John P. Warner
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John P. Warner

Shareholder

Washington, DC
 
 
 

John P. Warner focuses his practice on international and corporate tax matters and the taxation of financial instruments and securitization transactions. He has advised foreign-based individuals and businesses with respect to U.S. investments and activities and U.S.-based individuals and businesses with respect to foreign investments and activities. John is co-chair of the Business & International Tax Practice Group and former co-office head of the firm’s Washington, D.C. office.

John has been selected for inclusion in The Best Lawyers in America® list from 2015-2018. In 2017, he was also recognized on the 2017 Washington, D.C. Super Lawyers list.

He has more than 30 years of experience in domestic and international federal income tax and business planning, including the structuring of business formations, joint ventures and mergers and other domestic and cross-border business acquisitions and dispositions. He has advised a wide variety of U.S. citizens living abroad and foreign residents with U.S. activities and investments. He has helped to structure numerous foreign acquisitions, operations and investments by U.S. businesses and investors and to structure numerous U.S. acquisitions, operations and investments by foreign businesses and investors. John has experience in structuring various financial products, and providing issuers and investors advice as to the tax consequences of these products. He has represented many clients in obtaining Internal Revenue Service National Office rulings and in tax controversy matters, including IRS Appeals Office cases, competent authority proceedings, the resolution of transfer pricing disputes and voluntary disclosure of offshore financial accounts, assets and associated income.

His recent experience has extended to alternative energy tax credit and finance arrangements and federal excise tax refund claims under the Export Clause of the constitution, and other excise tax disputes. He has litigated disputes in the United States Tax Court and the United States Claims Court, including Oak Industries, Inc. v. Commissioner, 96 T.C. 559 (1991), and Libbey v. Commissioner, 55 T.C.M. (CCH) 1052 (1988), and wrote an influential amicus brief in Indianapolis Power & Light Co. v. Commissioner, 493 U.S. 203 (1990).

John is co-editor of the Tax Management International Journal and is the deputy technical editor of and a contributing author to the Tax Management Transfer Pricing Portfolio Series. He is a past chair of the Transfer Pricing Committee of the American Bar Association Section of Taxation and a frequent author and speaker in the United States and Europe on domestic and international tax issues. He is the author of many articles, including “Income, Estate, Gift and Wealth Tax Consequences to Inbound Employees,” 36 Tax Mgmt. Intl. Forum No. 2 (2015); “Income and Indirect Tax Consequences of Inbound Cloud Computing Transactions,” 35 Tax Mgmt. Intl. Forum No. 4 (2014); “Transfer Pricing Audits,” 30 Tax Mgmt. Intl. Forum No. 4 (2009); "Outbound Redomestications and Reverse Mergers," 29 Tax Mgmt. Intl. Forum No. 2 (2008); "Centralization of Regional Management and Shared Services," 27 Tax Mgmt. Intl. Forum No. 1 (2006); "Income Tax Consequences of Taxable Reorganization Transactions," 52 N.Y.U. Inst. on Federal Taxation chapter 20 (1994); "Too Much Ado About Something - The Proposed Regulations Governing Controlled Services Transactions," 33 Tax Mgmt. Intl. J. 67 (2004); "Squaring the Transfer Pricing Circle," 33 Tax Mgmt. Intl. J. 3 (2004); and "Control, Causality and Section 482," 28 Tax Mgmt. Intl. J. 403 (1999). His professional training includes completion of the course "Mediation for the Professional" presented by the Center for Dispute Resolution.