Mark D. Allison

Mark D. Allison

Attorney Profile

Top Rated Tax Attorney in New York, NY

Caplin & Drysdale, Chartered
 | 600 Lexington Avenue, 21st Floor
New York, NY 10022
Phone: 212-379-6060
Fax: 212-379-6001
Selected To Super Lawyers: 2013 - 2019
Licensed Since: 1996
Practice Areas:
  • Tax: Business
Attorney Profile

Mark D. Allison is a Member in Caplin & Drysdale's New York office. Mr. Allison's practice involves complex federal, state, and cross-border tax controversy and litigation matters; related civil, criminal, and regulatory proceedings; and internal investigations. He represents multinational corporations, financial institutions, and high net worth individuals and professional athletes in proceedings before the Internal Revenue Service, the U.S. Department of Justice, the U.S. Attorneys' Office, and other government regulators.

An experienced trial attorney, Mr. Allison has litigated before the U.S. Courts of Appeals, the U.S. Tax Court, the U.S. Court of Federal Claims and in bench and jury trials in federal district court. He also advises clients in pre- and post-transaction review and analysis of potential tax disputes for purposes of ASC 740, Schedule UTP and other regulatory reporting and internal risk management. Mr. Allison also serves as the general counsel to a New York City-based hedge fund manager.

Mr. Allison previously served as an attorney-advisor to the Honorable Julian I. Jacobs of the United States Tax Court, and as a law clerk to the Honorable Joseph C. Small of the New Jersey Tax Court.

About Mark Allison

Admitted: 1996, New York

Professional Webpage: http://www.caplindrysdale.com/mallison

Honors/Awards:

  • Above the Law, Tax Firm Power List, 2016
  • The Legal 500, Recommended, 2012-Present

Bar/Professional Activity:

  • Adjunct Professor, New York University School of Law, 2009-Present
  • Chair, Court Procedure & Practice Committee, American Bar Association, Tax Section, 2013-Present (formerly Vice-Chair, 2011-2013; Chair for the Tax Court, 2007-2011; Appellate Practice, 2005-2007; Current Developments, 2004-2005)
  • Articles Editor, The Tax Lawyer, 2011-Present
  • Fellow, American College of Tax Counsel, 2012-Present
  • Board of Advisors, Low Income Taxpayer Clinic, Legal Aid Society, 2007-2011
  • Member, New York State Bar Association, Tax Section
  • Board of Advisors, Duke Law School Low Income Taxpayer Clinic, 2006-2008
  • Former Associate Justice, B'nai B'rith International Supreme Court, 2003-2004

Scholarly Lectures/Writings:

