Recognized since 2023
Litigation and Controversy - Tax
Pat McCann is a Shareholder in the Tax Controversy and Litigation Group in the Atlanta office of Chamberlain Hrdlicka. He focuses his practice on representing taxpayers at all stages of tax controversy including, examination, appeals, and litigation. Pat has been counsel of record for more than 225 cases filed in the United States Tax Court. He also advises clients on various tax planning and restructuring matters designed to withstand any future scrutiny from the Internal Revenue Service. Pat has advised clients on a full range of federal tax matters including federal income tax, corporate income tax, partnership tax matters, employment taxes, estate and gift tax issues, tax shelter penalties and promoter examinations under Sections 6700 and 6701.
Pat has significant experience representing small captive insurance companies that elect federal tax treatment pursuant to Section 831(b) and the small businesses that rely on them as an alternative risk management strategy. He works closely with small business owners, their professional advisors, and their captive insurance management companies throughout the litigation process.
Pat also advises his captive insurance clients on various tax planning and structuring matters designed to ensure that their captive insurance companies are as strong as possible and remain able to effectively insure against their otherwise underinsured and uninsured risks. He works with his clients, their professional advisors, and their captive insurance management companies to ensure compliance with all federal regulatory requirements including compliance with Notice 2016-66. Pat has written several articles on issues facing the captive insurance industry and the government's coordinated campaign focusing on small captive insurance companies electing federal tax treatment pursuant to Section 831(b).
Recognized in Best Lawyers: Ones to Watch® in America 2023 for work in:
- Litigation and Controversy - Tax
- Tax Law
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