Mark D. Allison

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. In this context, he represents clients in various proceedings before the Internal Revenue Service, the U.S. Department of Justice, the U.S. Attorneys' Office, and other government regulators. 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. From 2018 through 2020, Mr. Allison was appointed by the US District Court for the Southern District of New York as lead counsel for all defendants in the nationwide multidistrict litigation brought by the Danish tax authorities (SKAT) against approximately 200 US pension plans and related parties relating to claims for dividend tax withholding.

Mr. Allison uses his tax controversy background to uniquely advise clients in a range of transactional and planning settings, including mergers, acquisitions and divestitures; private equity, hedge fund and real estate investments; bankruptcy and other restructurings; transfer pricing; and estate and gift tax issues. His work also involves 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 the tax treatment and implications of non-tax litigation and investigations.

Mr. Allison currently serves as the Group General Counsel of a Middle-East based family office and previously served as general counsel to a New York City-based SEC-registered fund manager.

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.

Bar & Court Admissions

• New York
• District of Columbia
• U.S. Court of Federal Claims
• U.S. Tax Court
• U.S. Court of Appeals, Second Circuit
• U.S. District Court, Southern District of New York
• U.S. District Court, Eastern District of New York

Education

LL.M., New York University School of Law, 1996

J.D., American University Washington College of Law, 1995, summa cum laude, Arthur Bakalar Award, Note & Comment Editor, American University Journal of International Law & Policy

M.A., American University, 1992

B.A., Claremont McKenna College, 1990

Honors & Recognitions

• Chambers USA, 2021
• The Legal 500, Recommended, 2012-2023
• Super Lawyers, New York, 2013-Present

Professional Activities

• Member, Planning Committee, New York University 9th Annual Tax Controversy Forum
• Member,  Appointments to the Tax Court Committee, American Bar Association, Taxation Section, 2015-present
• Former Chair, Court Procedure & Practice Committee, American Bar Association, Tax Section, 2013-2015; (previously Vice-Chair, 2011-2013; Chair for the Tax Court, 2007-2011; Appellate Practice, 2005-2007; Current Developments, 2004-2005)
• Adjunct Professor, New York University School of Law, 2009-present
• Instructor, Tax Law VITA Training, West Point Military Academy, 2016-present
• Articles Editor, The Tax Lawyer, 2011-present
• Fellow, American College of Tax Counsel, 2012-present
• Board of Advisors, Low Income Taxpayer Clinic, Legal Aid Society, 2007-2011
• Member, New York State Bar Association, Tax Section
• Board of Advisors, Duke Law School Low Income Taxpayer Clinic, 2006-2008
• Former Associate Justice, B'nai B'rith International Supreme Court, 2003-2004