Leila Carney is Of Counsel in Caplin & Drysdale’s Washington D.C. office, where she has practiced in the Tax Controversies Group since she first joined the firm in 2004.
Ms. Carney's practice focuses on tax controversy matters for individual, corporate clients, trusts, and exempt organizations. She has handled IRS exams, administrative appeals, voluntary disclosures, and submitted ruling requests. Ms. Carney has filed petitions in the U.S. Tax Court, and briefs in Federal District Court against the Department of Justice.
- handled an IRS third-party summons in Federal District Court;
sought a full allowance of large deductions in IRS “hobby loss” examination; and
- coordinated reinstatement of an inadvertent S-corp termination.
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
- 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