C. Terrell Ussing

Partner

C. Terrell Ussing concentrates his practice in the area of tax controversy and litigation, representing clients in all phases of tax controversy, from audit to litigation. He counsels multinational corporations on a range of complex domestic and international tax issues, with a particular emphasis on transfer pricing. Terrell’s transfer pricing experience focuses on hard-to-value intangible property and further includes sophisticated transfer-pricing planning and risk assessment at the federal and international level and state level where the federal transfer-pricing principles apply.

Extended Profile

Terrell advises clients at all stages of the tax controversy process, including pre-audit, audit, appeals, Advance Pricing Agreement and Competent Authority, and trial and judicial appeals. He was a critical member of the trial teams representing Amazon.com and The Coca-Cola Company in their multi-billion-dollar transfer-pricing litigations before the US Tax Court. Terrell deposed expert witnesses, lead direct and cross-examinations, and drafted successful motions and trial briefs. He also speaks on transfer pricing, tax controversy, and litigation topics at Tax Executive Institute (TEI) and BNA events.

Terrell is an adjunct professor in the Graduate Tax Program at the Georgetown University Law Center, where he currently teaches "Survey of Transfer Pricing."

Terrell regularly represents pro bono clients with cases docketed before the US Tax Court through the Washington, DC Center for Public Interest Tax Law, a non-profit organization that provides pro bono representation to low-income taxpayers with cases docketed before the US Tax Court.

selected representations

Western Digital Corporation & Subsidiaries v. Commissioner, T.C. Docket No. 18984-18 and 4818-19 (transfer pricing and section 956) (pending)
The Coca-Cola Company & Subsidiaries v. Commissioner, Tax Court Docket No. 31183-15 (transfer pricing and foreign tax credits; 10-week trial) (pending)
Amazon.com, Inc. & Subsidiaries v. Commissioner, 148 T.C. 108 (2017) (transfer pricing (cost-sharing) issues) (>5-week trial), aff’d 934 F.3d 976 (9th Cir. 2019)