With more than four decades of tax controversy experience representing Fortune 500 multinationals, Robert Carney joined Caplin & Drysdale in November 2017 as Senior Counsel. Mr. Carney offers guidance to clients on managing potential corporate tax risks, implementing best practices for corporate tax planning, and advocating for their rights in tax litigation and administrative tax controversies.
Before joining Caplin & Drysdale, Mr. Carney was Senior Counsel to Florida Power & Light Co. (a subsidiary of NextEra Energy, Inc.) for more than nine years. In this role, Mr. Carney was lead litigation counsel in the U.S. Tax Court and U.S. district courts, as well as in proceedings before the IRS Office of Appeals. He also advised on all aspects of tax procedure in IRS audits and tax planning.
Mr. Carney has represented corporate entities before the Internal Revenue Service, the Department of Justice, and in federal courts across the nation. Illustrations of his work for clients include:
- resolving IRS disputes involving R&D credits;
- resolving IRS disputes on transfer pricing issues;
- advising and resolving disputes involving capitalization and tax accounting issues; and
- advising on procedural issues related to transactions, transactional planning, and return filing requirements.
Prior to his tenure at Florida Power & Light/NextEra Energy, Mr. Carney was a tax partner in the Washington offices of several multinational law firms and was also the National Director of Tax Controversy Services in the National Tax Office of Ernst & Young. He also served as a Trial Attorney with the U.S. Department of Justice, Tax Division, where he tried cases in U.S. district courts throughout the country.
Mr. Carney is currently an Adjunct Professor of the Master of Tax Program at the Georgetown University Law Center, where he has taught tax practice and procedure (litigation and administrative) for over 30 years.
Admissions & Education
Bar & Court Admissions
- District of Columbia
- U.S. Supreme Court
- U.S. Tax Court
- U.S. District Court, District of Columbia
- U.S. Court of Federal Claims
- U.S. Court of Appeals, District of Columbia Circuit
- U.S. Court of Appeals, Federal Circuit
- U.S. Court of Appeals, Second Circuit
- U.S. Court of Appeals, Eleventh Circuit
J.D., Georgetown University Law Center, 1972, Editor, Georgetown Law Journal
B.A., Northwestern University, 1969
Professional Activities & Affiliations
Master, Inn of Court, U.S. Tax Court
Member, U.S. Patent and Trademark Office
Newsroom & Publications
- 12.11.2020 | The Federalist Society's Teleforum
- 01.08.2020 | The Federalist Society's Teleforum
- Robert Carney Discusses IRS Guidance and Regulations on Federalist Society WebinarAre IRS Defenses Crumbling? | Virtual
- Robert Carney Presents on BBA Partnership Audit Rules at D.C. Bar Program11.17.2021
Publications & Alerts
- 07.17.2023 | Tax Notes Federal Letter to the Editor
- 04.17.2023 | Tax Notes Federal, Article
- 05.26.2021 | Law360, Article