David Berke

Mr. Berke advises on tax issues arising in cross-border and domestic contexts, including in internal integration and restructuring transactions. He frequently counsels clients on a variety of international tax issues, including subpart F, tax treaties, transfer pricing, and foreign tax credits. He advises clients in connection with various corporate transactions, including mergers and acquisitions, liq-uidations and distressed situations, and financing transactions.

Mr. Berke also assists clients with tax controversies and dispute resolution in connection with IRS audits, refund claims and ad-ministrative proceedings, and litigation. He has advised numerous high-stakes, precedent-setting tax cases.

He previously worked as a special counsel in the IRS Office of Associate Chief Counsel (International) (ACCI), where he drafted guidance (including regulations and sub-regulatory guidance) and advised on complex and high-profile controversy matters.

Mr. Berke is a frequent speaker on domestic and international tax topics at various bar association events and conferences. Prior to his time at ACCI, Mr. Berke worked as an associate at Skadden.