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Randall Thomas

Partner

Randall Thomas advises domestic and international public charities, private foundations, and other tax-exempt organizations on a broad range of technical and compliance issues, including qualification, foundation classification, lobbying and political activities, revenue-generating operations, unrelated business income, excise taxes, reporting and disclosure requirements, joint ventures, and other structuring and transactional matters. He represents clients in tax litigation, in IRS audits and ruling requests, and in rulemaking proceedings before the Department of the Treasury. Randall also provides charitable giving advice to tax-exempt organizations and their donors, assisting with the design and implementation of tax-efficient charitable giving strategies.

Before joining the firm, Randall served as special counsel at the IRS’s Office of Chief Counsel for Employee Benefits, Exempt Organizations, and Employment Taxes, representing the division before other divisions at the Office of Chief Counsel, the Department of the Treasury, the Department of Justice, Congress, other federal agencies, and outside stakeholders. He has extensive experience working on the development of guidance with the Department of the Treasury and assisting the Department of Justice and Division Counsel at the Office of Chief Counsel with litigation and complex tax controversies.

Earlier in his career, Randall advised tax-exempt organizations and their donors in the Washington National Tax practice of a Big Four accounting firm and provided tax due diligence, structuring, and consulting services for mergers, acquisitions, and restructurings in that firm’s M&A group.

Randall has authored and co-authored numerous articles in tax publications and has presented at conferences on a variety of topics related to tax-exempt organizations and charitable giving.

  • New York University School of Law, 2014, LL.M., taxation, Public Interest Prize for LLMs
  • Louisiana State University, Paul M. Hebert Law Center, 2013, J.D., magna cum laude; Public Interest Law Society Pro Bono Service Award
  • University of North Florida, 2010, B.B.A., finance
  • Florida
  • US Tax Court

American Bar Association, section on taxation, exempt organizations committee

Mentor, Loretta Collins Argrett Fellowship (2025–2026)

Mentor, Florida Bar Counsel-to-Counsel (2024–2025)

Director, Court Appointed Special Advocates (Prince George’s County) (2016–2023)

Instructor, Coalition for Debtor Education (2014–2015)