Adjunct Professor Henry Cheng is an associate at DLA Piper LLP (US). He focuses his practice on tax controversy and litigation as well as international tax planning and operational structuring. Professor Cheng represents clients in all aspects of complex civil tax disputes at the federal, state, and local levels.
In federal civil tax controversy matters, Professor Cheng represents clients in the private letter ruling process, in IRS audits, in protests to the IRS Appeals Office, and in litigation in the United States Tax Court. Many of these matters involve international tax issues, such as sourcing of income, anti-deferral regimes, foreign tax credits, transfer pricing, and treaty issues. Professor Cheng also has experience in collection disputes involving Collection Due Process (CDP) hearings and lien priority and levy disputes.
In state and local civil tax controversy matters, Professor Cheng represents clients in tax disputes with state and local taxing jurisdictions throughout the United States. In those matters, he represents clients in audits involving sales and use, transient occupancy, payroll/unemployment taxes, as well as in audits involving residency and income allocation issues. Professor Cheng also represents clients in tax refund actions in state courts.
Professor Cheng was a law clerk to the Honorable David Laro of the United States Tax Court. As Judge Laro’s only law clerk, Professor Cheng was actively involved in case and trial management and oversaw pre-trial and discovery practice as well as motion practice under the U.S. Tax Court Rules of Practice and Procedure, modeled after the Federal Rules of Civil Procedure with rules unique to practicing before the U.S. Tax Court.
Professor Cheng received his LL.M. in taxation from New York University School of Law. He received his J.D. magna cum laude from University of California Hastings College of the Law, where he was elected to the Order of the Coif.