Robert Russell

Tax Law
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01 - Counsel

Sophisticated tax counsel for complex federal, California, and international matters.

Practical, experienced counsel for businesses and individuals navigating complex tax disputes, transactions, and planning matters. The practice focuses on tax controversy and on tax advisory and planning, with experience spanning federal, California, and international tax matters.

Robert Russell’s tax practice is informed by a background in both law and accounting, as well as prior government experience and an LL.M. in Taxation. He also serves as law school faculty member and frequently presents on tax matters. expertise
02 — Practice

Advisory, planning,
and controversy.

The work divides into tax controversy and tax advisory and planning, across federal, California, and international matters. Clients include closely held businesses, partnerships and other pass-through entities, businesses engaged in cross-border activities, and the individual owners, partners, and shareholders behind them.

Tax Advisory & Planning

Practical advice on the decisions before numbers go on a tax return: entity structure, partnership and pass-through taxation, transactions and liquidity events, state and local questions, and cross-border structuring:

  • BUSINESS & TRANSACTIONAL PLANNING
  • CHOICE OF ENTITY
  • PARTNERSHIPS & PASS-THROUGHS
  • M&A AND LIQUIDITY EVENTS
  • NEXUS, APPORTIONMENT & RESIDENCY
  • CROSS-BORDER STRUCTURING
  • RULING REQUESTS

Tax Controversy

Representing taxpayers in disputes with the IRS and the California taxing authorities, from the first information document request through examination, administrative appeals, and litigation—including international tax controversies and transfer pricing matters:

  • IRS EXAMINATIONS
  • BBA PARTNERSHIP AUDITS
  • INTERNATIONAL CONTROVERSIES
  • TRANSFER PRICING
  • VOLUNTARY DISCLOSURES
  • IRS ADMINISTRATIVE APPEALS
  • IRS COLLECTIONS
  • TAX LITIGATION
    _______________________________
  • CA INCOME TAX AUDITS
  • CA RESIDENCY AUDITS
  • CA OFFICE OF TAX APPEALS
Robert Russell Formal
Robert M. Russell, Esq. · J.D. · LL.M. (Tax)
03 — About

Practical solutions to
complex tax problems.

Robert Russell advises businesses, investors, and individuals on complex domestic and international tax matters. His practice includes tax planning, cross-border transactions, business structuring, tax advisory matters, and tax controversies. He works with clients to identify practical solutions to complex tax problems and to navigate an increasingly sophisticated tax environment.

In addition to many years advising clients in private practice, Robert has served in several different government roles, including the Internal Revenue Service's Large Business & International Division, the U.S. Treasury Department's Office of Tax Policy, and the Joint Committee on Taxation of the United States Congress. That experience provides a distinctive perspective on the development, interpretation, administration, and enforcement of federal tax law.

At the IRS, Robert worked on multinational tax issues and large-business examinations. At Treasury, he prepared technical explanations supporting U.S. tax treaty negotiations and international tax policy initiatives. At the Joint Committee on Taxation, he advised Congress on proposed tax legislation and tax policy matters. He has also testified before the House Small Business Committee on international aspects of tax simplification and reform.

Having advised clients in private practice and worked within the principal federal institutions involved in tax administration and policymaking, Robert brings both practical and governmental perspectives to client matters. Whether advising on a transaction, evaluating a planning opportunity, addressing a compliance issue, or resolving a tax dispute, he helps clients understand not only the technical requirements of the law but also the broader framework in which tax decisions are made.

Robert teaches in the University of California, Irvine Graduate Tax Program and previously taught International Tax Controversies at Georgetown University Law Center. He provides pro bono service through the Public Law Center's Low-Income Taxpayer Clinic in Santa Ana and was recognized as a 2024 Outstanding Volunteer by ONEOC.

Robert is admitted to practice law in California and the District of Columbia.

Government, academy,
and the bar.

Government Experience
  • U.S. Congress Joint Committee on Taxation ·
    Visiting Counsel · 2015
  • U.S. Department of Treasury
    Office of Tax Policy · 2014–2015
  • Internal Revenue Service Large Business & International · 2009–2012
    Small Business / Self-Employed · 2007–2009
  • U.S. House of Representatives Testimony · Small Business Committee · 2016
Teaching & Education
  • UC Irvine Law Graduate Tax Program Adjunct Faculty · Current
  • Georgetown University Law Center Adjunct Professor · Int'l Tax Controversies
  • Harvard Kennedy School Certificate · Comparative Tax Administration
  • Georgetown University Law Center LL.M. Taxation · Certificate in International Tax
  • Chicago-Kent College of Law J.D.
Service & Recognition
  • Federal Bar Association Past Chair · Section on Taxation
  • AICPA International Tax Technical Resource Panel Past Chair
  • Public Law Center · Low-Income Taxpayer Clinic Pro Bono Counsel · Santa Ana
  • ONEOC Outstanding Volunteer 2024
  • Bar Admissions California & District of Columbia

Recent Highlights

04 — Speaking, Writing, Testimony

April 2026

Presenter · American Bar Association

Taxing the Forecast: A Closer Look at Prediction Markets

March 2026

Presenter · California Lawyers Association Corporate and Passthrough Entity Committee

The BBA Regime—Attorneys Working with Accountants to Best Serve Clients

September 2025

Presenter · Internal Revenue Service Nationwide Tax Forum

Representing Businesses with No Records

July 2025

Proposed Changes to the IRS's Streamlined Filing Compliance Procedures

Co-author · Tax Notes Federal & Tax Notes International

2025 · IRS Forum

Representing Businesses with No Records

Presenter · IRS Nationwide Tax Forum

May 2025 · ABA

How to Represent Taxpayers with Differing Beliefs Than Your Own

Moderator · ABA Section of Taxation May Tax Meeting

December 2024

Moderator · Beverly Hills Bar Association

2025 Anticipated U.S. Tax Policies

September 2024

Featured Speaker · IRS Nationwide Tax Forum

Best Practices for Responding to IRS Collection Notices

2024

Outstanding Volunteer Recognition

ONEOC · For Pro Bono Service to Low-Income Taxpayer Clinic

05 — Inquire

For matters that benefit from a careful look.

Office

Robert Russell Tax Law, PC
23807 Aliso Creek Rd
Suite 100
Laguna Niguel, CA 92677

Bar Admissions
California
Washington, DC
Initial Consultation
A first conversation is typically thirty minutes, scheduled by email. Please describe the matter in two or three sentences.