Melinda Gammello advises multinational corporations, financial institutions and individuals on a wide range of tax controversy and tax planning matters.
Gammello represents clients in high-stakes and complex tax controversies relating to a variety of issues, including taxation of financial instruments, transfer pricing, international tax issues, income tax treaty disputes and judicial substance doctrines. She also advises on the tax aspects of domestic and cross-border corporate restructurings and other transactions.
Lawdragon Honors
| Honor | Year | Practice |
|---|---|---|
| The 2026 Lawdragon 500 Leading Global Tax Lawyers | 2026 | Tax, Planning, Controversy |
| The Inaugural Lawdragon 500 Leading Global Tax Lawyers | 2025 | Tax, Planning, Controversy |
Gammello’s representative cases include:
- Medtronic, Inc. v. Commissioner (U.S. Tax Court; U.S. Court of Appeals for the Eighth Circuit): One of the most significant transfer pricing disputes with the IRS, involving a second trial in the U.S. Tax Court after the Eighth Circuit’s review and remand. The Tax Court’s 2022 ruling adopted Medtronic’s transfer pricing methodology but made certain adjustments in favor of the IRS.
- Eaton Corp. & Subsidiaries v. Commissioner; Eaton Worldwide LLC, Eaton Holding II S.A. R.L., A Partner Other Than the Tax Matters Partner v. Commissioner (U.S. Tax Court): Several ongoing cases involving significant issues relating to the transfer pricing of various transactions and the taxation and treatment of a partnership for purposes of applying the subpart F provisions of the Internal Revenue Code.
- Commonwealth Bank of Australia v. United States (U.S. Court of Federal Claims): A high-profile dispute involving the U.S. taxation of financial transactions undertaken by the Australian bank.
- Aventis, Inc. and Subsidiaries v. Commissioner (U.S. Tax Court): Ongoing case of first impression challenging the IRS’ determination that a Financial Asset Securitization Investment Trust (FASIT) was invalid.