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David B. Blair

Partner

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

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 thirty 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

"LB&I Update: Emerging from the COVID-19 Pandemic," Crowell & Moring's Managing Tax Audits and Appeals Seminar 2021 (October 7, 2021). Speakers: Nikole C. Flax, David B. Blair, and Carina C. Federico.
Speech/Presentation
"Update from the IRS Office of Chief Counsel," Crowell & Moring's Managing Tax Audits and Appeals Seminar 2021 (October 7, 2021). Speakers: Drita Tonuzi and David B. Blair.
Speech/Presentation
"Audits: Selection, Examination, and Resolution," Crowell & Moring's Managing Tax Audits and Appeals Seminar 2021 (October 4, 2021). Speakers: David B. Blair and Carina C. Federico.
Speech/Presentation
Crowell Deepens Compensation And Benefits Capabilities With New Tax Partner The National Law Journal (August 31, 2021)
Media Mentions
"IRS Releases Guidance Regarding Section 45Q Carbon Capture and Sequestration Tax Credit," Tax Alert (July 6, 2021). Contacts: David B. Blair, David J. Fischer, Carina C. Federico, Eric Homsi
Client Alert / Newsletter
Chambers USA 2021 Ranks 63 Crowell & Moring Lawyers and 30 Practice Areas Among Best in U.S. (May.20.2021)
Firm News / Announcement
"Advance Pricing Arrangement in China: An Effective Tax Planning Tool for Multinational Companies," Tax Alert (May 10, 2021). Contacts: David B. Blair, David J. Fischer, Jackson C. Pai, Ye Zhou, Ph.D.
Client Alert / Newsletter
Investors Primed To Act On Carbon Tax Credit Guidance Law360 (March 17, 2021)
Media Mentions
"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

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Crowell & Moring LLP is an international law firm with offices in the United States, Europe, MENA, and Asia that represents clients in litigation and arbitration, regulatory and policy, and transactional and corporate matters. The firm is internationally recognized for its representation of Fortune 500 companies in high-stakes litigation and government-facing matters, as well as its ongoing commitment to pro bono service and diversity, equity, and inclusion.

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