Leila Carney is Of Counsel in Caplin & Drysdale’s Washington D.C. office, where she has practiced in the Tax Disputes & Tax Litigation Group since she first joined the firm in 2004. She also provides her tax, litigation, and federal law expertise to the Complex Litigation, Criminal Tax & White Collar Defense, Private Client, and Political Law Practices.
Ms. Carney's practice focuses on tax controversy matters and litigation for individual, corporate clients, trusts, and exempt organizations. Ms. Carney has filed petitions in the U.S. Tax Court, and briefs in Federal District Court against the Department of Justice, and represented clients in complex litigation, including financial products and a variety of structures including complex trusts, partnerships, and international holding company structures. She has handled IRS exams, administrative appeals, criminal matters, voluntary disclosures, submitted ruling requests, and served clients with international issues.
Ms. Carney has zealously:
- litigated cases involving captive insurance, conservation easements, and IRS third-party summons;
- defended Puerto Rico residency in IRS audits;
- defended a gift tax return examination involving a high net worth trust structure;
- sought full abatement of civil penalties related to foreign trust reporting, return preparer penalties, and appraiser penalties;
sought a full allowance of large deductions in IRS “hobby loss” and “cost segregation” examinations, and a refund of Net Investment Income Tax (NIIT);
- coordinated reinstatement of an inadvertent S-corp termination; and
- sought “9100” relief for missed “check the box” elections;
- advised on presidential ballot access law and procedure.
Ms. Carney has represented clients in sensitive audits with a risk of allegations of tax fraud or securities fraud. She has also assisted clients in responding to subpoenas for civil and criminal proceedings, as well as clients who are themselves under investigation.
Ms. Carney has protested civil penalties including those specific to foreign bank accounts, trusts, and gifts. She has represented clients on collection matters such as offers-in-compromise, lien releases, installment agreements, and innocent spouse petitions. Ms. Carney is also experienced in obtaining tax-exempt status for public and private charities, in addition to trade associations.
Additionally, Ms. Carney has advised clients on creating business practices that are in compliance with changing regulatory regimes, including those governing taxpayer consent to disclosure of tax return information, foreign bank account reporting (FBAR), and nonqualified deferred compensation plans. She has assisted clients in submitting comments on proposed regulations.
Admissions & Education
Bar & Court Admissions
- District of Columbia
- U.S. Tax Court
J.D., University of Virginia School of Law, 2004
B.A., The College of William & Mary, 2001
Professional Activities & Affiliations
Other Professional Affiliations
Member, American Bar Association, Section of Taxation
Member, District of Columbia Bar
Newsroom & Publications
- 07.17.2023 | Tax Notes
- 11.12.2021 | Captive Insurance Times
- 11.10.2021 | Bloomberg Tax
- 03.08.2019 | Caplin & Drysdale
- Caplin & Drysdale Welcomes Former IRS Nonprofit Senior Technical Adviser and Strengthens Tax Controversies and Private Client Groups01.16.2018 | Caplin & Drysdale, Chartered
Publications & Alerts
- 07.17.2023 | International Tax Alert
- 05.08.2023 | Procedurally Taxing
- Evaluating and Improving The Taxpayer Rights Provisions of the IRS Restructuring and Reform Act of 199803.16.2023 | Pittsburgh Tax Review
- 03.10.2023 | International Tax Alert
- 02.17.2023 | International Tax Alert
- 02.01.2023 | International Tax Alert
- 01.01.2023 | Practical Tax Strategies Thomson Reuters , Article
- IRS to Issue Proposed Regulations Identifying Syndicated Conservation Easements as Listed Transactions12.07.2022 | Tax Alert
- 07.06.2020 | Tax Alert