Charles M. Ruchelman

Charles M. Ruchelman

Attorney Profile

Top Rated Tax Attorney in Washington, DC

Caplin & Drysdale, Chartered
 | One Thomas Circle NW, Suite 1100
Washington, DC 20005
Phone: 202-862-7834
Fax: 202-429-3301
Selected to Super Lawyers: 2013 - 2019
Licensed Since: 2004
Practice Areas:
  • Tax: Business (50%),
  • Tax: Consumer (50%)
Attorney Profile

Mr. Ruchelman is a Member in Caplin & Drysdale's Washington, D.C., office, where he concentrates his practice in tax litigation and controversies with the Internal Revenue Service and other tax authorities. He also represents clients in general tax matters.

Mr. Ruchelman has extensive experience in resolving tax matters at all stages of tax disputes including IRS examinations, IRS appeals, post-appeals mediation, trial court litigation, and appellate litigation. He has litigated cases in the U.S. Tax Court, various U.S. district courts, and the U.S. Court of Federal Claims.

Before joining Caplin & Drysdale, Mr. Ruchelman was a Trial Attorney with the U.S. Department of Justice, Tax Division, and an Attorney with the Internal Revenue Service, Office of Chief Counsel. While at the Department of Justice, he litigated tax cases in the federal district courts and the U.S. Court of Federal Claims. For his work representing the government in extended trials involving the IRS's attack on leveraged corporate-owned life insurance as a tax shelter, Mr. Ruchelman received the Attorney General's Distinguished Service Award.

"His strengths include the ability to speak about the law in layman's terms, strong follow-through, and an unbelievable attention to detail"  - Chambers USA

"a great litigator, a good strategic thinker and an excellent advocate"   - Chambers USA

About Charles Ruchelman

Admitted: 2004, Washington D.C.

Professional Webpage: http://www.capdale.com/cruchelman

Honors/Awards:

  • Chamber USA, 2016
  • The Legal 500, Top-Tier Firm, Tax - US Taxes - Contentious, 2010, 2015-Present
  • The Legal 500, Leading Lawyer, 2011, 2012; Recommended, 2014
  • Super Lawyers, Washington, D.C., 2013-Present
  • The Washington Post, Top Attorneys in D.C., 2014
  • Received the U.S. Attorney General's Distinguished Service Award in 2001

Bar/Professional Activity:

  • Active member of American Bar Association (Section of Taxation), the Court of Federal Claims Bar Association, and the U.S. Tax Court's J. Edgar Murdoch Inns of Court
  • Past Chair, D.C. Bar (Tax Section, Tax Audits and Litigation Committee)
  • Admitted to New York Bar in 1994; Admitted in D.C. in 2003

Scholarly Lectures/Writings:

