Lawrence Hill
Partner
Overview
Larry Hill is a tax attorney in Holland & Knight's New York office. Mr. Hill focuses his practice on the resolution of complex domestic and cross-border civil tax disputes through the IRS administrative process and litigation.
Mr. Hill represents numerous financial institutions, multinational corporations, international accounting firms, partnerships, private foundations and high-net-worth individuals in domestic and international tax-related disputes. He also represents clients in high-profile white collar investigations, criminal cases and congressional investigations.
Mr. Hill has litigated some of the most significant civil and criminal tax cases in U.S. history. He was lead counsel for the sponsor/partner in the seminal taxpayer victory in Cross Refined Coal, LLC v. Commissioner, 45 F.4th 150 (D.C. Cir. 2022), where the U.S. Court of Appeals for the District of Columbia Circuit found that a tax credit partnership was a bona fide partnership for tax purposes and was imbued with economic substance, despite the lack of any pre-tax profit potential. Mr. Hill represented the American Tax Policy Institute on its amicus brief to the U.S. Supreme Court in Moore v. U.S., perhaps the most significant tax case in the last 50 years. Additionally, Mr. Hill was counsel for the American College of Tax Counsel on its amicus brief to the U.S. Supreme Court in support of an appellant law firm in the In re Grand Jury case – a landmark attorney-client privilege case.
Mr. Hill is one of the nation's preeminent tax litigators and first-chair trial lawyers. The New York Times has called him "a leading member of the American Tax Bar" and "a litigator who is known for aggressively defending clients before the IRS over tax matters." Chambers USA praises him as "technically superb and so knowledgeable, he knows all the details and brings a lot of gravitas." In addition, The Legal 500 ranks Mr. Hill in its Hall of Fame for Contentious Tax, stating:
Lawrence Hill has an exceptional ability to distil highly complex tax issues into clear, actionable guidance. He ensures clients understand how his advice fits within the broader strategic picture, reducing pressure on in-house teams. Rather than simply reciting the law, he takes time to explain context and objectives, delivering thoughtful solutions under tight timelines while remaining engaged and accessible throughout.
Prior to joining Holland & Knight, Mr. Hill was a senior partner and head of tax controversy and litigation at several major international law firms, as well as the co-global head of the financial institutions practice at one of those firms. Earlier in his career, Mr. Hill was a trial attorney and national tax shelter project attorney with the IRS Office of Chief Counsel and a Special Assistant U.S. Attorney with the U.S. Attorney's Office in Washington, D.C. The IRS honored him twice with special achievement awards for his work as a top trial attorney in the country. Mr. Hill also previously served as assistant general counsel to a Big Four accounting firm.
Representative Experience
- Lead partner for a bank in the largest criminal tax investigation in U.S. history, resulting in one of the few non-prosecution agreements
- Lead partner in the U.S. Senate Permanent Subcommittee on Investigations hearings in its IRS promoter penalty investigation, multiple federal appeals and more than 1,000 civil lawsuits and arbitrations involving claims by high-net-worth customers
- Lead partner representing a global financial services company in a $1 billion IRS examination involving the deductibility of settlements to government-sponsored enterprises and regional Federal Reserve Banks, which resulted in close to a full IRS concession
- Lead partner in the representation of the Saudi royal family in a criminal tax investigation and IRS civil examination involving Swiss and Bahamian financial institutions
- Lead partner in many of the largest IRS examinations involving a variety of financial products and structured transactions
- Advised nine prominent, international financial services companies in IRS examinations and/or IRS Appeals involving complex structured financial products and risk management-related matters
- Advised three prominent, international financial services companies and a number of other financial institutions in IRS procedural and audit-related matters
- Advised a Swiss bank as independent examiner in conjunction with the U.S. Department of Justice's Swiss Bank Settlement Program, resulting in a non-target letter
- Advised a hedge fund in a German criminal tax investigation and a Swiss tax investigation involving so-called "cum ex trades"
- Advised one of the world's largest banking and financial services organizations; served as lead counsel to the organization's witnesses in several criminal trials and DOJ investigations involving unreported foreign bank accounts of its customers
- Served as lead counsel to a major South American financial institution in a voluntary disclosure proceeding and IRS examination
- Advised a leading global financial services firm as lead appellate counsel in U.S. Court of Appeals for the Third Circuit cases involving tax penalties
- Advised a government-sponsored enterprise as a tax litigation consultant in its seminal hedging case victory before the U.S. Supreme Court
- Advised one of America's largest private companies after trial and successfully mediated a multimillion-dollar federal district court decision pending Third Circuit appeal
- Advised a board chair of two major public corporations; served as lead trial attorney in a multimillion-dollar gift tax case in the U.S. Tax Court
- Advised the CEO of one of the world's largest hedge funds in successfully quashing a Tax Court subpoena for his testimony
- Advised numerous high-net-worth individuals in voluntary disclosures in conjunction with the IRS' offshore voluntary disclosure initiative
- Served as lead counsel to 30 family trusts in a transferee liability case involving a leading telecommunications service provider
- Representing a large microcaptive insurance company in an IRS promoter penalty investigation and related tax cases involving the IRS' position that the insurance does not qualify as insurance and that the arrangements are shams
