Alex E. Sadler

Alex brings a strategic, solutions-oriented approach to complex tax litigation, particularly in the area of research and development (R&D) tax credit provided under Internal Revenue Code section 41—a business tax incentive that is valuable but also frequently the subject of Internal Revenue Service (IRS) scrutiny and tax controversy—a field in which he is considered one of the foremost authorities, having authored the treatise “Legal Guide to the Research Credit” published by Thomson Reuters®. Alex also chairs the firm’s annual R&D Tax Credit Symposium, a leading event for thought leadership on the research credit. He has litigated several high-profile research credit cases and helped many more clients resolve research credit issues with the IRS without litigation.

Alex has also helped corporate clients navigate high-stakes transfer pricing and other sophisticated corporate tax issues to successful resolution.

While with the Tax Division of the US Department of Justice (DOJ), Alex served in several extended trials involving corporate tax issues and received both the Attorney General’s Distinguished Service Award and the Tax Division’s Outstanding Attorney Award. This government-side experience gives Alex unique insight into IRS and DOJ strategy, which he uses to the advantage of his clients in both settlement negotiations and court proceedings.

Alex is widely recognized by his peers and the legal community. Alex is a past Chair and Vice Chair of the DC Bar’s Tax Audits and Litigation Committee and is listed in Chambers USA, The Legal 500 US, Washingtonian Top Lawyers Guide, and Washington DC Super Lawyers.

Note: This list includes engagements completed prior to joining Morgan Lewis.

• Research Credit: Litigated R&D cases in US Tax Court, federal district court, and US Court of Federal Claims for companies in the steel, pharmaceuticals, automotive, chemical manufacturing, engineering, and retail industries;. Rresolved numerous research credit cases for businesses from a range of industries involving technology and manufacturing before the IRS.
• Transfer Pricing: Assisted companies in manufacturing industries in favorably resolving high-stakes transfer pricing adjustments before IRS Appeals and competent authorities using treaty-based procedures.
• Other Corporate Tax Issues: Represented numerous taxpayers in cases involving a range of complex tax issues before the IRS and courts including financial products, structured transactions, worthless stock, interest netting, welfare benefit arrangements, enforcement of settlement agreements, tax accounting, Freedom of Information Act (FOIA), confidentiality concerns, IRS summonses, and tax penalties.