Overview

Elizabeth Erickson provides legal counsel on complex civil tax controversies, including tax litigation and transfer pricing matters. She has extensive experience in resolving domestic and international tax matters at all stages of dispute, including Internal Revenue Service examinations, administrative appeals, and litigation in the US Tax Court and district courts. She has advocated for clients before the Internal Revenue Service National Office, negotiated Advance Pricing Agreements with the Internal Revenue Service and other tax authorities, and resolved disputes through the Competent Authority process.

Elizabeth also advises clients on tax planning matters, including captive insurance arrangements and the tax treatment of settlement payments and legal fees (including tax reporting requirements).

Elizabeth is the hiring partner for the Washington, DC office, and is a former co-chair of the Firm’s Pro Bono and Community Service Committee for the Washington, DC office. She speaks frequently on tax controversy matters for professional organizations and is an editor of the Firm’s
Tax Controversy 360 blog.

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Results

ITOCHU International Inc. v. American Tire Distributors, Inc., No. 14-cv-4347 (S.D.N.Y. filed Jun. 17, 2014)
Securitas Holdings, Inc. v. Commissioner, T.C. Memo. 2014-225 (Oct. 29, 2014)
Goodrich Corp. v. United States, 2012 US Dist. LEXIS 5301 (W.D. N.C. Jan. 18, 2012) and Goodrich Corp. v. Commissioner, No. 29180-09 (Tax Ct. filed Dec. 8, 2009)

United Services Automobile Association (“USAA”) v. United States, No. 10-cv-00185 (W.D. Tex. filed Mar. 5, 2010) and USAA v. Commissioner, No. 021037-10 (Tax Ct. filed Sept. 21, 2010)
Capital One Fin. Corp. v. Commissioner, 659 F.3d 316 (4th Cir. 2011), aff’g 130 T.C. 147 (2008) and 133 T.C. 136 (2009)

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Recognitions

The Legal 500 2014, Tax Controversy, Rising Star
World Transfer Pricing 2018, International Tax Review – recommended
Tax Controversy Leader, International Tax Review 2017
Women in Tax Leader, International Tax Review 2017

Credentials

Education
Georgetown University Law Center, JD, cum laude, 2000
Florida State University, MAcc, 1997
Florida State University, BS, magna cum laude, 1996

Admissions
District of Columbia

Courts / Agencies
US Tax Court