Royce Tidwell’s practice focuses on tax controversy and litigation. He represents multinational corporations, financial institutions and individuals through the full range of federal income tax controversy proceedings, including audit, administrative appeals and judicial proceedings.
Mr. Tidwell’s substantive experience includes a wide range of complex tax issues, including financial products, transfer pricing, foreign tax credits, economic substance and business purpose, debt/equity, cross-border withholding and a variety of partnership issues.
Mr. Tidwell was named a “Tax Controversy Leader” in the International Tax Review’s 2015 Leaders Guide. He has guest lectured at the David A. Clarke School of Law’s (UDC’s) Low-Income Taxpayer Clinic on U.S. Tax Court practice and procedure. Additionally, he has represented pro bono clients referred by UDC before the IRS. Mr. Tidwell’s representative cases include:
- Eaton Corp. v. Commissioner, Tax Court Dkt. No. 5576-12 (IRS cancellation of an Advance Pricing Agreement; transfer pricing; Section 367(d));
- Santander Holdings USA, Inc. v. United States, — F. Supp. 2d — 2013 WL 5651414 (D. Mass. 2013); (foreign tax credits, economic substance challenge); and
- Salem Financial, Inc. v. United States (BB&T), 112 Fed. Cl. 543 (2013) (foreign tax credits, economic substance challenge).
His representative cases prior to joining Skadden include the following:
- Chemtech v. United States, ___ F.3d ___ (M. Dist. La. Feb. 26, 2013) (partnership economic substance, debt/equity);
- Imprimis Investors v. United States, 83 Fed. Cl. 46 (2008) (TEFRA, inconsistent positions with respect to partnership allocations).
- J.D., Georgetown University Law Center, 2007 (cum laude; Articles Editor, Georgetown Law Journal)
- B.S., Southern Methodist University, 2004
- District of Columbia
- U.S. Court of Federal Claims
- U.S. Court of Appeals for the Federal, Fifth and Ninth Circuits
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