Brendan J. Sponheimer
Partner
Brendan Sponheimer focuses his practice on tax disputes and transfer pricing matters. He represents taxpayers at all levels of federal tax controversy, including IRS audits, administrative appeals, competent authority, and litigation before the US Tax Court, federal district courts, and US Court of Federal Claims. He has represented clients in controversies involving complex transfer pricing issues, research and development tax credits, debt-equity characterization of intercompany advances, expense characterization, economic substance, and substance-over-form issues.
Prior to joining Morgan Lewis, Brendan was a tax partner at another global law firm and, before that, served as an attorney advisor at the US Tax Court.
- Represented a life sciences company in transfer pricing and Tax Cuts and Jobs Act litigation before the US Tax Court
- Represented clients in a range of industries to resolve transfer pricing matters before the IRS
- Represented a retail industry company in research credit litigation before the US Tax Court
- Represented businesses in a range of industries to resolve research credit matters before the IRS
- Represented a life sciences company in litigation before the US Tax Court regarding the deductibility of M&A termination fees, including subsequent appellate proceedings
- Represented a retail automotive services company in litigation before the US District Court for the Southern District of New York involving tax-related indemnification and corporate separation issues
- Represented a life sciences company in Freedom of Information Act litigation before the US District Court for the District of Columbia
- Georgetown University Law Center, 2011, LL.M., with distinction
- Western New England University School of Law, 2010, J.D., cum laude
- Yale University, 2007, B.A.
- New York
- Connecticut
- US Court of Appeals for the Seventh Circuit
- US Tax Court
- US Court of Federal Claims