Drew A. Cummings
Drew Cummings represents taxpayers during all stages of federal income tax controversy matters. Drew brings a wealth of experience in transfer-pricing dispute resolution and avoidance, including during Internal Revenue Service (IRS) audits, mutual agreement procedure (MAP) competent authority, IRS administrative appeals, and US Tax Court and district court litigation. Drew also represents clients against adjustments related to high-stakes international and domestic controversy issues. Drew advises multinational corporations on complex transactions, including issues related to withholding tax, foreign tax credits, worthless stock deductions, and economic substance.
Drew provides both sound technical and persuasive advocacy skills but, more importantly, strategic counsel regarding the best routes of resolution to resolve disputes effectively and efficiently. He focuses the majority of his practice on representing Fortune 500 companies and high-net-worth individuals against IRS income adjustments, including in front of the Advance Pricing and Mutual Agreement (APMA) program for MAPs and Advance Pricing Agreements (APA). He also assists clients navigating international and domestic (summons and subpoena) document productions issued to taxpayers and third parties. Drew represents taxpayers across industries and draws on experience representing companies in the life sciences (medical device and pharmaceutical), healthcare, retail, financial services, and technology industries.
