status of tax-exempt bonds, the examination of tax-exempt organizations, the tax treatment of corporate distributions and reorganizations, the valuation of going concerns, international restructuring transactions, the tax treatment of insurance contracts, and compliance with information reporting and withholding rules.
Resident in Skadden’s Washington office, Mr. Goldberg was a member of the National Commission on Restructuring the IRS, a member of the Center for Strategic and International Studies National Commission on Retirement Policy and executive director of the Bi-Partisan Congressional Commission on Entitlement and Tax Reform.
Mr. Goldberg repeatedly has been selected for inclusion in Chambers Global: The World’s Leading Lawyers for Business, Chambers USA: America’s Leading Lawyers for Business and The Best Lawyers in America.
- Board Member, Children’s National Medical Center; Chair of the Legal Affairs and Audit Committee
- Board Member, Doorways to Dreams
- Board Member, DC Appleseed Center for Law and Social Justice
J.D., Yale University, 1973
B.A., Yale University, 1969
Assistant Secretary for Tax Policy, Department of the Treasury (1992)
Commissioner, Internal Revenue Service (1989-1992)
Chief Counsel, Internal Revenue Service (1984-1986)
Co-Author, “Reforming Social Security: A Practical and Workable System of Personal Retirement Accounts,” Administrative Aspects of Investment-Based Social Security Reform, 9-40 (with Professor Michael Graetz) (J. Shoven, ed.) (NBER 2000)
Author, “Filling the Void: Can the IRS Restructuring Bring Purpose and Meaning to the Random World of Tax Litigation?,” March 1999 TAXES Magazine