B. John Williams Jr., a partner in Skadden’s Tax Group, represents clients in federal tax controversy and litigation matters, from Internal Revenue Service examinations and administrative appeals through trial and appeal in the federal courts.
Previously, Mr. Williams was chief counsel for the IRS, a position to which he was appointed by President George W. Bush and confirmed by the Senate. During his 18 months as chief counsel, Mr. Williams 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 $163 million in foreign tax credits related to taxes paid to the United Kingdom in 2003 and The Bank of New York Mellon Corporation in a tax dispute with the IRS in connection with $215 million in foreign tax credits related to taxes paid in the United Kingdom in 2001 and 2002.
Among many notable cases, he litigated Rite Aid v. U.S., 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 has been selected for inclusion 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 was included in Washingtonian Magazine’s 2013 “Best Lawyers” list.