Dianne C. Mehany is an associate in Caplin & Drysdale's Washington, D.C. office. She joined the firm in 2010.
ServicesMs. Mehany's practice focuses on international tax planning and controversies, including inbound and outbound tax planning, foreign tax credits, tax treaties, tax audits, and FATCA compliance. She also has experience in tax compliance of individuals, companies and financial institutions in the cross-border context, including FATCA reporting, reporting of interests in foreign trusts, and offshore financial accounts and assets.
Ms. Mehany's practice also encompasses income and succession planning for wealthy individuals and families, including pre-immigration planning and expatriations, and foreign trusts.
In addition to advising clients in these areas, Ms. Mehany has extensive experience advising individual and corporate clients in federal civil and criminal tax controversy matters. She guides clients through all stages of IRS disputes, including preparing protests of IRS actions, representing clients at appeals conferences, filing petitions in the Tax Court and complaints in District Court, and assisting with trial matters and settlement discussions.
- Served on the trial team, who achieved a multi-million dollar victory in the Tax Court regarding the deductibility of a termination fee
- Achieved a summary judgment on research credit for private company
- Successfully obtained private letter rulings granting Section 9100 relief for changes in accounting method, retroactive applications of registration, and retroactive elections
- Served on the trial team for Avenell v. Commissioner, T.C. Memo 2012-32, which successfully defended the taxpayer against allegations of fraud by the IRS
Ms. Mehany speaks before many professional associations and conferences. Her recent engagements include:
- Speaker, Coping with FATCA if You're Not a Foreign Financial Institution, ABA Section of Taxation 2013 May Meeting
- Speaker, The Ethical Framework - Duties of the Tax Practitioner to the Client and to the System, University of Virginia School of Law 2012 Annual Conference of Federal Taxation
- Speaker, The Road Less Traveled: Exploring Niche Tax Practices, ABA Section of Taxation 2012 May Meeting
- Speaker, The New Application of Transferee Liability, ABA Section of Taxation 2011 Winter Meeting
- Speaker, Tax Consequences of Disasters, ABA Section of Taxation 2010 Fall Joint Meeting
- Speaker, Four Actions Explained in Forty Minutes, ABA Section of Taxation 2009 Fall Joint Meeting
- Speaker, Forever Ought to be Worth a Lot: Defending Perpetual Conservation Easements, Chamberlain Hrdlicka 2008 Annual Tax Forum
- Speaker, Getting the Most Out of Your Expert Witness in Tax Cases, ABA Section of Taxation 2008 Fall Meeting
Ms. Mehany also represented pro bono matters through the Houston Bar Association from 2006-2010.
Awards & Honors
- Member, Wex S. Malone American Inn of Court (one of ten from the graduating class invited for membership due to outstanding performance in LSU Trial Advocacy Program)
- Facebook Expat Is Latest Billionaire Without Borders, Tax Analysts, Volume 95, Number 96 (May 17, 2012)
- Comments to the Proposed Amendments to the Rules of the United States Tax Court, ABA Tax Section (May 27, 2009)