Mark D. Allison is a Member in Caplin & Drysdale's New York office. Mr. Allison's practice involves complex federal, state, and cross-border tax controversy and litigation matters; related civil, criminal, and regulatory proceedings; and internal investigations. He represents multinational corporations, financial institutions, and global high-net-worth individuals, professional athletes and estates in proceedings before the Internal Revenue Service, the U.S. Department of Justice, the U.S. Attorneys' Office, and other government regulators, with substantial industry experience in financial services, healthcare, utilities and infrastructure.
Mr. Allison also advises and represents clients on SEC regulatory and enforcement matters and related compliance and oversight issues for investment advisers, and serves as the general counsel to a New York City-based SEC-registered fund manager.
An experienced trial attorney, Mr. Allison has litigated before the U.S. Courts of Appeals, the U.S. Tax Court, the U.S. Court of Federal Claims and in bench and jury trials in federal district court. He also advises clients in pre- and post-transaction review and analysis of potential tax disputes for purposes of ASC 740, Schedule UTP and other regulatory reporting and internal risk management, as well as planning for global high-net-worth individuals with respect to income, estate and gift tax issues.
A member of the Appointments to the Tax Court Committee, Mr. Allison plays an essential role in making recommendations on who is appointed as a judge to the Tax Court. Mr. Allison previously served as an attorney-advisor to the Honorable Julian I. Jacobs of the United States Tax Court, and as a law clerk to the Honorable Joseph C. Small of the New Jersey Tax Court.