Overview
Larry Hill is a tax partner who heads the firm's tax controversy practice. He is one of the nation's preeminent tax litigators and first-chair trial lawyers who focuses his practice on the resolution of complex domestic and cross-border civil tax disputes through the IRS administrative process and litigation.
The NY Times has called Larry "a leading member of the American Tax Bar" and "a litigator who is known for aggressively defending clients before the IRS over tax matters." The Legal 500 ranks Larry in their Hall of Fame for Contentious Tax and refers to Larry as "a superb lawyer and one of the leaders of the tax controversy bar," Chambers USA praises him as "technically superb and so knowledgeable, he knows all the details and brings a lot of gravitas."
He represents numerous financial institutions, multinational corporations, international accounting firms, partnerships, private foundations, and high net worth individuals in domestic and international tax-related disputes. He also represents clients in high-profile white-collar investigations, criminal cases, and congressional investigations.
Larry has litigated some of the most significant civil and criminal tax cases in U.S. history. Larry was lead counsel for the sponsor/partner in the seminal taxpayer victory in Cross Refined Coal, LLC v. Commissioner, 45 F.4th 150 (D.C. Cir. 2022), where the US Court of Appeals for the DC Circuit found that a tax credit partnership was a bona fide partnership for tax purposes and was imbued with economic substance despite the lack of any pre-tax profit potential. Larry represented the American Tax Policy Institute on its amicus brief to the US Supreme Court, in Moore v. U.S., perhaps the most significant tax case in the last fifty years. Additionally, Larry was counsel for the American College of Tax Counsel on their Amicus Brief to the US Supreme Court, in support of Appellant law firm, in the In re Grand Jury case—a landmark attorney-client privilege case.
Prior to joining Steptoe, he served as a senior partner and global head of tax controversy and litigation at several major international law firms, as well as the co-global head of the financial institutions practice at one of those firms. Earlier in his career, Larry was a trial attorney and National Tax Shelter Project Attorney with the Office of Chief Counsel of the Internal Revenue Service and a Special Assistant United States Attorney with the United States Attorney’s Office in Washington, DC. The IRS honored him twice with Special Achievement Awards for his work as a top trial attorney in the country. Larry also previously served as Assistant General Counsel to a "Big Four" accounting firm.
- New York
- US Supreme Court
- US District Court, Southern District of New York
- US District Court, Eastern District of New York
- US District Court, Northern District of Illinois
- US District Court, District of Colorado
- US Tax Court
- US Court of Federal Claims
- US Court of Appeals, Second Circuit
- US Court of Appeals, Third Circuit
- US Court of Appeals, Fifth Circuit
- US Court of Appeals, Sixth Circuit
- US Court of Appeals, Seventh Circuit
- US Court of Appeals, Ninth Circuit
- US Court of Appeals, District of Columbia Circuit
- US Court of Appeals, Federal Circuit
- LL.M., The George Washington University, 1989
- J.D., The George Washington University, 1984
- B.A., Binghamton University, 1981
Areas of Work
Speaking Engagements
- "Estate Planning: Attorney Client Privilege, Work Product Doctrine, and IRC Section 7525," myLawCLE, February 6, 2025
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"Preparing for 2025: Understanding Upcoming Tax Changes," Federal Bar Association, August 16, 2024
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"Gen AI & Tax: Practical Applications," Wall Street Tax Association Seminar, April 17, 2024
- "Moore Musings: Examining the Possible Outcomes of Moore v. United States," Federal Bar Association's 2024 Tax Law Conference, March 1, 2024
- "Estate Planning: Attorney client privilege, work product doctrine, and IRC Section 7525," Federal Bar Association, November 28, 2023
- "The Ethics and Best Practices Involving the Use of Generative AI in Tax Practice," Wall Street Tax Association Seminar, September 12, 2023
