Royce Tidwell represents multinational corporations, financial institutions and individuals through the full range of federal and state income tax controversy proceedings, including audits, administrative appeals and judicial proceedings.
Tidwell focuses on complex tax controversies in connection with transfer pricing, financial products, foreign tax credits, economic substance and business purpose, debt-equity, cross-border withholding and a variety of partnership issues.
Lawdragon Honors
| Honor | Year | Practice |
|---|---|---|
| The 2026 Lawdragon 500 Leading Global Tax Lawyers | 2026 | Tax, Controversy, Litigation |
| The Inaugural Lawdragon 500 Leading Global Tax Lawyers | 2025 | Tax, Controversy, Litigation |
Ongoing cases include representing:
- Amgen Inc. in connection with a significant transfer pricing case concerning the licensing of complex biopharmaceutical products from the U.S. to Amgen’s Puerto Rican subsidiary. Amgen Inc. & Subsidiaries v. Commissioner (U.S. Tax Court)
- Liberty Global in two lawsuits challenging the validity of regulations issued under Section 245A of the Internal Revenue Code, a statute added as part of the Tax Cuts and Jobs Act that allows a deduction for certain dividends received by U.S. shareholders. Liberty Global, Inc. v. United States (U.S. Court of Appeals for the Tenth Circuit) industry. Newell Brands Inc. & Subsidiaries v. Commissioner (U.S. Tax Court)
- Altria Group Inc. in a case involving a $105.7 million tax refund stemming from Altria’s equity interest in beverage company Anheuser-Busch InBev SA/NV. Altria Group, Inc. v. United States (U.S. District Court for the E.D. Virginia)
Recently completed cases include:
- Altria Group Inc. in a victory in its dispute with the Michigan Department of Treasury regarding the constitutionality of taxing Altria’s extraterritorial investment gains. Philip Morris USA v. Department of Treasury (Michigan Court of Claims)
- Agero Holdings Inc. in a victory in a case involving the IRS’ determination of subsidiaries’ status as insurance companies. IRS conceded in full. Sirius XM Connected Vehicle Services Holdings Inc. v. Commissioner (U.S. Tax Court)
- Amazon.com, Inc. in a victory in one of the largest transfer pricing cases in decades and the first involving e-commerce. Amazon.com, Inc. v. Commissioner (U.S. Tax Court; U.S. Court of Appeals for the Ninth Circuit)
- Athene USA Corp. in reaching a global settlement with the IRS and DOJ of a refund case involving the IRS’ disallowance of a change in method of accounting. Athene USA Corp. v. United States (U.S. District Court, Southern District of Iowa)