April 2026
Presenter · American Bar Association
Taxing the Forecast: A Closer Look at Prediction Markets
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
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.
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:
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:
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.
April 2026
Taxing the Forecast: A Closer Look at Prediction Markets
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ONEOC · For Pro Bono Service to Low-Income Taxpayer Clinic
Robert Russell Tax Law, PC
23807 Aliso Creek Rd
Suite 100
Laguna Niguel, CA 92677