Dianne MehanyMember at Caplin & Drysdale
Ms. Mehany's practice focuses on international tax planning and controversies, including inbound and outbound tax planning, foreign tax credits, tax treaties, tax audits, and FATCA planning and compliance. She also has experience in tax compliance of individuals, companies and financial institutions in the cross-border context, including FATCA reporting, reporting of interests in foreign trusts, and offshore financial accounts and assets.
Ms. Mehany's practice also encompasses income and succession planning for wealthy individuals and families, including pre-immigration planning and expatriations, and foreign trusts.
In addition to advising clients in these areas, Ms. Mehany has extensive experience advising individual and corporate clients in federal civil and criminal tax controversy matters. She guides clients through all stages of IRS disputes, including preparing protests of IRS actions, representing clients at appeals conferences, filing petitions in the Tax Court and complaints in District Court, and assisting with trial matters and settlement discussions. Moreover, Ms. Mehany has counseled individual clients and financial institutions on the U.S. government's investigation of undisclosed foreign assets, particularly with respect to the classification of foundation and trust structures.
- Served on the trial team, who achieved a multi-million dollar victory in the Tax Court regarding the deductibility of a termination fee.
- Achieved a summary judgment on research credit for privately-held company.
- Successfully obtained private letter rulings granting Section 9100 relief for changes in accounting method, retroactive applications of registration, and retroactive elections.
- Served on the trial team for Avenell v. Commissioner, T.C. Memo 2012-32, which successfully defended the taxpayer against allegations of fraud by the IRS.
- Member, Wex S. Malone American Inn of Court (one of ten from the graduating class invited for membership due to outstanding performance in LSU Trial Advocacy Program).
- Represented pro bono matters through the Houston Bar Association from 2006-2010.
Awards & Rankings
- Super Lawyers, Rising Star, Washington, D.C., 2017-2018
- The Legal 500, Recommended, 2016
- The American Lawyer's Global Legal Award, Global Dispute of the Year: Investigations, Swiss Tax Settlements, 2015
- Nolan Fellowship, American Bar Association, Section of Taxation, 2015-2016