Nick focuses on corporate and tax law. His experience includes work on a variety of tax matters, including federal tax litigation, tax disputes with the Internal Revenue Service at the examination and appeals levels, and international tax issues involving tax treaties, transfer pricing, and cross-border investments and business operations.
Prior to joining Williams Parker, Nick was an associate with an Am Law 100 firm in Washington, D.C. for five years. Before that, he clerked for the Honorable C. Christopher Hagy and the Honorable Justin S. Anand at the United States District Court for the Northern District of Georgia.
His representative matters include:
- Private developer’s counsel in relocation, public-private real estate co-development, and financing for Atlanta Braves spring training stadium and surrounding mixed use development.
- Represented development team in $200 million joint venture with global private equity firm for acquisition of multi-state residential real estate development community portfolio.
- Advised a major U.S. energy company with respect to 10 consecutive years of IRS audit and appeals cycles; obtained favorable settlements on issues including like-kind exchanges of refinery equipment, abandonment losses from shuttered refinery facilities, classification and quantification of refinery “line fill,” research credits, international restructuring transactions, and accuracy-related penalties; and drafted refund claims with respect to erroneous income inclusions arising from federal tax credits under Sections 6426 and 6427 for blending gas and alcohol fuel mixtures and biodiesel mixtures.
- Advised a U.S. private equity fund regarding tax audits, litigation, and international arbitration involving the application of tax treaties to cross-border investments, including issues concerning permanent establishments, residence and entitlement to treaty benefits of tax-exempt entities, the application of treaty benefits with respect to pass-through entities, and beneficial ownership of capital gains and dividends.
- Represented a property and casualty insurance company in IRS audit, fast track mediation, and Court of Federal Claims refund litigation concerning the application of Section 847 and refunds arising from unutilized “special estimated tax payments.”
- Represented U.S. subsidiaries of foreign manufacturing and consumer goods companies regarding Advance Pricing Agreements and competent authority Mutual Agreement Procedures, including cross-border buy-sell distribution arrangements and IP licensing arrangements.
- Advised an e-commerce business regarding IRS audits involving transfer pricing and information reporting issues and obtained favorable private letter ruling regarding the application of Section 6050W information reporting requirements to an e-commerce business model.
- Successfully obtained relief for a global market and listing company under Treas. Reg. §§ 1.6038B-1 and 1.367(a)-8 with respect to potential gain recognition from incomplete gain recognition agreements and subsequent filings necessitated by international restructuring transactions.
- Advised the U.S. subsidiary of a foreign steel company with respect to withholding taxes and penalties on interest payments paid to the foreign parent, including Section 6672 Trust Fund Recovery Penalties.
- Advised an electronics company and assisted in obtaining a pre-filing agreement confirming the deductibility of approximately $90 million of state-law antitrust settlement payments, notwithstanding Section 162(f) and (g).