A former trial attorney with the U.S. Department of Justice, Brian Harris represents clients in federal, state, and local tax controversy and litigation throughout the United States. From the IRS to state departments of revenue and municipalities, Brian advocates and defends the interests of a diverse range of clients operating in the automotive, retail, logistics, financial services, finance, and manufacturing sectors. Clients value Brian’s expansive tax knowledge across jurisdictions and his extensive courtroom experience gained from litigating over 100 cases in federal and state courts.
Brian represents clients before the IRS in audits, appeals, and litigation in U.S. Tax Court and federal district courts. He works with clients on offshore voluntary disclosures, streamlined filings, penalty waivers, private letter rulings, responses to summonses/subpoenas, and collections matters (i.e., liens, levies, offers-in-compromise). In addition, he counsels clients on international tax compliance, pre-immigration planning, expatriation consulting, income tax planning, and other federal tax matters.
Brian’s state and local tax practice includes defending audits and litigation with numerous state departments of revenue. He counsels on sales taxes, corporate income taxes, unitary business groupings, nexus, captive insurance companies, among other issues. His experience includes audits and administrative appeals through to litigation in state supreme courts.
Before joining Akerman, Brian was a trial attorney with the U.S. Department of Justice, Tax Division. He was the lead attorney for the United States and IRS in federal courts across the country and litigated several of the government’s largest and most significant tax shelter cases involving coordinated national issues, debt versus equity transactions, and the economic substance and business purpose doctrines. He also handled cases involving summons enforcement, trust fund recovery penalties, return preparer penalties and injunctions, property valuation, fraudulent transfers, and the treatment of taxes in bankruptcy.