404 Not Found

Not Found

The requested URL /esi/header.html was not found on this server.

Additionally, a 500 Internal Server Error error was encountered while trying to use an ErrorDocument to handle the request.

gradient
gradient

John Barrie’s practice focuses solely in the areas of federal and state tax controversy and transactional matters. He regularly represents individuals and business entities in federal and state tax controversy matters, including before IRS Appeals Offices, the United States Tax Court, the United States Court of Federal Claims, United States District Courts, as well as in various state courts in state tax matters. Tax litigation and tax controversy matters have included valuation issues (valuation of art work, easements, closely held businesses), excise tax issues, summons enforcement, offshore voluntary disclosure, transfer pricing, as well as various technical Code section interpretation and documentation issues.

Mr. Barrie's transactional practice includes representing public and private businesses in taxable and tax-free mergers, acquisitions, reorganizations, spin-offs, divestitures and restructurings, as well as representing clients before the IRS National Office in connection with ruling requests and technical advice.

Mr. Barrie is a member of the American Bar Association Section on Taxation and past vice-chair of the Tax Section. He is currently Chair of Taxation of Business Entities for the New York City Bar Association. He is an adjunct professor in the graduate tax program at Georgetown University Law Center, where he has taught courses in reorganizations, spin-offs and corporate tax planning and at New York Law School, where he has taught courses on corporate tax planning, S corporations and Tax Court litigation. Mr. Barrie is on the board of advisors for the Journal of Taxation and Regulation of Financial Institutions. He was a past editor on state tax matters for State Tax Notes and an advisor and department editor for the Journal of Multistate Taxation. Mr. Barrie has served as an attorney advisor to Hon. Leo H. Irwin, U.S. Tax Court, in Washington, D.C.

Civic Involvement & Honors

    • The Best Lawyers in America, 1991-2018
    • Who’s Who Legal: Corporate Tax
    • New York and Washington, D.C. Super Lawyers, 2009-2015
    • Member, NYU Institute on State and Local Taxation Advisory Board
    • Member, Partnership for New York City
    • New York and Washington, D.C. Super Lawyers, 2009-2015
    • Member, NYU Institute on State and Local Taxation Advisory Board
    • Member, Partnership for New York City
    • Member, Partnership for New York City
Read More

Professional Affiliations

    • American Bar Association, Section of Taxation (chair of the Pro Bono Award Committee, past vice-chair and past council director); Committee on Affiliated and Related Corporations (past chair); Committee on IRS Liaison Meetings (past chair); Committee on Government Submissions (past chair)
    • American Bar Association, Section on Litigation
    • District of Columbia Bar Association, Tax Section (past chair)
    • Federal Bar Association, Tax Section
    • Missouri Bar Association, Taxation Committee (past chair)
    • State Bar of California, Tax Section
    • New York State Bar Association, Tax Section
    • New York City Bar Association, Chair of Taxation of Business Entities Committee
    • National Association of State Bar Tax Sections, Executive Committee (past chair)
    • Fellow, American College of Tax Counsel
    • Missouri Bar Association, Taxation Committee (past chair)
    • State Bar of California, Tax Section
    • New York State Bar Association, Tax Section
    • New York City Bar Association, Chair of Taxation of Business Entities Committee
    • National Association of State Bar Tax Sections, Executive Committee (past chair)
    • Fellow, American College of Tax Counsel
    • New York City Bar Association, Chair of Taxation of Business Entities Committee
    • National Association of State Bar Tax Sections, Executive Committee (past chair)
    • Fellow, American College of Tax Counsel
Read More

Publications

  • "The Definition of Manufacturing for Missouri S&U Tax Exemption Purposes: An Evolving Story," Journal of Multistate Taxation and Incentives, May 2017, Vol. 27 No. 2
  • Author, "Mixed News on the Section 385 Front and Two Massachusetts Rulings Affecting Financial Institutions," Journal of Multistate Taxation and Incentives, Winter 2017, Vol. 30 No. 2 
  • Author, "New York Addresses Tax Treatment of Premiums Paid to a Captive Insurance Company," Journal of Multistate Taxation and Incentives, June 2016, Vol. 26 No. 3
  • Co-Author - Appeals of Tax Decisions, Eighth Circuit Appellate Practice Manual, 7th Edition, 2016
  • Author, "A Taxpayer Wynne and Other Interesting Developments," Journal of Taxation and Regulation of Financial Institutions, September/October 2015, Vol. 29 No. 1
  • Author, "Getting Refunds - South Dakota Supreme Court to Address Right to Bank Franchise Tax Refund Resulting From a Favorable Federal Income Tax Adjustment," Journal of Taxation and Regulation of Financial Institutions, March/April 2015, Vol. 28 No. 4
  • Co-Author - Appeals of Tax Decisions, Chapter 18, Eighth Circuit Appellate Practice Manual, 2013

Speaking Engagements

  • "Economic Nexus Standards in State Taxation," Lorman Education Services, Webinar, June 21 & 26, 2017
  • Co-Speaker, "Suing the IRS: Selecting the Right Court in Taxpayer-Initiated Litigation," New York Law School's Graduate Tax Program, March 30, 2017
  • Panelist and Member of Advisory Board, “What’s Happening Everywhere Today?” NYU 35th Institute on State and Local Taxation, Dec. 9, 2016
  • Moderator, "State Tax Implications – New Partnership Audit Rules," National Association of State Bar Tax Section Conference, October 28, 2016
  • "Litigation in United States Tax Court," Clear Law Institute, Webinar, November 16, 2016
  • Panelist, "Potential State Tax Implications of Proposed IRC 385 Debt/Equity Regulations," 2016 Joint Fall CLE Meeting, ABA Section of Taxation, September 2016
  • "Cross-Border Mergers & Acquisitions," U.S. International Tax Seminar, Networking Seminars, April 18, 2016
  • "FBAR and You - New Developments," 2015 Mid-Atlantic CPAsNET.com Regional Meeting, Sept. 30, 2015
  • Panelist,  "Document Requests vs. Document Demands: New IRS Attitudes Toward Collecting Information During Audits," NYU’s 7th Annual Tax Controversy Forum, June 5, 2015
  • "Attorney-Client Privilege in the Tax Context," Grant Thornton RRLA Attorney Retreat, Jan. 7, 2015
  • Panelist and Member of Advisory Board, “What’s Happening Everywhere Today?” NYU 33rd Institute on State and Local Taxation, Dec. 9, 2014
  • Panelist, “Conservation Easements – Issues and Answers & Non-Cash Charitable Donations of Real Estate,” IRS Valuation Summit, Oct. 21, 2014
  • Panelist, "Introduction to FATCA & Intergovernmental Agreements," New York Law School, April 7, 2014  
  • Host, Audio Conference on Economic Nexus Standards in State Taxation, Lorman Education Services, Dec. 16, 2014; June 25, 2014; Dec. 19, 2013; June 19, 2013
  • "FBARS/FATCA and Foreign Reporting," New York State Society of CPAs Conference on Current Tax Developments, Dec. 16, 2013
  • Panelist, "Current Developments," New York University 32nd Institute on State and Local Taxation, Dec. 13, 2013
  • Co-Presenter, "FATCA: The Game Has Started," NYSSCPA's Tax Planning for Individuals Conference, Aug. 13, 2013
  • Panelist, "Following the Money: Developments in the Global High Wealth Industry Group," NYU's 5th Annual Tax Controversy Forum, June 7, 2013
  • "Application of Penalties on IRS Adjustments to Historic Facade Easement Charitable Deductions and Lobbying Efforts," Fulbright & Jaworski LLP, March 8, 2011