  • "New Law Changes FBAR Filing Deadline," with Matthew C. Hicks, Niles A. Elber, Charles M. Ruchelman, Scott D. Michel, Zhanna A. Ziering, Mark E. Matthews, and T. Joshua Wu, Caplin & Drysdale, August 10, 2015
  • "Transfer Pricing Audits: Flipping the Tested Party," with H. David Rosenbloom, Neal M. Kochman, Patricia Gimbel Lewis, J. Clark Armitage, Peter A. Barnes, and Elizabeth J. Stevens, Caplin & Drysdale, August 13, 2015
  • "The Final OECD BEPS Tome Has Arrived," with Dianne C. Mehany, Michael G. Pfeifer, Richard W. Skillman, H. David Rosenbloom, Stafford Smiley, Neal M. Kochman, Patricia Gimbel Lewis, Kirsten Burmester, J. Clark Armitage, Peter A. Barnes, and Jonathan S. Brenner, Caplin & Drysdale, October 8, 2015
  • "Congress Enacts Entirely New Tax Examination and Collection Regime for Partnerships," with Rachel L. Partain, T. Joshua Wu, and Christopher S. Rizek, Caplin & Drysdale, December 10, 2015
  • "U.S. Passports in Jeopardy for Taxpayers Owing the IRS ," with Dianne C. Mehany and Niles A. Elber, Global Tax Weekly , January 11, 2016
  • Speaker, Examinations of TEFRA Partnership, American Law Institute Continuing Legal Education (ALI CLE), Handling a Tax Controversy 2015: Current Trends in Civil Tax Controversies and Litigation, October 8, 2015
  • Speaker, IRS Audits and Appeals in the Issue Focused Exam Era, 2015 Nashville TEI Spring Seminar, May 20, 2015
  • Chair, Court Procedure and Practice Roundtable Discussion , American Bar Association, 2015 May Meeting, May 8, 2015
  • Panelist, Cross Border Privileges Issues, American Bar Association, 2015 May Meeting, May 8, 2015
  • Panelist, Pre-Trial Planning & Judicial Precedence, American Bar Association, 2015 Midyear Meeting, January 30, 2015
  • Panelist, From the Experts: Civil & Criminal Tax Controversy and Tax Litigation Update, New York University School of Professional Studies, 73rd Institute on Federal Taxation, November 16, 2014
  • Speaker, Cascading Toward Extinction? The Continuing Assault on Privilege, Tax Executive Institute, Nashville Chapter, October 22, 2014
  • Panelist, From the Experts: Civil and Criminal Tax Controversy and Tax Litigation Update, New York University, 73rd Institute on Federal Taxation, October 19, 2014
  • Panelist, Tax Court Procedures: Pretrial Practices (Motions, Pretrial Memoranda, Stipulations of Fact, Exhibits and Witness Subpoenas), American Law Institute (ALI) CLE, Handling a Tax Controversy: Audit, Appeals, Litigation, & Collections, October 17, 2014
  • Panelist, It's a Privilege, or Is It: Privilege Issues in Tax Cases, American Bar Associaton, 2014 Joint Fall CLE Meeting, September 19, 2014
  • Chair, Court Procedure and Practice Roundtable Discussion, American Bar Association, 2014 Joint Fall CLE Meeting, September 19, 2014
  • "IRS Releases Guidelines for Examining CFC Transactions," with H. David Rosenbloom, Neal M. Kochman, Patricia Gimbel Lewis, J. Clark Armitage, Peter A. Barnes, and Elizabeth J. Stevens, Caplin & Drysdale, July 29, 2015
  • "Abusive Small Captive Insurance Companies on IRS 'Dirty Dozen' List," with Charles M. Ruchelman, Christopher S. Rizek, and Rachel L. Partain, International Law Office, February 27, 2015
  • "Abusive Small Captive Insurance Companies Added to IRS "Dirty Dozen Tax Scams" ," with Charles M. Ruchelman, Christopher S. Rizek, and Rachel L. Partain, Caplin & Drysdale, February 13, 2015
  • "Proposed New York Tax Changes Would Affect Large and Small Businesses," with Rachel L. Partain and Clinton G. Wallace, International Law Office, January 30, 2015
  • "NYC Proposed Tax Code Changes Would Affect Businesses Large and Small," with Rachel L. Partain, Caplin & Drysdale, January 13, 2015
  • "Switzerland Narrows Advance Notice to Account Holders of Treaty Requests: Americans with Unreported Accounts Impacted," with Scott D. Michel and Mark E. Matthews, Caplin & Drysdale, December 16, 2014
  • "IRS Issues Final Regulations On Material Advisor Penalties," Global Tax Weekly, September 4, 2014
  • "IRS Issues Final Regulations on Material Adviser Penalties," with Christopher S. Rizek, International Law Office, August 29, 2014
  • "IRS Issues Final Regulations on Material Advisor Penalties," with Christopher S. Rizek, Rachel L. Partain, and Zhanna A. Ziering, Caplin & Drysdale, August 4, 2014

Educational Background:

  • LL.M., New York University School of Law, 1996
  • J.D., American University Washington College of Law, summa cum laude, Arthur Bakalar Award, Note & Comment Editor, American University Journal of International Law & Policy, 1995
  • M.A., American University, 1992
  • B.A., Claremont McKenna College, 1990
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Office Location for Mark D. Allison

600 Lexington Avenue
21st Floor
New York, NY 10022

Mark D. Allison:

Last Updated: 4/4/2019

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