Dwight Mersereau is a Tax Group partner in Crowell & Moring's Washington, D.C. office. Dwight represents large, multinational corporate clients in high-stakes policy, planning, and controversy matters. These projects typically involve complex, highly technical tax accounting issues involving billions of dollars. Dwight is involved in shaping tax policy through legislation, U.S. Department of the Treasury regulation projects, revenue rulings, and private letter rulings. He has represented individual clients, industry associations, and client coalitions before Congress, the Treasury, and the Internal Revenue Service (IRS). Over the years, Dwight has fostered close working relationships with officials at the IRS and Treasury. He is often consulted by policy makers grappling with difficult tax accounting issues.
Dwight also represents clients involved in controversy with the IRS at all levels of the proceedings, including during examination, at appeals, and in litigation before the U.S. Tax Court. He achieves impressive results for his clients because of his depth of understanding of complex tax accounting issues gained through his more than 20 years of experience in dealing with all aspects of the law, which he first obtained in drafting tax accounting guidance while serving in the Office of Chief Counsel.
Recent cases have involved leading manufacturers, financial institutions, retailers, and construction companies, and included issues involving accounting for credit card fees; original issue discount; accounting for research and development expenses; capitalization and amortization of intangibles; last-in, first-out (LIFO) inventory accounting; income deferral; uniform capitalization costs of inventory and self-constructed assets; the “production deduction” under Section 199 of the Internal Revenue Code; the percentage-of-completion method; and depreciation. Dwight is adept at using various settlement tools, including Fast Track settlement, Industry Issue Resolution (IIR), and alternative timing settlements.
Dwight began his career as an appellate and trial lawyer in the Office of the Judge Advocate General in the United States Navy. In addition to briefing dozens of cases, he has orally argued 10 cases before the U.S. Court of Appeals for the Armed Forces and the Navy-Marine Corps Court of Military Review. Dwight rose to head trial counsel at the Charleston Naval Base and was the lead prosecutor in more than 50 felony cases.
While in the IRS Office of Chief Counsel, in the Office of the Associate Chief Counsel (Income Tax & Accounting), the chief counsel awarded Dwight the Technical Guidance Award for his publication of comprehensive guidance for accounting method changes.
Dwight is a frequent writer and lecturer on tax accounting issues. From 2003 to 2005, he was an adjunct professor of law at the Georgetown University Law Center, where he taught Income Tax Accounting in the Masters of Law Program.
Affiliations
Admitted to practice: District of Columbia, New Mexico (inactive), U.S. Court of Claims, U.S. Tax Court, Supreme Court of New Mexico
Highlights, News & Knowledge
Speeches & Presentations
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"Ethics for Tax Professionals," Tax Executives Institute (TEI), Northeast Chapter Meeting, Needham, MA
(April 7, 2017).
Presenters: Jeremy Abrams, Teresa Abney and Dwight N. Mersereau.
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"Section 199 Regulations," TEI's 71st Annual Conference, Philadelphia, PA
(October 18, 2016).
Speaker: Dwight N. Mersereau.
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"Recent Developments in Tax Accounting," Crowell & Moring’s Managing Tax Audits and Appeals Seminar 2016, Washington, D.C.
(September 30, 2016).
Presenter: Dwight N. Mersereau.
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"Managing & Resolving R&D & 199 Issues," TEI 2016 Audits & Appeals Seminar – East, Boston, MA
(June 14, 2016).
Presenter: Dwight N. Mersereau.
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"Recent Developments in Tax Accounting," Crowell & Moring's Managing Tax Audits and Appeals Seminar 2015, San Francisco, CA
(October 8, 2015).
Presenter: Dwight N. Mersereau.
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"Recent Developments in Tax Accounting," Crowell & Moring's Managing Tax Audits and Appeals Seminar 2015, Washington, D.C.
(October 2, 2015).
Presenter: Dwight N. Mersereau.
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"Tax Accounting Periods and Methods,” Tax Executive Institute Region II Annual Tax Forum, Atlantic City, NJ
(June 16, 2015).
Presenter: Dwight N. Mersereau.
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"Tax Accounting Issues,” Tax Executive Institute San Francisco Chapter, San Francisco, CA
(May 20, 2015).
Presenter: Dwight N. Mersereau.
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"Federal/Multi-State Tax – All Day Session," Tax Executives Institute, Detroit Chapter, Troy, MI
(December 9, 2014).
Presenter: Dwight N. Mersereau.
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"Tax Accounting Issues: Basis, Methods, Periods, Hot Topics," Tax Executive Institute San Francisco Chapter, San Francisco, CA
(October 3, 2014).
Presenter: Dwight N. Mersereau.
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"The Much Anticipated Final Repair Regulations and Best Practices for Controversy with the IRS," Lorman Webinar
Presenter: Dwight N. Mersereau.
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"IRS Repair and Maintenance Regulation Update," Webinar
(November 20, 2013).
Presenter: Dwight N. Mersereau.
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"IRS Repair and Maintenance Regulation Update," Webinar
(November 6, 2013).
Presenter: Dwight N. Mersereau.
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"IRS Repair and Maintenance Regulations," Elk Grover, IL
(August 28, 2013).
Presenter: Dwight N. Mersereau.
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"IRS Repair and Maintenance Regulation Update," Webinar
(May 22, 2013).
Presenter: Dwight N. Mersereau.
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Tax Executive Institute Philadelphia Chapter Meeting, Philadelphia, PA
(April 25, 2013).
Presenter: Dwight N. Mersereau.
Publications
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"New IRS Regulations Affect Brewers," The New Brewer
(July – August 2014).
Author: Dwight N. Mersereau.
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"IRS Addresses Whether Publisher Is 'Producer' Under §199," Bloomberg BNA
(April 2013).
Author: Dwight N. Mersereau.
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"The New Repair Regulations - Some Things to Consider," The Tax Executive
(March - April 2012).
Author: Dwight N. Mersereau.
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"Navigating the Accounting Method Change Landscape - The New §381 Regulations and Other Developments," Tax Management Memorandum
(December 19, 2011).
Author: Dwight N. Mersereau.
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"IRS Audits of Gift Card Sales: Practical Tips and Strategies," Tax Management Memorandum
(December 21, 2009).
Author: Dwight N. Mersereau.
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"Changing Times: IRS Updates 'Automatic' Method Change Program," The Tax Executive
(January – February 2009).
Author: Dwight N. Mersereau.
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"The IRS Takes Aim at Gift Card Sales," Tax Notes
(September 10, 2007).
Author: Dwight N. Mersereau.
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"Chief Counsel Revamps Case-Specific Advice Procedures to Match LMSB's New Enforcement Paradigms," The Tax Executive
(July - August 2006).
Author: Dwight N. Mersereau.
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"So Much for Simplification - IRS Discourages Taxpayers From Using the IPIC Pooling Method," Journal of Taxation
(March 2006).
Author: Dwight N. Mersereau.
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"IRS Further Expands Capitalization Requirement for Environmental Cleanup Costs," BNA Daily Report for Executives
(November 2005).
Author: Dwight N. Mersereau.
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"Whatever, Whenever: Treasury Further Expands Capitalization Requirement of Environmental Cleanup," Tax Management Weekly Report
(October 17, 2005).
Author: Dwight N. Mersereau.
Client Alerts & Newsletters
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