- Advised a prominent mono-line insurance financial services holding company; served as lead partner in its bankruptcy tax litigation in U.S. Bankruptcy Court for the Southern District of New York, where the IRS sought repayment of an $800 million "quickie" tax refund received by the debtor prior to bankruptcy; the highly successful settlement included an 87 percent concession by the IRS and U.S. Department of Justice (DOJ) after extensive fact and expert discovery and lengthy mediation; the case of first impression involved the tax treatment of credit default swaps, and the settlement enabled the company to come out of bankruptcy
- Advised a major telecommunications company in the IRS' examination of its captive insurer
- Advised a Fortune 500 American multinational insurance company and financial services organization in disputes with the IRS
- Advised one of the world's largest insurance, banking and financial conglomerates in the review of tax structured insurance products
- Advised a dozen Fortune 500 corporations in the IRS' challenge and litigation of leveraged corporate-owned life insurance
- Advised several financial institutions in advice pertaining to bank-owned life insurance
- Represented one of the largest life insurance companies in the U.S. in civil litigation and insurance insolvency proceedings involving its liquidation
- Advised a multinational conglomerate in a multibillion-dollar IRS examination involving a so-called inversion transaction, which resulted in almost a full concession by the IRS
- Advised one of the world's largest pharmaceutical companies in the IRS' challenge of the tax status of a multibillion-dollar merger
- Advised a global leading provider of diagnostic information services; served as lead trial attorney in a tax refund suit of first impression in the U.S. Court of Federal Claims involving the deductibility of penalties under the False Claims Act (FCA)
- As former assistant general counsel with a Big Four accounting firm, responsible for national litigation of tax malpractice suits, threatened litigation, government investigations, disciplinary investigations and issues pertaining to tax opinions, tax engagements, IRS procedural matters such as 9100 relief and standards of tax practice; responsibilities included trying cases as well as supervision of outside counsel in trials of cases
- Represented four international accounting firms in IRS promoter penalty investigations, including summons and John Doe summons defense, IRS interviews, and technical and procedural issues, as well as in some instances defense of civil lawsuits brought by high-net-worth individuals; also represented international banks, insurance companies and law firms in IRS tax shelter investigations that included an investigation by the U.S. Senate Permanent Subcommittee on Investigations, the largest criminal tax investigation in U.S. history, IRS promoter penalty investigations and more than 1,000 civil suits involving high-net-worth individuals
- Represented an international accounting firm in two independent counsel investigations, one of which included the quashing of a grand jury subpoena seeking information outside the scope of the independent counsel's investigation
- Represented witnesses of an international accounting firm before the grand jury and at trial in the Bank of Credit and Commerce International investigation, as well as in other grand jury investigations
- Represented tax and actuarial partners and principals of an international accounting firm before the director of practice of the U.S. Department of the Treasury with respect to disciplinary claims
- Represented a number of partners of an international accounting firm before state boards of accountancy and the American Institute of Certified Public Accountants, as well as in defense of return preparer penalties
- Provided comments to Senate Finance Counsel related to the enactment of Internal Revenue Code Section 7525 and successfully litigated a seminal case applying the joint defense privilege to Section 7525
- Advised a coalition of the Big Four accounting firms and the world's largest member association representing the accounting profession in successful unauthorized practice of law litigation before the Supreme Courts of Florida and South Carolina
- Served as principal drafter for the American Bar Association (ABA) of comments pertaining to Circular 230 Rules of Practice before the IRS
- Represented a coalition of corporations related to IRS proposals pertaining to Schedule UTP
- Testified before the ABA Commission on Multidisciplinary Practice
Credentials
- The George Washington University Law School, LL.M., Taxation
- The George Washington University Law School, J.D.
- State University of New York at Binghamton, B.A., with highest honors
- New York
- U.S. Supreme Court
- U.S. District Court for the Southern District of New York
- U.S. District Court for the Eastern District of New York
- U.S. District Court for the Northern District of Illinois
- U.S. District Court for the District of Colorado
- U.S. Tax Court
- U.S. Court of Federal Claims
- U.S. Court of Appeals for the Second Circuit
- U.S. Court of Appeals for the Third Circuit
- U.S. Court of Appeals for the Fifth Circuit
- U.S. Court of Appeals for the Sixth Circuit
- U.S. Court of Appeals for the Seventh Circuit
- U.S. Court of Appeals for the Ninth Circuit
- U.S. Court of Appeals for the District of Columbia Circuit
- U.S. Court of Appeals for the Federal Circuit
- American Tax Policy Institute, Trustee
- American College of Tax Counsel, Fellow; Amicus Curiae Committee
- American Bar Association (ABA), Section of Taxation, Court Procedure and Practice Committee, Former Chair; Appointments to the Tax Court Committee; Litigation Section, Amicus Curiae Briefs Committee
- American Bar Foundation, Life Fellow
- Wall Street Tax Association
- The Tax Club
- Focus on Tax Controversy and Litigation Newsletter, Editor
- Law Firm Antiracism Alliance (LFFA), Tax Working Group
- Law360 Editorial Board Member, Tax Authority Federal, 2025
- Journal of Tax Practice & Procedure, Advisory Board
- Chambers USA – America's Leading Business Lawyers guide, Tax: Controversy, 2006-2026
- The Legal 500 USA, Hall of Fame, Tax – U.S. Taxes: Contentious, 2008-2026
- The Best Lawyers in America guide, Lawyer of the Year, Litigation and Controversy – Tax, 2022
- The Best Lawyers in America guide, Litigation and Controversy – Tax, 2010-2026
- New York Super Lawyers magazine, Tax, 2006-2026
- Leading Global Tax Lawyers, Lawdragon 500, 2025
- Martindale-Hubbell AV Preeminent Peer Review Rated, 2000-Present
- Who's Who Legal: Corporate Tax
- International Tax Review World Tax, Tax Controversy
- World Tax: The Comprehensive Guide to the World's Leading Tax Controversy Advisers