Andrew has significant tax experience in a variety of government and private practice roles, and is nationally recognized for his work in tax-related disputes, litigation and investigations. He advises on a comprehensive range of tax controversy matters with particular focus on tax litigation, IRS appeals, exempt organizations, Administrative Procedure Act issues and transfer pricing issues. His clients span a variety of industries including global nonprofits, private equity, technology and global financial institutions.
Andrew’s government experience includes most recently serving as Senior Tax Counsel in the Biden White House, advising on the full spectrum of federal taxation issues. Earlier in his career, he served as a trial attorney in the Department of Justice Tax Division and was selected to serve in a tax advisory role in the Obama White House.
Experience
Prior to joining Willkie, Andrew was counsel at an international law firm.
Andrew previously served as Senior Tax Counsel in the Biden White House, where he advised on all manner of issues relating to federal taxation, and oversaw the vetting and Senate confirmation process. Previously, he served as a trial attorney in the Department of Justice Tax Division, litigating a range of civil tax matters involving tax-exempt organizations, tax refund suits, matters concerning the Administrative Procedure Act and transfer pricing disputes. While at the DOJ, Andrew was also detailed to the Obama White House, where he served in a similar tax advisory role.
Prior to his DOJ tenure, Andrew was a Presidential Management Fellow, where he split his time between the IRS, where he issued rulings and guidance on tax-exempt organizations, and the U.S. Attorney’s Office for the District of Columbia, representing the United States in complex civil litigation.
- Outstanding Attorney Award, U.S. Department of Justice, Tax Division, 2013
- Younger Federal Lawyer Award, Federal Bar Association, 2012
- Fellow, American College of Tax Counsel
- Fellow, Foundation of the Federal Bar
- Sections-Division Council Member, Federal Bar Association
- National Chair, Federal Bar Association Section on Taxation, 2013/2014
- Co-Author, “The Corporate AMT’s Crypto Problem Has Constitutional Hazards,” Tax Notes Federal, 2024
- Author, “Corporate AMT’s Shadow Grows as FASB Goes Mark-to-Market,” Tax Notes Federal, 2024
- Co-Author, “The IRS and America’s Longest Running ADR Program,” The Federal Lawyer, 2016
- Author, “The IRS's Use of Secret Subpoenas,” The Federal Lawyer, 2016
- Author, “Bankruptcy Tax Litigators: The Unicorns of Federal Tax Litigation,” The Federal Lawyer, 2014
- Author, “Choose, but Choose Wisely: Designating a Partial Federal Tax Payment,” The Federal Lawyer, 2013
- Varian Medical Systems v. Commissioner, 163 T.C. No. 4 (2024): in the first Tax Court case to apply the Supreme Court's new standard from Loper Bright Enterprises v. Raimondo regarding agency deference, the Court ruled a federal regulation was invalid as it impermissibly overrode the clear statutory language and effective dates in the Tax Cuts and Jobs Act of 2017.
- In a lengthy trial decided in the US Court of Federal Claims in 2023, the plaintiff, a leading global bank, was awarded a federal tax refund of $183 million plus interest following the government’s breach of contract.
*Andrew advised on some of these matters prior to joining Willkie.
Credentials
Education
Georgetown University Law Center, LL.M., 2010 American University, J.D., 2008 University of Virginia, B.A., 2002