By Rob Starr, Content Manager, Big4.com
Gary Wilcox has joined PwC US as co-leader of the firm’s US Tax Controversy and Dispute Resolution (TCDR) practice resident in the Washington National Tax Services (WNTS) office, the firm announced yesterday.
Formerly Deputy Chief Counsel for the IRS, Mr. Wilcox helped lead the government’s development of positions on technical tax issues and the issuance of regulations and rulings. Earlier in his career he served as a leader of PwC’s Tax M&A practice in Washington, D.C. Mr. Wilcox, who most recently led the tax practice at Morgan, Lewis & Bockius LLP, was litigation counsel to Iberdrola and ScottishPower in NAGP v. Commissioner, a 2012 Tax Court decision that has received widespread attention for upholding nearly $1 billion of taxpayer’s interest deductions on cross-border intercompany debt.
PwC’s TCDR practice includes professionals located throughout the U.S. with years of experience in resolving IRS disputes, ranging from former high-level government officials to major law firm partners and in-house tax executives at large multinationals. Given the increased volume and scope of IRS enforcement efforts, the TCDR team strives to help companies minimize the disruption to business operations stemming from IRS disputes by preventing such disputes, proactively managing them when they do occur, and effectively resolving them in a manner that avoids costly and unpredictable litigation. The US TCDR team is closely integrated with PwC’s Global TCDR Network led by David Swenson, which comprises hundreds of transfer pricing and other controversy professionals located throughout the world.