  • Please click HERE to see full list.
  • "EXPERT ANALYSIS: Planning For Partnership Representatives In The New Year", with Rachel L. Partain and Aaron M. Esman, Law360, January 4, 2019
  • "BLOG: Tax Court Rules - Partnership Representative", with Benjamin Z. Eisenstat, www.PartnershipRepresentative.com, December 28, 2018
  • "BLOG: IRS Publishes Draft Instructions for Form 8979, Partnership Representative Revocation, Designation, and Resignation Form", with Aaron M. Esman, www.PartnershipRepresentative.com, December 5, 2018
  • "Year-End Updates on Partnership Representatives", with Rachel L. Partain and Aaron M. Esman, Caplin & Drysdale Client Alert, November 6, 2018
  • "Paradise Papers: U.S. Citizens and Residents Required to Report on Offshore Assets", with Mark D. Allison, J. Clark Armitage, Peter A. Barnes, and Arielle M. Borsos, Caplin & Drysdale Client Alert, November 6, 2017
  • Panelist, Captive Legal and Tax Insights, Kentucky Captive Association, 2017 Kentucky Captive Association Educational Conference, June 16, 2017
  • Panelist, TOIs, Investigations, and Campaigns – the Tools of the IRS, Delaware Captive Insurance Association Spring Forum, May 8, 2017
  • Panelist, Part 5 of 6 Pass-Throughs and Real Estate and Part 6 of 7 Tax Audits and Litigation Tax Series: Exploring the Proposed BBA Partnership Audit Regulations, D.C. Bar, April 5, 2017
  • "Captive Insurance: State Reporting Obligations for Transactions of Interest", with Christopher S. Rizek and Rachel L. Partain, International Law Office, March 3, 2017
  • "IRS Launches Issue Based Corporate Compliance Campaigns", with Mark D. Allison, J. Clark Armitage, Kirsten Burmester, and Niles A. Elber, Global Tax Weekly, February 16, 2017
  • "Captive Insurance Industry Should Be Aware of State Reporting Obligations for Transactions of Interest", with Christopher S. Rizek and Rachel L. Partain, Caplin & Drysdale Client Alert, February 10, 2017
  • "IRS Launches 13 Issue-Based Corporate Compliance Campaigns," with Mark D. Allison, J. Clark Armitage, Kirsten Burmester, Niles A. Elber, Neal M. Kochman, Rachel L. Partain, James E. Salles, Zhanna A. Ziering, and Dustin J. Barzell , Caplin & Drysdale Client Alert, February 3, 2017
  • "Syndicated Conservation Easement Transactions Identified as New 'Listed Transactions'", with Christopher S. Rizek, International Law Office, January 27, 2017
  • "Tax Claims - Court of Federal Claims: Jurisdiction, Practice, and Procedure," Court of Federal Claims: Jurisdiction, Practice, and Procedure, January 9, 2017
  • "Congress Looks to Fix New Partnership Audit Rules," with Elizabeth J. Stevens, Jonathan S. Brenner, and Rachel L. Partain, International Law Office, January 6, 2017
  • "Syndicated Conservation Easement Transactions Indentified as New "Listed Transactions"," with Christopher S. Rizek and Arianna Caldwell, Caplin & Drysdale Client Alert, January 3, 2017

Verdicts/Settlements:

  • Currently representing numerous clients in all stages of Internal Revenue Service examinations and Government investigations involving foreign accounts and foreign entities.
  • Represented a large Wall Street financial services firm in appeal to the 7th Circuit Court of Appeals (JPMorgan Chase & Co. v. C.I.R., 530 F.3d 634 (7th Cir. 2008)).
  • Represented an international accounting firm in litigation concerning privilege issues (United States v. BDO Seidman LLP, 2004 WL 1470034 (N.D. Ill, June 28, 2004)).
  • Attained a favorable settlement for a high-net-worth individual in an IRS examination involving a contribution of a conservation easement.
  • Represented third-party witness in Amazon.com Inc. & Subsidiaries transfer pricing case before the U.S. Tax Court.
  • Successfully defended Hawaii Department of Taxation and its employees against unlawful disclosure claims in the U.S. District Court (Marsoun v. United States, 525 F. Supp.2d 206 (D. D.C. 2007)).
  • Achieved a favorable settlement for a high-net-worth family in an IRS examination involving family limited partnership issues.
  • Reached global settlement with IRS Office of Chief Counsel in 80 separate Tax Court cases involving common employee benefit plan tax issues.
  • Represented a hedge fund and its tax matters partner in a three-way IRS examination that led to litigation with the IRS and an adverse partner in the U.S. Court of Federal Claims (Imprimis Investors LLC v. United States, 83 Fed. CI. 46 (2008)).
  • Represented a tax attorney in proceedings brought by the IRS Office of Professional Responsibility in the U.S. administrative court. IRS conceded significant issues on the eve of trial.
  • Successfully resolved an examination involving promoter penalty issues in IRS post-appeals mediation.

Other Outstanding Achievements:

  • Mr. Ruchelman has been published or quoted in the media including Forbes, CNBC, Bloomberg News, Tax Notes, and The Forward. For a comprehensive list of Mr. Ruchelman's mentions in the media, please click here.

Educational Background:

  • LL.M. in Taxation, Georgetown University Law Center, 1999
  • J.D., Syracuse University College of Law, 1993, cum laude
  • B.S., George Mason University, 1990, with distinction

Industry Groups

  • ABA
  • U.S. Tax Court's J. Edgar Murdock Inn Of Court
Office Location for Charles M. Ruchelman

One Thomas Circle NW
Suite 1100
Washington, DC 20005

Charles M. Ruchelman:

Last Updated: 2/11/2019

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