MichaelCoravos

Michael Coravos has nearly 15 years of experience working for the Internal Revenue Service (IRS), Office of Chief Counsel. As a trial attorney, Michael led and oversaw the development of several high-profile cases involving significant international tax issues, including transfer pricing, subpart F income, and penalties. Michael has litigated numerous cases before the United States Tax Court, managed all aspects of litigation from case inception through post-trial briefing, and orally argued significant motions and briefs.

In addition to his trial work, Michael regularly advised the Large Business & International Division (LB&I) and the Independent Office of Appeals on a variety of international and domestic tax matters related to federal income tax audits of large corporations and partnerships, including inbound and outbound reorganizations, transfer pricing, section 956 investments in U.S. property, subpart F income, withholding tax, total return swaps and security loans, tax treaties, effectively connected income, section 41 research tax credits, and hybrid financial instruments, among other matters. During his time at the IRS, Michael also provided technical advice to the Department of Justice (DOJ) on tax matters in bankruptcy court, district court, and federal courts of appeal. Michael was twice decorated for his service with national awards for outstanding litigation.