Michael Quigley leads the Firm’s Tax Controversy and Litigation Practice. For more than twenty-five years he has specialized in the resolution of tax disputes by negotiation and, when necessary, litigation before the courts.

To achieve negotiated settlements with the IRS, Mr. Quigley works with examining agents and other IRS field personnel whenever possible to resolve disputes at the earliest possible stage. When this is unavailing, Mr. Quigley appears before the IRS Office of Appeals and has successfully represented clients in a multitude of appeals conferences, fast track mediations, and post-appeals mediations. Mr. Quigley also has extensive experience using external mediators and the written determination and advice process as a means of resolving tax disputes. 

There are times when good faith negotiations do not produce a settlement and seeking judicial review is the only option. Mr. Quigley has tried more than fifty civil tax cases before the Tax Court, the Court of Federal Claims and many federal district courts. These cases include disputes over transfer pricing, civil fraud penalties, jeopardy assessments, debt/equity issues, valuations,  tax deferred exchanges, exempt organizations UBIT, excise taxes, partnerships and TEFRA procedural issues, life insurance company taxation, export incentives under the DISC/FSC regime, disallowed corporate deductions under 162(f), and many other provisions of the Internal Revenue Code. His tax litigation experience is extensive and his expertise has been recognized by his peers. He is nationally ranked in his field by Chambers & Partners, is a master of the Inns of Court, and is frequently called upon to serve as specialty tax litigation counsel. 

Mr. Quigley is also a leading authority on intercompany transfer pricing and other tax issues affecting multinational corporations. He has negotiated advance pricing agreements with the IRS and the tax authorities of many foreign jurisdictions including obtaining some of the very first APAs between the United States, Japan, and Korea more than fifteen years ago. He frequently appears before the US Competent Authority, as well as the competent authorities of many other countries including Japan, Korea, India and France, among others, and is experienced in the use of the mutual assistance provisions of tax treaties to eliminate double taxation. He also has served as lead tax controversy counsel advising clients on international tax disputes with foreign tax authorities in India, Japan, Korea, France and other jurisdictions.

Mr. Quigley has extensive experience with the operations and practices of the global operations of multinational firms and, particularly, their interaction with the US and foreign governments. He has represented clients in many business sectors and industries, including energy, pharmaceutical, airlines and aviation, broadcasting, vehicle manufacturing, consumer electronics, personal computers, semiconductors, home appliances, components manufacturing, defense, life insurance, property & casualty insurance, investment banking, and private equity.

Beginning in 1992 and for many years Mr. Quigley has studied the economic, business, and political affairs of the Republic of Korea and the Korean Peninsula, with a particular emphasis on US-Korea relations. Mr. Quigley also has a developed interest in Japan and its relations with both the United States and Korea. In 1999 he expanded his study to include US-India relations and the political and economic affairs of India including the modernization and administration of its international tax rules governing multinationals. More broadly, Mr. Quigley is keenly focused on U.S. relations with Asia.

Before entering private practice, Mr. Quigley served as a trial attorney with the Tax Division of the Department of Justice.

Mr. Quigley has spoken on transfer pricing, tax controversy, tax litigation and international tax issues before the Federal and American Bar Associations, Tax Executives Institute, the Mumbai Tax Conference and many other organizations.