David R. Fuller

Partner

David R. Fuller is a partner in Morgan Lewis’s Employee Benefits and Executive Compensation Practice. Mr. Fuller focuses his practice on tax planning and tax controversy matters involving employment taxes, fringe benefits, and contingent workforces, and he regularly advises Fortune 500 companies on these matters. He is recognized as an authority on matters involving payroll taxes, including worker classification, Section 530 relief, Section 3121(v), social security taxes, independent contractors, income tax withholding, supplemental unemployment compensation benefit plans (SUB pay), employee outsourcing, and information reporting. Mr. Fuller also has a background in fringe benefits, qualified transportation fringes, executive fringe benefits, working condition fringes, employer-provided jet aircraft and automobiles, no additional cost fringes, meals/lodging, accountable plans, and income minimization techniques.

Mr. Fuller has dealt with a range of compliance, planning, and litigation matters. He has worked on many employment tax, employee-independent contractor, and fringe benefits planning strategies and has handled numerous tax controversy matters both with and against IRS agents and appeals officers. Mr. Fuller has worked on a wide array of nonlitigation issues with attorneys, agents, and officials at all levels of the IRS.

Prior to joining Morgan Lewis, Mr. Fuller was a partner at a large international law firm. Before that, he was a manager in the IRS’s Office of the Associate Chief Counsel—Tax Exempt and Government Entities (formerly known as EBEO). At the IRS, Mr. Fuller shared supervisory and management functions in the first IRS branch with combined interpretative and litigation functions. He also formerly served as a law clerk in the U.S. Tax Court.

Mr. Fuller is a frequent speaker and author on issues involving fringe benefits, payroll taxes, and worker classification. He is the co-contributing editor for both the Employer’s Guide to Fringe Benefit Rules and Complying with IRS Employee Benefit Rules. He also conducted the first tax seminar on the Internet in conjunction with tax analysts.

Mr. Fuller received his LL.M. from New York University School of Law in 1984; his J.D. from the University of Cincinnati College of Law in 1983; and his B.A. from Anderson University in 1980.

Mr. Fuller is admitted to practice in the District of Columbia.