Previously, Mr. Williams was chief counsel for the IRS. During his 18 months as chief counsel, he was responsible for all IRS litigation matters in the U.S. Tax Court, the IRS’ recommendations to the Solicitor General on IRS appeals to the U.S. Circuit Courts and the IRS’ legal positions in regulations, rulings and other guidance. Mr. Williams helped to craft and implement IRS strategies for interdicting tax avoidance transactions that the IRS regarded as abusive.
Mr. Williams also has served as a judge on the United States Tax Court, deputy assistant attorney general in the Tax Division of the Justice Department and special assistant to the chief counsel of the Internal Revenue Service.
His representations include advising Wells Fargo Bank, N.A. in a tax dispute with the IRS in connection with foreign tax credits, Entergy in connection with nuclear decommissioning costs, and private equity funds in IRS examinations and administrative appeals.
Among many notable cases, he litigated Massachusetts Mutual Life Insurance Co. v. United States, 103 Fed. Cl. 111 (2012), aff’d 782 F.3d 1354 (Fed. Cir. 2015), Rite Aid v. United States, 255 F.3d 1357 (July 6, 2001), rev’g 46 Fed. Cl. 500 (April 21, 2000) (invalidating the duplicated loss factor of Regulation § 1.1502-20 (a consolidated return regulation)) and Federal Home Loan Mortgage Corp. v. Commissioner, 121 T.C. No. 8 (filed September 4, 2003).
Mr. Williams repeatedly has been included in Chambers Global: The World’s Leading Lawyers for Business, Chambers USA: America’s Leading Lawyers for Business, The Best Lawyers in America, The Legal 500 U.S. and International Tax Review’s “Tax Controversy Leaders Guide.” He also has repeatedly been included in Washingtonian Magazine’s Top Lawyers list and in Who’s Who Legal: Corporate Tax.