Royce L. Tidwell
Partner, Washington, D.C.
Tax Controversy and Litigation

Royce Tidwell represents multinational corporations, financial institutions and individuals
through the full range of federal and state income tax controversy proceedings, including
audits, administrative appeals and judicial proceedings. Mr. Tidwell focuses on complex
tax controversies in connection with transfer pricing, financial products, foreign tax credits,
economic substance and business purpose, debt-equity, cross-border withholding and a varietyof partnership issues.
Mr. Tidwell has been ranked in Chambers USA and named a Tax Controversy Leader in
the International Tax Review’s Leaders Guide. He has guest lectured at the David A. Clarke
School of Law’s (UDC’s) Low-Income Taxpayer Clinic on U.S. Tax Court practice and procedure. Additionally, he has represented pro bono clients referred by UDC before the IRS.
T: 202.371.7159
royce.tidwell@skadden.com

Representative cases include:

Education- Amgen Inc. in connection with an ongoing significant transfer pricing case concerning
the licensing of complex biopharmaceutical products from the United States to Amgen’s
Puerto Rican subsidiary. Amgen Inc. & Subsidiaries v. Commissioner (U.S. Tax Court)

J.D., Georgetown University
Law Center, 2007 (cum laude;Articles Editor, Georgetown Law Journal)- Endo International Plc. as tax controversy counsel in connection with Skadden’s role as
primary restructuring counsel in Endo’s ongoing Chapter 11 bankruptcy proceeding. In re
Endo Int’l, plc (Southern District of New York)

B.S., Southern Methodist
University, 2004

- Altria Group Inc. in its ongoing dispute with the Michigan Department of Treasury regarding the constitutionality of taxing Altria’s extraterritorial investment gains. Philip Morris
USA v. Department of Treasury (Michigan Court of Claims)

Bar Admissions
District of Columbia
Maryland
U.S. Court of Federal Claims
U.S. Tax Court
U.S. Court of Appeals for theFederal, Ninth and Tenth Circuits- Altria Group Inc. in securing a complete victory in an IRS dispute related to a $9.3 million
tax refund regarding the scope of Section 162(f). Altria Group Inc. v. United States ofAmerica (Eastern District of Virginia)- Agero Holdings Inc. in a victory in a case involving the IRS’ determination of subsidiaries’ status as insurance companies. IRS conceded in full. Sirius XM Connected Vehicle
Services Holdings Inc. v. Commissioner (U.S. Tax Court)- Veolia Environnement SA (France) in its dispute with the IRS regarding a $4.6 billion
worthless stock deduction. IRS conceded in full
- Amazon.com, Inc. in a victory in one of the largest transfer pricing cases in decades andthe first involving e-commerce. Amazon.com, Inc. v. Commissioner (U.S. Tax Court; U.S.
Court of Appeals for the Ninth Circuit)- Eaton Corporation in a victory in the first case involving a court’s review of an IRS decision to retroactively cancel an advance pricing agreement. Eaton Corporation v. Commissioner (U.S. Tax Court)- Athene USA Corp. in reaching a global settlement with the IRS and DOJ of a refund caseinvolving the IRS’ disallowance of a change in method of accounting. Athene USA Corp. v.
United States (U.S. District Court, Southern District of Iowa)

1 Skadden, Arps, Slate, Meagher & Flom LLP

Royce L. Tidwell
Continued

Representative cases prior to joining Skadden include:- Chemtech Royalty Associates L.P. in its dispute with the IRS
involving partnership economic substance and debt-equity.
Chemtech Royalty Associates, L.P. v. United States of America(U.S. District Court, Middle District of Louisiana; U.S. Court ofAppeals, Fifth Circuit)- Imprimis Investors LLC in a case involving the Tax Equity andFiscal Responsibility Act and inconsistent positions with respect
to partnership allocations. Imprimis Investors LLC v. United States(U.S. Court of Federal Claims)

2 Skadden, Arps, Slate, Meagher & Flom LLP