Jeff Silver

Attorney at IRS, Office of Chief Counsel
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Contact Information
us****@****om
(386) 825-5501
Location
Detroit Metropolitan Area
Languages
  • English Native or bilingual proficiency
  • French Professional working proficiency

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Bio

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Credentials

  • CPA
    Commonwealth of Massachusetts
    Jul, 1988
    - Oct, 2024

Experience

    • United States
    • Law Practice
    • 400 - 500 Employee
    • Attorney
      • Jun 2023 - Present

    • United States
    • Government Administration
    • 700 & Above Employee
    • Transfer Pricing Specialist
      • Jul 2012 - Jun 2023

      Responsible for identifying transfer pricing cases of strategic importance, building an adequate factual record to support the government's position, and advocating (in briefing and oral presentations) for the government through the IRS Appeals process. I have secured favorable results for the government in appeals, and successfully advocated for designating cases for litigation. I have been attached to trial teams to assist in preparing transfer pricing cases for litigation in the Tax Court and US District Court, and have participated in negotiations with Taxpayer's counsel in attempts to resolve cases short of litigation. Show less

    • United States
    • Higher Education
    • 700 & Above Employee
    • Visiting Assistant Professor
      • Aug 2004 - Jul 2012

      Member of faculty with responsibility for teaching courses in tax law, constitutional law, and torts. Researched and drafted articles in all 3 fields. Member of faculty with responsibility for teaching courses in tax law, constitutional law, and torts. Researched and drafted articles in all 3 fields.

    • United States
    • Law Practice
    • 400 - 500 Employee
    • Associate
      • Jul 2003 - Jul 2004

      Specialized in broker-dealer litigation on behalf of major brokerage houses. Second chaired NASD arbitration hearings and prepared arbitration cases for hearing. Assisted clients in responding to subpoenas from financial market regulators, including the SEC, NASD, and NYSE. Specialized in broker-dealer litigation on behalf of major brokerage houses. Second chaired NASD arbitration hearings and prepared arbitration cases for hearing. Assisted clients in responding to subpoenas from financial market regulators, including the SEC, NASD, and NYSE.

    • United States
    • Law Practice
    • 700 & Above Employee
    • Associate
      • Sep 2000 - May 2003

      Civil and criminal litigation associate. Member of trial team on multi-billion dollar arbitration. Represented clients of brokerage house in suit for malfeasance, reaching a favorable settlement through mediation. On brief for amici Steelcase, Inc., et al. in US Supreme Court. Represented a state run college in suit alleging violations of Open Meetings Act. Civil and criminal litigation associate. Member of trial team on multi-billion dollar arbitration. Represented clients of brokerage house in suit for malfeasance, reaching a favorable settlement through mediation. On brief for amici Steelcase, Inc., et al. in US Supreme Court. Represented a state run college in suit alleging violations of Open Meetings Act.

    • Law Clerk
      • Aug 1999 - Sep 2000

    • United Kingdom
    • IT Services and IT Consulting
    • 700 & Above Employee
    • Tax Senior Manager
      • 1990 - 1996

      Advised both US and non-US clients on US tax effective structures for international operations. Advised UK multinational on restructuring after its LBO created very unfavorable US tax results. Instructor for both internal training and seminars for the tax community. Advised both US and non-US clients on US tax effective structures for international operations. Advised UK multinational on restructuring after its LBO created very unfavorable US tax results. Instructor for both internal training and seminars for the tax community.

    • Tax Senior
      • 1986 - 1990

      As a member of firm-wide system development team for the firm's proprietary foreign tax credit software, worked with programmers to insure software produced results consistent with evolving guidance in the aftermath of the Tax Reform Act of 1986. Supervised tax compliance prjects for corporations, partnerships (including large syndicated real estate partnerships), mututal funds, and high net-worth individuals. As a member of firm-wide system development team for the firm's proprietary foreign tax credit software, worked with programmers to insure software produced results consistent with evolving guidance in the aftermath of the Tax Reform Act of 1986. Supervised tax compliance prjects for corporations, partnerships (including large syndicated real estate partnerships), mututal funds, and high net-worth individuals.

Education

  • University of Michigan Law School
    JD, Law
    1996 - 1999
  • University of Michigan - Stephen M. Ross School of Business
    Master of Business Administration (MBA)
    1984 - 1986
  • University of Pennsylvania
    Bachelor of Arts (BA), Political Science and Government
    1980 - 1984

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