Gary Wilcox is a partner in Mayer Brown's Washington DC office and a member of the Tax Controversy and Transfer Pricing practices. Gary joined Mayer Brown in 2017, after serving as a co-leader of PricewaterhouseCoopers' (PwC) US tax controversy practice. Previously, Gary led the tax practice at another international law firm. Prior to that, he served as the deputy chief counsel of the US Internal Revenue Service (IRS), where he was in charge of approximately 700 attorneys in the Office of Chief Counsel and had primary responsibility within the IRS for developing its positions on technical tax issues and the issuance of regulations and rulings.
Gary's practice focuses on tax controversies and tax planning. Gary represents multinational corporations in the audit and appeals phases of an IRS dispute as well as in litigation. He has particular experience with controversies arising from complex transactions, typically in a cross-border context, such as leveraged distributions and other repatriations, intercompany debt, worthless stock deductions, and cost sharing arrangements. He has litigated significant cases in tax court involving intercompany debt (ScottishPower) and consolidated return (Duquesne Light) issues.
Gary has many years of experience advising clients on structuring mergers, acquisitions and internal reorganizations. He is a frequent lecturer on corporate tax issues, and is an author of the BNA Tax Management Portfolio entitled "Corporate Acquisitions- (A), (B), and (C) Reorganizations."
Gary has an LL.M. in Taxation from New York University, a JD with highest honors from the University of Oklahoma and an undergraduate degree (cum laude) from Texas Tech University.