Wiley Rein's Tax Practice is led by Matt E. Egger, who has more than 25 years of experience working on tax issues in private practice and with the government.  Prior to joining the firm, he was a partner in the tax group of a large, international law firm where he was responsible for handling the tax aspects of sophisticated corporate transactions.  Mr. Egger also was an attorney with the Tax Division of the U.S. Department of Justice (DOJ) where he worked in tax litigation.

Our Tax attorneys provide counseling on all types and sizes of business transactions, as well as matters related to the Employee Retirement Income Security Act (ERISA), employee benefits and executive compensation.  We also represent taxpayers in dealings with the Internal Revenue Service (IRS), from the audit level through administrative appeals and into the federal courts.  When necessary, we are prepared to advocate public policy issues before Congress, the Executive Departments, regulatory agencies and the courts.

To best meet the individual needs of our clients, we form multi-disciplinary teams that are equipped to handle a wide range of legal problems.  We work closely with the firm's other practice areas, especially Aviation, Bankruptcy & Financial Restructuring, Communications, Election Law, Employment & Labor, Public Policy and Franchise.

Transactional Tax

Wiley Rein’s Tax Practice Group works closely with the Corporate Practice Group in structuring transactions and developing tax strategies.  Our attorneys provide tax counsel at all phases of the business cycle, from start-up enterprises to mature industries, and devise strategies to minimize the incidence of tax on a variety of ongoing business operations.  We plan and execute corporate mergers and acquisitions, divestitures, restructurings, asset transfers, like-kind exchanges and debt and equity financings.  We assist clients with matters involving taxation of corporations and shareholders, partnerships and partners, limited liability companies and their members, Sub. S Corporations, cooperatives and other business entities.  Our attorneys represent debtors and other interested parties in connection with insolvency restructurings and workouts both within and outside of formal bankruptcy proceedings.  In addition, our attorneys advise individual clients on the tax aspects of their acquisition, ownership and disposition of both passive investments and active business interests. 

Representative Industries

We represent clients from a wide range of industries and have particular experience with aerospace, aviation, communications and technology companies, as well as franchisors.

• Aerospace and Aviation.  Wiley Rein Tax attorneys work with our Aviation Practice Group to provide transactional and regulatory support to owners, operators, financiers, lessors, lessees and manufacturers of aircraft assets.  We assist in the negotiation of the terms of aircraft acquisition, regulatory compliance, importation and exportation and tax planning (including tax-deferred, like-kind exchanges), and we provide regulatory and legal advice on aircraft sharing arrangements, such as time-sharing, joint ownership, interchange and fractional ownership.
• Communications.  As the most comprehensive communications practice in the country, we provide a full range of tax and transactional services to the communications industry in areas that include satellite, personal communications, cable television, cellular and local telephone and public radio and television.
• Franchises.  Our Franchise attorneys counsel clients on a wide variety of franchise issues and assist with transactional matters.  We assist franchisors who wish to buy, sell or provide equity financing to franchise companies.  We also help with strategic planning, due diligence, purchase and sale agreements, regulatory aspects and post-transaction issues.

Executive Compensation

We represent both employers and executives in negotiating and documenting the increasingly complex contractual arrangements governing the relationship of top-level executives with their companies.  Working closely with attorneys in the Employment & Labor Practice Group, we assist clients with tax aspects of fixed and incentive-based compensation, equity-based compensation, special excise taxes and deductibility limitations.  We also represent clients with issues raised by anti-discrimination and wage/hour regulations, effective severance and dispute resolution procedures and compensation requirements for tax-exempt organizations under the “intermediate sanctions” legislation.

Tax-Exempt Organizations

Tax-exempt organizations, such as public charities, issue advocacy groups, trade associations, political organizations and academic institutions, are subject to strict national, state and local tax regulations.  We help our clients navigate through their corporate and tax matters, including compliance with state registration requirements and obtaining and maintaining federal and local tax exemption.  We also counsel clients who are subject to regulation from state and local campaigns, the Federal Election Commission (FEC) and the IRS. 

Public Policy

We are actively involved in the policy debate on national and state Internet and e-commerce sales tax issues. Our attorneys are frequent lecturers and authors on the subject.

Contact Us

Matt E. Egger
202.719.7539 | megger@wileyrein.com