Clint Massengill is Special Counsel in the Tax Practice Group and a member of the firm's Litigation department. His practice is focused on federal tax controversies involving questions of federal tax law and procedure. He joined Cooley in 2013.
Mr. Massengill's experience includes several years as senior in-house tax counsel at a major international insurance company, a previous tenure at Cooley and its predecessor firm, Kronish Lieb Weiner & Hellman, and owning a general litigation practice. In his recent position as in-house counsel, he advised his company on a wide range of tax controversy matters, including directing complex tax refund cases in federal court, managing various IRS audits, developing and implementing audit strategy, making use of alternative dispute procedures, enhancing a diverse range of departmental policies and processes, and assisting in the development and implementation of a global tax controversy function. Those experiences have greatly enhanced his ability to counsel corporate clients.
Mr. Massengill, who has litigated matters in state and federal courts, has advised Fortune 500 clients in a variety of industries, including banking, insurance, energy, manufacturing, and oil and gas. Some of the significant issues on which he has advised clients include:
the creditability of foreign taxes paid in connection with structured, cross-border transactions;
transfer pricing;
tax shelter/economic substance challenges by the IRS;
summons enforcement proceedings;
conflicts of laws in the context of cross-border discovery;
deductible/capitalization challenges by the IRS, including the deductibility of environmental cleanup costs and of merger breakup fees;
accounting method challenges by the IRS;
debt/equity challenges by the IRS;
issues arising under subchapter L; and
Tax Shelter Registration/List Maintenance examinations.
Mr. Massengill earned his master of laws (LLM) in taxation from New York University and his law degree (JD) from the University of North Carolina School of Law. He earned his BA (Political Science) from Davidson College.
Mr. Massengill is a member of the State Bar of New York and the State Bar of North Carolina. He is also a member of the American Bar Association, Tax Section.
