Michael Coravos

Michael Coravos has extensive tax controversy and litigation experience having spent nearly 15 years working for the Internal Revenue Service (IRS), Office of Chief Counsel. As a trial attorney, Michael led and oversaw the development of several high-profile tax controversy cases involving significant international tax issues, including transfer pricing, subpart F income, and penalties. Michael has litigated numerous cases before the United States Tax Court, managed all aspects of litigation from case inception through post-trial briefing, and orally argued significant motions and briefs.

In addition to his trial work, Michael regularly advised the Large Business & International Division (LB&I) and the Independent Office of Appeals on a variety of international and domestic tax controversies related to federal income tax audits of large corporations and partnerships, including inbound and outbound reorganizations, transfer pricing, section 956 investments in U.S. property, subpart F income, withholding tax, total return swaps and security loans, tax treaties, effectively connected income, section 41 research tax credits, and hybrid financial instruments, among other matters. During his time at the IRS, Michael also provided technical advice to the Department of Justice (DOJ) on tax controversies in bankruptcy court, district court, and federal courts of appeal. Michael was twice decorated for his service with national awards for outstanding litigation.

Now in private practice, Michael helps clients avoid litigation by effectively navigating the IRS examination process, strategically building relationships with government stakeholders, and successfully defending return positions.