Vivek A. Patel

Vivek’s practice focuses on the resolution of Federal income tax controversies and disputes with the IRS and other taxing authorities. Vivek advises clients throughout all administrative phases of a controversy, including audit, administrative appeals, and alternative dispute resolution proceedings. He has also helped clients successfully resolve cases before the United States Tax Court, United States Courts of Appeals, and other courts throughout the country, as well as in various non-U.S. jurisdictions. Vivek also advises clients on compliance with partnership tax audit and dispute strategies under both TEFRA and the Bipartisan Budget Act, as well as on procedural and substantive challenges to regulations and other administrative guidance.

Vivek also handles corporate tax planning related to domestic and international transactions, including transfer pricing considerations and supply chain ramifications. He assists clients with the implementation of global tax structures and strategies.

Drafted court opinions, orders, and correspondence regarding Federal income, estate, and gift taxes; assisted in trial preparation of IRS deficiency and collections hearings; and analyzed substantive tax issues and procedural strategies to adjudicate proceedings and dispose parties’ motions.

Counseled tax-exempt and non-profit organizations on activities and operations; prepared IRS Form 1023 and corporate documents for various tax-exempt organizations; provided emergency advice regarding payroll tax issues and Federal tax filing obligations to local tax-exempt organizations; prepared presentations and created client letters on maintaining tax-exempt status and matters of corporate governance; advised Board of Directors and Executive Officers of the Pro Bono Partnership of Atlanta regarding strategic planning, client outreach, and fundraising possibilities; and performed additional duties as Intern Assistant and volunteer from January 2007 to August 2011.

Drafted tax opinions, IRS protest letters, and client correspondence on matters of corporate and partnership taxation, including international tax ramifications of discharge of indebtedness income and qualification for renewable energy tax credits and bond programs; represented multi-national corporations before federal courts, including litigation on tax treatment of telecommunications support payments; proposed tax structures for complex corporate transactions, including Section 368(a)(1)(A) reorganizations in connection with initial public offerings; analyzed information reporting requirements and advised clients on tax compliance obligations, including IRS OVDP initiative and FATCA implementation; lectured at various conferences on the tax treatment of series limited liability companies and on real estate income tax issues.