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Cameron Reilly

Partner
Baker & McKenzie LLP

Biography

Cameron Reilly is a partner in Baker McKenzie's Global Tax Practice Group in the Chicago office. He regularly advises both multinational corporations and individuals at all stages of tax disputes, from audit to administrative appeal and US Tax Court litigation.

Practice Focus

Cameron advises mainly on transfer pricing disputes and other local and international tax disputes. He assists clients in all stages of tax disputes — from audit and administrative appeals before the IRS to litigation before the United States Tax Court and other federal courts.

Representative Legal Matters

  • Facebook, Inc. & Subs. v. Commissioner, U.S. Tax Court, No. 21959-16 (transfer pricing cost-sharing valuation dispute)

  • Pfizer Inc. & Subs. v. United States, No. 19-01803 T, U.S. Court of Federal Claims (successful resolution of section 6611 overpayment interest suit)

  • FedEx Corp. & Subs. v. United States, U.S. District Court for the Western District of Tennessee, No. 2:20-cv-02794 (challenge to the validity of regulations under section 965)

  • Whirlpool Financial Corp. v. Commissioner, U.S. Tax Court, Nos. 13986-17, 13987-17, U.S. Court of Appeals for the Sixth Circuit, Nos. 20-1899, 20-1900 (application of Subpart F Manufacturing Branch Rules to Mexican manufacturing company)

  • Judkins v. U.S. Department of the Treasury, No. 20-cv-2342, U.S. District Court for the District of Columbia (FOIA litigation related to section 965 administrative record)

  • Judkins v. Internal Revenue Service, No. 20-cv-2344, U.S. District Court for the District of Columbia (FOIA litigation related to section 965 administrative record)

  • Richardson v. Commissioner, U.S. Tax Court Dkt. No. 7390-17S (section 469(i) rental real estate passive activity loss issue with a stipulated decision that no deficiencies or accuracy-related penalties are applicable)

  • Blumenkrantz v Commissioner, U.S. Tax Court, No. 26585-17 (civil fraud and FBAR litigation)

  • Bin Attash v. Biden, No. 05-cv-1592, U.S. District Court for the District of Columbia (Guantanamo Bay detainee habeas counsel and Private Counsel before the Periodic Review Board)

  • Al-Bihani v. Biden, No. 22-cv-2845 and No. 05-cv-2386, U.S. District Court for the District of Columbia (Guantanamo Bay detainee habeas counsel litigation)

Professional Associations and Memberships

  • American Bar Association - Member
  • NBLSA Tax Mentor Program - Mentor

Admissions

  • U.S. Court of Federal Claims (2020)
  • U.S. Court of Appeals, Sixth Circuit~United States (2020)
  • U.S. District Court, District of Columbia~United States (2020)
  • U.S. District Court, Western District of Tennessee~United States (2020)
  • U.S. Tax Court~United States (2018)
  • U.S. District Court, Northern District of Illinois~United States (2017)
  • Illinois~United States (2015)
  • U.S. District Court, Southern District of Texas~United States

Education

  • University of Minnesota (J.D. Business Law, cum laude) (2015)
  • University of Kentucky (B.A., summa cum laude) (2012)

Presentations

  • Presenter, "Tax Controversy Landscape - Issues & Trends," TEI Northeast Wisconsin: International Tax Seminar, October 2024

  • Co-presenter, "Future of Track: Tax Litigation Overview," 19th Annual Global TPT Workshop, June 2024

  • Co-presenter, "Global trends Affecting Canadian Tax Controversies," TEI Tax Litigation Day, September 2023

  • Co-presenter, "Are CUTs Still King? Coca-Cola, Medtronic, and the Future of Transfer Pricing," Dell Technologies, Inc. Baker McKenzie Tax Workshop, June 2023

  • Co-presenter, "Tax: Ethics Update," The Chicago Tax Club, Fall 2020

  • Co-presenter, "Issues and Opportunities Relating to Cross-Border Tax Controversies After the TCJA," Tax Executive Institute/Houston Chapter 2018 Tax School, Houston, TX, May 2018.