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William F. Nelson

Partner

Will Nelson’s practice encompasses all areas of federal taxation, with special emphasis on partnership taxation and tax controversy and litigation matters. Previously chief counsel for the Internal Revenue Service, Will co-authored the treatise Federal Taxation of Partnerships and Partners (Warren, Gorham & Lamont, 4th edition, 2007) as well as Structuring and Drafting Partnership Agreements: Including LLC Agreements (Warren, Gorham & Lamont, 3rd edition, 2003). Will writes on tax law for numerous journals, and he frequently lectures at tax institutes.

Extended Profile

Noted as “technically expert, creative, and a terrific tax litigator” as well as a “tremendous thinker who always provides great guidance," Will is named one of the leading practitioners in taxation by Chambers Global and Chambers USA, among others.

Prior to joining Morgan Lewis, Will was a partner in the corporate practice of another international law firm, where he was a former co-leader of the firm’s tax practice.

Education

  • Mississippi State University, 1969, Bachelor of Science, High Honors
  • University of Virginia School of Law, 1972, Juris Doctor

Admissions

  • District of Columbia
  • Georgia
  • US Court of Appeals for the Eleventh Circuit
  • US Court of Appeals for the Federal Circuit
  • US Court of Appeals for the Fifth Circuit
  • US Court of Appeals for the First Circuit
  • US Court of Appeals for the Second Circuit
  • US Court of Appeals for the Third Circuit
  • US Court of Federal Claims
  • US Tax Court

Awards and Affiliations

Member, Practice Group of the Year, Tax, Law360 (2017)

Recognized, Who’s Who Legal (2016) 

Recognized, Litigation and Controversy – Tax, Washington, DC, The Best Lawyers in America (2012–2019)

Recognized, Tax Law, Washington, DC, The Best Lawyers in America (2010–2015, 2017, 2019)

Ranked, Tax, District of Columbia, Chambers USA (2003–2015, 2018)

Ranked, Tax: Controversy, Nationwide, Chambers USA (2006–2016, 2018)

Ranked, Tax: Corporate, Chambers Global (2001–2017)

Recommended, Tax Controversy, The Legal 500 US (2013, 2015)

Recommended, Tax – Domestic tax, The Legal 500 US (2015)

Recognized, International Who’s Who of Corporate Tax Lawyers (2013)

Recognized, Washington, DC Super Lawyers (2007–2014)

Recognized, Euromoney’s Legal Media Group’s Guide to the World’s Leading Lawyers, Tax Advisers

Publications

11/2/2015 - New Legislation Makes Sweeping Changes Impacting All Partnerships

8/13/2015 - Treasury and IRS Release Notice 2015-54: Potential Impact on Domestic and Foreign Partnerships

Events

2/7/2019 - Final Partnership Audit Rules, IRS Implementation, and Impact on Partnerships

1/25/2018 - Navigating US Tax Reform: Pass-Through Entities

12/8/2015 - New Legislation Makes Sweeping Changes Affecting All Partnerships

9/30/2015 - A New Era of IRS Examinations – Doing More with Less?