Peter A. Lowy, a nationally-recognized tax controversy practitioner, joined Chamberlain, Hrdlicka, White, Williams & Martin as a Shareholder in the firm's Houston office. Prior to joining the firm, Mr. Lowy had been practicing as a Member of Caplin & Drysdale in New York. Before joining Caplin and Drysdale in 2013, Mr. Lowy developed more than a decade of experience handling U.S. federal and state tax controversies for two of the world's largest corporations, Exxon Mobil Corporation and Royal Dutch Shell; he also served in an executive position as the Global Tax Dispute Resolution Manager for Shell, with worldwide management responsibilities for Shell's tax litigation matters. Mr. Lowy's years as a leader and in-house litigator for major corporations, give him an inside perspective on what matters most to clients.
Mr. Lowy's practice centers on advising and defending multinational corporations, foreign businesses, and U.S. taxpayers in tax controversy matters with U.S. federal and state tax authorities. He brings a broad range of experience managing and resolving complex and high-stakes tax audits, appeals, and litigation. He also provides proactive and strategic advice to avoid controversies and prepare for contentious audits; advises corporations on FIN 48, related financial accounting issues, and risk management on cross-border transactions and transfer pricing; and advises private equity firms and others with energy-related investments and tax issues.
Mr. Lowy is a well-respected authority in the tax controversy field. He is the immediate-past chair of the American Bar Association Tax Section's Committee on Court Procedure & Practice (the ABA's main civil tax litigation committee), has been an adjunct law professor at two law schools where he taught Tax Controversies, and is widely published on tax audits and litigation-related subjects.
During his career, Mr. Lowy has been responsible for over 100 tax cases; participated in over 80 successful settlements of docketed cases and administrative appeals; and when reasonable settlements were infeasible, litigated cases to decision with favorable outcomes for his clients. Disputes Mr. Lowy has participated in include seven cases with amounts in issue exceeding $100 million each, and two cases exceeding $1 billion each. His cases have cut across many types of taxes, including U.S. federal income and excise taxes, state direct taxes (e.g., income and franchise taxes), state and local indirect taxes (e.g., sales & use, motor fuels, and other specialty taxes), and state and local ad valorem taxes (e.g., property and severance taxes). Mr. Lowy's over 100 tax cases have involved a broad range of issues, including transfer pricing, debt/equity, complex structured transactions, domestic oil & gas tax issues, worthless securities, deductibility of fines, deductibility of charitable contributions, valuations, capitalization versus expense, and many others. He also served as lead attorney in structuring a multi-billion dollar, cross-border transaction.
Dedicated throughout his career to pro bono work, Mr. Lowy devotes substantial time each year to represent underprivileged taxpayers. A leader in the pro bono field, Mr. Lowy is a past chair of the ABA Tax Section's Pro Bono Committee and for years coordinated a pro bono program for the U.S. Tax Court. In 2003, his work with disadvantaged taxpayers earned him the ABA Tax Section's Pro Bono Award.
L.L.M., Taxation, New York University School of Law (1997)
J.D., Tulane Law School (1995) cum laude
B.A., Hobart and William Smith Colleges (1992) with honors
Bloomberg BNA Tax Management Portfolios:
639 T.M., Responsible Person and Lender Liability for Trust Fund Taxes — Sections 6672 and 3505 (co-author)
100 T.M., U.S. Federal Tax Research (author)
Peter Lowy is a member of the Bloomberg BNA Tax Management US Income Advisory Board.
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