David B. Blair

David Blair counsels large corporations and partnerships facing contentious IRS audits, appeals, and litigation. With over three decades of experience handling tax controversies for clients in a broad range of industries, David has a deep understanding of the procedural and substantive nuances of the tax laws.

He has handled large cases involving IRS challenges to tax credits, partnership transactions, Section 199 deductions, mineral production payments, transfer pricing, foreign tax credits, tax-exempt bonds, consolidated returns, excise taxes, employment taxes, and tax accounting issues. And he is experienced with IRS alternative dispute resolution procedures, including its Fast Track Settlement program. David is also active in pro bono litigation.

David has extensive experience implementing and defending tax credits for the energy industry, such as the carbon capture and sequestration, wind, solar and other credits available under the Inflation Reduction Act (IRA). He has extensive experience working with clients, IRS and Treasury on the issuance of regulations and sub-regulatory guidance. His decades of working with clients in the energy and natural resources industries allow him to quickly identify issues and solutions for clients investing in green energy projects under the IRA.

As a recognized authority on tax controversy, David has been an adjunct professor at Georgetown University Law Center, teaching courses on transfer pricing and tax common law doctrines (e.g., economic substance, business purpose, step transaction, conduit entities). He is also the editor of “The Transfer Pricing Answer Book” (Practicing Law Institute).