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Experience:
Tax Controversy and litigation: Mr. Hildy has represented taxpayers in all stages of federal tax controversy, including pre-audit, audit, administrative appeals, and litigation. He is also experienced in representing taxpayers during IRS "Fast Track" proceedings and in court-supervised mediation. Mr. Hildy has also advised taxpayers in connection with competent authority negotiations, advance pricing agreements, and other tax treaty matters.
International tax and transfer pricing: Mr. Hildy's practice focuses heavily on defending and structuring transactions with significant transfer pricing implications, including cross-border transfer pricing of tangible and intangible property, shared headquarter services, and cost sharing arrangements. He has advised both US taxpayers with respect to international tax implications of off-shore operations (e.g., Subpart F manufacturing, section 936), as well as non-US taxpayers with respect to the implications of their US activities.
Tax procedure: Mr. Hildy has extensive experience defending against civil and criminal tax penalties and in addressing evidentiary privileges in the tax controversy context, including the attorney client privilege and work product protection in the modern business environment in light of IRS policies concerning tax accrual work papers and FASB Interpretation ("FIN") No. 48.
Prior to joining Mayer Brown in 1998, Mr. Hildy was with another Chicago law firm.
Notable Engagements:
United Parcel Service of America v. Commissioner of Internal Revenue, 254 F.3d 1014 (11th Cir. 2001), rev'g and remanding, T.C. Memo. 1999-268, 78 T.C.M. (CCH) 262 (1999) (vacating Tax Court's finding on sham, assignment of income and penalties).
Nestlé Holdings, Inc. v. Commissioner of Internal Revenue, T.C. Memo. 2000-374 (unagreed computation under Tax Court Rule 155; IRS held to Stipulation).
Comcast Corporation v. Commissioner of Internal Revenue, T.C. Docket No. 10983-99, decision entered March 17, 2000 (application of I.R.C. § 83 to warrants issued in public LBO).
Milwaukee Safeguard Insurance Co. et al. v. Selcke, 179 Ill.2d 94 (1997) (striking a state tax on constitutional grounds).
Education:
Northwestern University School of Law, JD, 1996 o University of Illinois, BA, finance, with distinction, 1993, Certified Public Accountant, Illinois, 1993. | 