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David B. Blair

Partner

dblair@crowell.com
Phone: +1 202.624.2765
1001 Pennsylvania Avenue NW
Washington, DC 20004-2595

David B. Blair is a partner and chair of Crowell & Moring's Tax Group. Mr. Blair's practice is in the area of federal tax litigation and controversy. With over twenty years of tax litigation and trial experience, he has handled large tax litigations in the areas of transfer pricing, foreign tax credits, partnerships, tax-exempt bonds, consolidated returns, excise taxes, employment taxes, and tax accounting issues. He is also active in pro bono litigation. Where clients sought resolution short of litigation, Mr. Blair achieved outstanding results through alternative dispute resolution procedures, including the Internal Revenue Service's (IRS) Fast Track Settlement program. He also has extensive experience in handling tax controversies before IRS Exam, Appeals, National Office, and Advance Pricing and Mutual Agreement program (APMA).

A recognized authority on tax controversy, Mr. Blair taught transfer pricing as an adjunct professor at Georgetown University Law Center, and regularly speaks at tax conferences and symposia. He is the editor of The Transfer Pricing Answer Book (Practising Law Institute) and a co-author of the BNA Tax Management Portfolio No. 891-2nd, "Transfer Pricing: Audits, Appeals, and Penalties."

Mr. Blair is recognized as a leading lawyer in the tax field by Chambers USA.

Mr. Blair began his career as a trial attorney for the Tax Division of the U.S. Department of Justice, where he litigated tax issues before the United States District and Bankruptcy Courts.

Representative Engagements

  • BrokerTec Holdings Inc. v. Commissioner, T.C. No. 3573-17 (Non-shareholder contributions to capital).
  • Exxon Corp. v. Commissioner, 113 T.C. 338 (1999) (Foreign tax credit for U.K. Petroleum Revenue Tax).
  • DeNaples v. Commissioner, 674 F.3d 172 (3d Cir. 2012) (Tax exempt interest).
  • Exxon Mobil Corp. v. Commissioner, 114 T.C. 293 (2000) (Tax accounting).
  • Mary Kay Corp. v. Commissioner, T.C. Nos. 18150-02 and 14352-03 (Transfer pricing regarding marketing intangibles).
  • Danstar Ferment, Inc. v. Commissioner, T.C. No. 12288-04 (Foreign personal holding company tax).
  • Representation of Branded Pharmaceuticals Company on International Tax Issues before IRS Exam and Appeals.
  • Representations of International Oil & Gas Companies on Partnership Issues before IRS Exam and Appeals.
  • Representation of International Oil & Gas Company on Section 45Q Environmental Credits before IRS Exam and Appeals.

Education

  • Georgetown University, B.A. (1985)
  • Cornell Law School, J.D. (1989) magna cum laude, Order of the Coif

Affiliations

Admitted to practice: District of Columbia and Massachusetts (inactive)

Court admissions:

  • United States Tax Court
  • United States Court of Federal Claims
  • United States Court of Appeals for the Second Circuit
  • United States Court of Appeals for the Third Circuit
  • United States Court of Appeals for the Eleventh Circuit
  • United States District Court for the Northern District of Texas

Memberships

  • Vice-Chair, Inter-Pacific Bar Association's Tax Committee (2015-2017)
  • J. Edgar Murdock Inn of Court for U.S. Tax Court (1999-2017)

View More

"Now Is The Time For Carbon Capture Projects," Bloomberg Tax Management Memorandum (March 1, 2021). Authors: David B. Blair, Larry F. Eisenstat, Carina C. Federico, and Tyler A. O'Connor.
Publication
4 Takeaways From The Final IRS Carbon Capture Rules Law360 (January 21, 2021)
Media Mentions
"Transition 2021: Shining a Light on Midnight Rules and the Biden Regulatory Agenda," Biden First 100 Days Series (January 13, 2021). Contacts: Byron R. Brown, David B. Blair, S. Starling Marshall, Daniel W. Wolff
Client Alert / Newsletter
"Treasury and the IRS Release Final Regulations Regarding Section 45Q Carbon Capture and Sequestration Tax Credit," Tax Alert (January 8, 2021). Contacts: David B. Blair, David J. Fischer, Carina C. Federico
Client Alert / Newsletter
"Congress Extends Section 45Q Beginning of Construction Date by Two Years in COVID-Relief Bill," Tax Alert (December 29, 2020). Contacts: David B. Blair, David J. Fischer, Carina C. Federico
Client Alert / Newsletter
"Climate 2021: Preparing for the Legal, Regulatory, Policy and Shareholder Challenges Ahead," Crowell & Moring and Crowell & Moring International Webinar (December 9, 2020). Moderator: Ambassador Robert Holleyman; Panelists: David B. Blair, Thomas A. Lorenzen, Amanda Shafer Berman, Himamauli Das, and Joshua Boswell.
Speech/Presentation
"Deputy Commissioner (LB&I) Flax Discuss Revised Procedures and Priorities During COVID-19 Pandemic," Tax Alert (November 4, 2020). Contacts: David B. Blair, Carina C. Federico
Client Alert / Newsletter
"Climate Change Will Be Front and Center in 2021, Regardless of the Nov. 3 Results," Environment & Natural Resources Law Alert (November 2, 2020). Contacts: Robert Holleyman, Himamauli Das, David B. Blair, Thomas A. Lorenzen, Amanda Shafer Berman, Tyler A. O'Connor
Client Alert / Newsletter
"Partnership Audit Developments," Crowell & Moring's Managing Tax Audits and Appeals Seminar 2020 (October 8, 2020). Presenters: David B. Blair and Teresa Abney.
Speech/Presentation
IRS Open To Placing More FAQs In The Internal Revenue Bulletin Tax Notes (October 7, 2020)
Media Mentions

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Crowell & Moring LLP is an international law firm with approximately 550 lawyers representing clients in litigation and arbitration, regulatory and policy, and transactional matters. The firm is internationally recognized for its representation of Fortune 500 companies in high-stakes litigation, as well as its ongoing commitment to pro bono service and diversity, equity and inclusion. The firm has offices in Brussels, Doha, London, Los Angeles, New York, Orange County, San Francisco, Shanghai, and Washington, D.C.

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