Michael Quigley

Mr. Quigley has tried more than 50 civil tax cases before the U.S. Tax Court, the U.S. Court of Federal Claims, and many U.S. federal district courts. His tax litigation experience is extensive, and he has been nationally ranked in the United States by Chambers & Partners, has been a master of the Inns of Court, and is frequently called upon to serve as lead tax litigation counsel.

Mr. Quigley is a leading authority on intercompany transfer pricing, tax treaties, permanent establishment issues and other tax matters affecting multinational corporations. He has represented clients in obtaining advance pricing agreements with the IRS and the tax authorities of many other jurisdictions including obtaining some of the first APAs between the United States and Korea and Japan. He has appeared before the U.S. Competent Authority and the competent authorities of many other countries including Korea, India, and Japan, among others, and is experienced in the use of the mutual assistance provisions of tax treaties to eliminate double taxation.

For many years, Mr. Quigley has studied the economic, business, and political affairs of the Republic of Korea and the Korean Peninsula, with a particular emphasis on U.S.-Korea relations. He has a developed interest in Japan and its relations with the United States and Korea, and with U.S.-India relations, and the political and economic affairs of India. More broadly, Mr. Quigley is keenly focused on U.S. relations with Asia.