William A. Schmalzl focuses on tax litigation, corporate tax planning and state tax advice. He represents clients in all stages of tax litigation including audits, administrative proceedings, United States Tax Court, federal district court and courts of appeals and Illinois state courts.
The issues he has litigated include I.R.C. § 482, the investment tax credit, research tax credit, sale-leasebacks, foreign tax credits, franchises, patents and other intangibles.
William’s undergraduate majors in economics and mathematics have proven invaluable in the preparation of expert reports and in the examination of expert witnesses at trial. William’s trial experience includes Seagate Technology, National Semiconductor, United Parcels Service, RJR Nabisco, ConEd and Flextronics.
Prior to joining Mayer Brown, William served as a Clerk to the Honorable Robert A. Ainsworth, Jr., of the 5th Circuit Court of Appeals (1977-1978).
Mayer Brown was recently named Tax Controversy Team of the Year for the second consecutive year in the Legal 500 United States Awards. “Mayer Brown is ‘among the best’ and fields a large team…dedicated exclusively to tax controversy and transfer pricing,” said Legal 500 and its sources in the US edition. The firm is “regularly seen in the most high-profile controversy cases before the US Tax Court” and produced “yet another impressive run of work” in 2014.
- University of Pittsburgh, BA, summa cum laude
- Harvard Law School, JD, magna cum laude
- US Tax Court
- US Supreme Court
- US Court of Federal Claims
- US District Court for the Northern District of Illinois
- American Bar Association, (Section on Taxation)
- Chicago Bar Association, (Federal Tax Committee, State & Local Tax Committee)
- Consolidated Edison Co. of N.Y., Inc. & Subsidiaries v. United States, 2013 WL 93110 (Fed. Cir. Jan. 9, 2013), rev’g 90 Fed. Cl. 228 (2009) (recharacterizing lease-in lease-out (“LILO”) transaction under substance over form doctrine).
- Wells Fargo & Company v. United States, Docket No. 06-628-T, 105 A.F.T.R.2d 2010-377 (Ct. Fed. Cl., Jan. 8, 2010), (denying deductions for leveraged leases of transit equipment and technical equipment).
- Represented a client in a matter involving a Lease-in-lease-out (LILO) transaction involving Dutch power facility (Consolidated Edison Company of New York, Inc. & Subsidiaries v. The United States, 90 Fed. Cl. 228 (2009).
- Represented a client in a matter involving the deductibility of package design costs and the characterization of income from foreign expropriation under I.R.C. § 1231 (RJR Nabisco, Inc. v. Commissioner of Internal Revenue, 76 T.C.M. (CCH) 71 (1998)).
- Represented a client in a matter involving a debt-equity swap, asbestos removal expense, and lease portfolio valuation (Norwest Corporation and Subsidiaries v. Commissioner of Internal Revenue, 108 T.C. 358 (1997)).
- Represented a client in a matter involving the allocation of income between foreign parent corporation and U.S. subsidiary (Westreco, Inc. (Nestlé) v. Commissioner of Internal Revenue, 64 T.C.M. (CCH) 849 (1992)).
- Represented a client in a matter involving the calculation of the amount in receipt of preferred stock for property (Nestlé Holdings, Inc. v. Commissioner of Internal Revenue, 94 T.C. 803 (1990)).
- Represented a client in a matter involving the capitalization of publishing costs (Encyclopaedia Britannica, Inc. v. Commissioner of Internal Revenue, 685 F.2d 212 (7th Cir. 1982)).
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