Christopher P. Murphy
Chris Murphy’s practice focuses on tax controversy and litigation. He represents multinational corporations and financial institutions through the full range of federal income tax controversy proceedings, including audit, administrative appeals, and trial and appellate judicial proceedings.

Bio

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;
  • 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; and
  • 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); and
  • TIFD III-E INC. v. United States, (partnership economic substance, debt/equity).

Mr. Murphy was named in the International Tax Review’s 2017 Tax Controversy Leaders Guide.

Credentials

Education

  • J.D., American University Washington College of Law, 2006
  • M.A., American University, 2009
  • B.A., Boston College, 2001

Admissions

  • California
  • New York
  • District of Columbia
  • U.S. District Court for the District of Columbia
  • U.S. Courts of Appeal for the Federal and District of Columbia Circuits
  • U.S. Court of Federal Claims
  • U.S. Tax Court

Christopher P. Murphy

Counsel, Tax Controversy and Litigation
christopher.murphy@skadden.com