Edward L. Froelich - McDermott Will & Emery


Edward L. Froelich represents domestic and foreign public corporations, privately held companies, partnerships, trusts and individuals across the spectrum of federal tax controversies, including audits, trials and appeals. Ed’s clients include businesses, business owners and investors with operations and interests in the financial services, technology, real estate, healthcare and other industries.

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  • Persuaded the IRS to withdraw a Notice of Proposed Adjustment asserting section 482 adjustments in excess of $200M against a large tech company and accept the taxpayer’s valuation*
  • Successfully resolved an audit involving a $4B worthless stock deduction*
  • Won key discovery motion in $150M US Court of Federal Claims tax refund action which led to a mediated settlement and substantial refund*
  • Persuaded the IRS Appeals Office to concede a $300M proposed 482 adjustment against a major media company*
  • Persuaded IRS Exam management to drop novel assessment of the section 6672 trust fund penalty against individuals who managed an entity which invested in the delinquent taxpayer*
  • Persuaded IRS Collections to drop a $10M penalty for delinquent Form 3520 foreign trust filings*

*Matter handled prior to joining McDermott


  • The Legal 500 US, US Taxes: Contentious, Rising Star 2022
  • Chambers USA, Tax: Controversy in the USA, Nationwide (Band 4) 2020


  • American College of Tax Counsel, Fellow


Georgetown University Law Center, LLM, 1999
University of Virginia School of Law, JD, 1994
Catholic University of America, MA, 1991
Thomas Aquinas College, BA, 1988

District of Columbia

Courts / Agencies
US Court of Federal Claims