Gregg D. Lemein advises clients on US federal income taxation, and has handled numerous tax cases, particularly those related to intercompany pricing issues. In addition to his practice, Mr. Lemein frequently speaks at tax seminars and has authored numerous articles on international tax issues.
Practice Focus
Mr. Lemein focuses on international tax planning and controversies involving multijurisdictional tax issues. He has extensive experience in the development of intercompany pricing policies and international reorganizations. He also helps clients resolve tax controversies at the audit and appeals levels of the IRS, through bilateral advance pricing agreements and competent authority procedures, as well as in US Tax Court and other federal courts.
Representative Legal Matters
- Eli Lilly and Company v. Commissioner, 84 T.C. 996 (1985), aff'd in part, rev'd in part, and rem'd, 856 F.2d 855 (7th Cir. 1988) (intercompany pricing issues).
- Coulter Electronics, Inc. v. Commissioner, 59 T.C.M. 350 (1990), aff'd without opinion, 943 F.2d 1318 (11th Cir. 1991) (transfer of lease receiv¬ables to bank as pledges or sales; deductibility of warranty expenses of Canadian subsidiary).
- Square D Company v. Commissioner, 109 T.C. 200 (1997) (deductibility of VEBA contributions).
- Laidlaw Transportation, Inc. v. Commissioner, 75 T.C.M. 2598 (1998) (deductibility of interest paid to related Dutch finance company and other issues).
- Square D Company v. Commissioner, 118 T.C. 299 (2002), aff'd, 438 F.3d 739 (7th Cir. 2006) (timing of deductions for interest payable to foreign parent).
- Square D Company v. Commissioner, 121 T.C. No. 11 (2003) (deductibility of executive retention payments, loan commitment fees and legal fees).
- Jefferson Smurfit Corporation (U.S.) v. United States, 95 AFTR 2d 2005-2322 (E.D. Mo. 2005), rev'd, 439 F.3d 448 (8th Cir. 2006) (finality of Tax Court decision).
Admission
U.S. Court of Appeals, Third Circuit~United States (1996)
U.S. Court of Appeals, Seventh Circuit~United States (1986)
U.S. Court of Appeals, Federal Circuit~United States (1982)
U.S. Tax Court~United States (1979)
U.S. Court of Federal Claims~United States (1978)
U.S. District Court, Northern District of Illinois~United States (1977)
Illinois~United States (1976)
Education
Kellogg Graduate School of Management, Northwestern University
(M.M. Distinction)
(1976)
Northwestern University School of Law
(J.D. magna cum laude)
(1976)
University of Illinois
(B.S. High Honors)
(1972)
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