Gary B. Wilcox Esq.

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Gary Wilcox is a Principal with PricewaterhouseCoopers in Washington, DC, where he co-leads a US controversy team that actively advises clients during the audit management and appeals and resolution phases of an IRS dispute.  Gary also works closely with corporate and international specialists in cross-border transactions to help clients prepare for potential controversy.  Gary’s team frequently seeks rulings and other guidance for clients from IRS and Treasury as a means of proactively avoiding tax controversies.
     Gary was recently a partner with Morgan Lewis, where he headed up the firm’s tax practice.  Prior to that, he served as Deputy Chief Counsel (Technical) in the Office of Chief Counsel of the Internal Revenue Service and, earlier, a leader of PwC’s Mergers & Acquisitions practice.
     Gary was litigation counsel to Iberdrola and ScottishPower in NAGP v. Commissioner, a 2012 Tax Court decision that upheld nearly $1 billion of taxpayer’s interest deductions on cross-border intercompany debt.  He is a frequent lecturer on corporate tax issues.  

Education:

LL.M., Taxation, New York University School of Law
J.D., University of Oklahoma, with highest honors
B.B.A., Texas Tech University, cum laude

Bloomberg BNA Tax Management Portfolios:

771 T.M., Corporate Acquisitions - (A), (B), and (C) Reorganizations (co-author)