Photograph of David B. Blair

Government Experience

  • Department of Justice: Tax Division—Trial Attorney (1990-1995)
  • U.S. Court of Appeals for the Eleventh Circuit—Hon. Frank Minis Johnson Jr. – Clerk (1989-1990)

Education

  • Georgetown University, B.A. (1985)
  • Cornell Law School, J.D. (1989) magna cum laude, Order of the Coif

Admissions

  • District of Columbia


Tax – IRS Draft Regs: OIRA Review Offers Fresh Opportunity


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Crowell & Moring's Regulatory Forecast 2020
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Regulatory Forecast 2020

David B. Blair

Partner
Washington, D.C.
dblair@crowell.com
Phone: +1 202.624.2765
1001 Pennsylvania Avenue NW
Washington, DC 20004-2595

David B. Blair is a partner and chair of Crowell & Moring's Tax Group. Mr. Blair's practice is in the area of federal tax litigation and controversy. With over twenty years of tax litigation and trial experience, he has handled large tax litigations in the areas of transfer pricing, foreign tax credits, partnerships, tax-exempt bonds, consolidated returns, excise taxes, employment taxes, and tax accounting issues. He is also active in pro bono litigation. Where clients sought resolution short of litigation, Mr. Blair achieved outstanding results through alternative dispute resolution procedures, including the Internal Revenue Service's (IRS) Fast Track Settlement program. He also has extensive experience in handling tax controversies before IRS Exam, Appeals, National Office, and Advance Pricing and Mutual Agreement program (APMA).

A recognized authority on tax controversy, Mr. Blair taught transfer pricing as an adjunct professor at Georgetown University Law Center, and regularly speaks at tax conferences and symposia. He is the editor of The Transfer Pricing Answer Book (Practising Law Institute) and a co-author of the BNA Tax Management Portfolio No. 891-2nd, "Transfer Pricing: Audits, Appeals, and Penalties."

Mr. Blair is recognized as a leading lawyer in the tax field by Chambers USA.

Mr. Blair began his career as a trial attorney for the Tax Division of the U.S. Department of Justice, where he litigated tax issues before the United States District and Bankruptcy Courts.

Representative Engagements

  • BrokerTec Holdings Inc. v. Commissioner, T.C. No. 3573-17 (Non-shareholder contributions to capital).
  • Exxon Corp. v. Commissioner, 113 T.C. 338 (1999) (Foreign tax credit for U.K. Petroleum Revenue Tax).
  • DeNaples v. Commissioner, 674 F.3d 172 (3d Cir. 2012) (Tax exempt interest).
  • Exxon Mobil Corp. v. Commissioner, 114 T.C. 293 (2000) (Tax accounting).
  • Mary Kay Corp. v. Commissioner, T.C. Nos. 18150-02 and 14352-03 (Transfer pricing regarding marketing intangibles).
  • Danstar Ferment, Inc. v. Commissioner, T.C. No. 12288-04 (Foreign personal holding company tax).
  • Representation of Branded Pharmaceuticals Company on International Tax Issues before IRS Exam and Appeals.
  • Representations of International Oil & Gas Companies on Partnership Issues before IRS Exam and Appeals.
  • Representation of International Oil & Gas Company on Section 45Q Environmental Credits before IRS Exam and Appeals.