Gregg D. Lemein

Gregg Lemein advises clients on US federal income taxation, and has handled numerous tax cases, particularly those related to intercompany pricing issues. In addition to his practice, Mr. Lemein has authored numerous articles on international tax issues.

Mr. Lemein focuses on international tax planning and controversies involving multijurisdictional tax issues. He has extensive experience in the development of intercompany pricing policies.

He also helps clients resolve tax controversies at the audit and appeals levels of the IRS, through bilateral advance pricing agreements and competent authority procedures, as well as in US Tax Court and other federal courts.

Education:

• Kellogg Graduate School of Management, Northwestern University (M.M. Distinction) (1976)
• Northwestern University School of Law (J.D. magna cum laude) (1976)
• University of Illinois (B.S. High Honors) (1972)

Admissions:

• U.S. Court of Appeals, Third Circuit~United States (1996)
• U.S. Court of Appeals, Seventh Circuit~United States (1986)
• U.S. Court of Appeals, Federal Circuit~United States (1982)
• U.S. Tax Court~United States (1979)

Representative Legal Matters:

• Eli Lilly and Company v. Commissioner, 84 T.C. 996 (1985), aff’d in part, rev’d in part, and rem’d, 856 F.2d 855 (7th Cir. 1988) (intercompany pricing issues).
• Coulter Electronics, Inc. v. Commissioner, 59 T.C.M. 350 (1990), aff’d without opinion, 943 F.2d 1318 (11th Cir. 1991) (transfer of lease receiv¬ables to bank as pledges or sales; deductibility of warranty expenses of Canadian subsidiary).
• Laidlaw Transportation, Inc. v. Commissioner, 75 T.C.M. 2598 (1998) (deductibility of interest paid to related Dutch finance company and other issues).
• Square D Company v. Commissioner, 118 T.C. 299 (2002), aff’d, 438 F.3d 739 (7th Cir. 2006) (timing of deductions for interest payable to foreign parent).