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"Attorney Client Privilege in International Estate Planning Matters," Practising Law Institute's International Estate & Tax Planning 2023, May 19, 2023
- "Mid-Term and Presidential Elections Impacts on Tax Legislation in the US and Brazil," Bichara Advogados Webinar, December 12, 2022
- "Seminar on Tax Insurance," Wall Street Tax Association Seminar, December 7, 2022
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"Implications of Recent Decisions on Agencies' Regulatory Power," Wall Street Tax Association 2022 Fall Tax Conference, November 22, 2022
- "Best Practices for Preparing for an IRS Audit," Tax Executives Institute's Virginia Chapter, April 28, 2022
- "The New International Tax Controversy Paradigm," NY Tax Club Presentation, November 10, 2021
- "Ethics in Tax Controversy and Administrative Practice," Wall Street Tax Association Seminar, November 3, 2021
- "International Tax Audits: Hiding Income and Assets Internationally from Tax Authorities," 17th Annual University of San Diego School of Law International Tax Institute, October 28, 2021
- "Death and Taxes: What is Certain Today?," Estate Planning Council of NYC, October 21, 2021
- "John Doe Summonses: The Tool to Close the Crypto Compliance Gap and Implications for Privilege," Virtual 2021 Fall ABA Tax Section Meeting, Administrative Practice and Court Procedure & Practice Committees, September 22, 2021
News & Publications
Media Mentions
February 24, 2025
Focus on Tax Controversy Newsletter
Supreme Court Opens the Doors to Federal Court Challenges to Treasury and IRS Regulations
July 15, 2024
Media Mentions
July 8, 2024
Media Mentions
Bloomberg Tax Quotes Larry Hill in Article About Corporate Alternative Minimum Tax
April 15, 2024
Focus on Tax Controversy Newsletter
Employee Retention Credit Voluntary Disclosure Plan Announced
January 10, 2024
By: Lawrence Hill
Media Mentions
Bloomberg Law Quotes Larry Hill on Book Minimum Tax Effect on Some Federal Rescue Tools
January 9, 2024
Media Mentions
Law360 Quotes Lawrence Hill in 2024 Federal Tax Cases to Watch Article
January 1, 2024
Client Alerts
Employee Retention Credits (ERCs) Voluntary Disclosure Program
December 26, 2023
By: Lawrence Hill
Resources
Focus on Tax Controversy Newsletter
Ninth Circuit Appropriately Revises Its Opinion in In re Grand Jury
March 2022
By: Lawrence Hill
Focus on Tax Controversy Newsletter
Sixth Circuit Upholds Conservation Easement Regulation
March 2022
By: Lawrence Hill
Focus on Tax Controversy Newsletter
January 1, 2022
By: Lawrence Hill, Caitlin R. Tharp, Nick Sutter
Focus on Tax Controversy Newsletter
November 15, 2021
By: Lawrence Hill, Lisa M. Zarlenga, Nick Sutter
Focus on Tax Controversy Newsletter
August 19, 2021
Events
Seminars & Events
Year End Tax Conference and Celebration
December 6, 2021
Speakers: Alan Cohn, Micah S. Green, Zvi Hahn, Lawrence Hill, Aaron P. Nocjar, Caitlin R. Tharp, Beth D. Tractenberg, Amanda Pedvin Varma, Philip R. West, Lisa M. Zarlenga
Webinars
The IRS on Steroids: Audits of Wealthy Taxpayers
October 5, 2021
Speakers: Lawrence Hill, Beth D. Tractenberg
Noteworthy
- Chambers USA, Tax: Controversy, Nationwide, 2008-2024
- Legal 500, US Taxes: Contentious, 2008-2024
- Best Lawyers in America, Lawyer of the Year, Litigation & Controversy, Tax, 2022
- Best Lawyers in America, Litigation & Controversy, Tax, 2010-2025
- Super Lawyers, New York, Tax, 2006-2024
- ALM Media and Martindale-Hubbell, Top Rated Litigator, 2022
- Martindale-Hubbell, Top Rated Lawyer, 2022
- Martindale-Hubbell, Preeminent Attorney, 2000-2022
- Who’s Who Legal, Corporate Tax, 2020
- International Tax Review, Leader in US Tax Controversy
- World Tax: The Comprehensive Guide to the World’s Leading Tax Controversy Advisers
Professional Affiliations
- Trustee, American Tax Policy Institute
- Fellow, American College of Tax Counsel (Member of the Amicus Curiae Committee)
- Former Chair, Court Procedure and Practice Committee of the Tax Section of the American Bar Association
- Life Fellow, American Bar Foundation
- Member, Wall Street Tax Association
- Member, The Tax Club
- Editor, Focus on Tax Controversy and Litigation Newsletter
- Member, Law Firm Antiracism Alliance (LFFA), Tax Working Group
- Board Member, Law360's 2025 Tax Authority Federal Editorial Board