Christopher P. Murphy

Mr. Murphy's substantive experience includes a wide range of complex tax issues, including economic substance and business purpose, foreign tax credits, debt/equity, transfer pricing and a variety of partnership issues.

Mr. Murphy also has represented various pro bono clients in tax and non-tax matters, including securing disability benefits for a pro bono client in a Social Security appeal.

His representative cases while at Skadden include the following:

• Amazon.com, Inc. v. Commissioner (U.S. Tax Court). In 2017, victory in the U.S. Tax Court involving one of the largest transfer pricing cases in decades and the first involving e-commerce
• Athene USA Corp. v. United States (U.S. District Court, Southern District of Iowa). Settlement reached in refund case involving the IRS’ disallowance of a change in method of accounting related to Athene’s treatment of the cost of options purchased to hedge its fixed-indexed annuity products
• Eaton Corporation v. Commissioner (U.S. Tax Court). In 2017, victory in the first case involving a court’s review of an IRS decision to retroactively cancel an advance pricing agreement that had settled taxpayer’s transfer pricing dispute
• Santander Holdings USA, Inc. v. United States (U.S. District Court, Massachusetts; U.S. Court of Appeals for the First Circuit). Case involving the IRS’s disallowance of foreign tax credits in context of a cross-border financing. In 2016, the U.S. Court of Appeals for the First Circuit overturned an earlier $234 million victory by Santander in the U.S. District Court for the District of Massachusetts
• Mylan v. Commissioner (U.S. Tax Court). In 2017, settlement reached with the IRS in a sale versus license dispute

His representative cases prior to joining Skadden include the following:

• Salem Financial, Inc. v. United States (BB&T), (foreign tax credits, economic substance challenge)
• Chemtech v. United States, (partnership economic substance, debt/equity)
• United States v. G-I Holdings Inc., (partnership, economic substance, debt/equity, disguised sale, statute of limitations)
• TIFD III-E INC. v. United States, (partnership economic substance, debt/equity)

Mr. Murphy has been recognized in The Legal 500 U.S. and as a leading tax attorney in International Tax Review’s Tax Controversy Leaders and World Tax guides.