Emin Toro

Emin Toro is a partner in the Washington, D.C., office of Covington & Burling LLP, where he represents and counsels multinational companies in tax controversies. Mr. Toro’s tax controversy experience includes audits, administrative appeals, litigation, as well as advance pricing agreement and competent authority proceedings. He is also a Fellow of the American College of Tax Counsel. Upon graduation from law school, Mr. Toro served as a law clerk to Judge Karen LeCraft Henderson of the U.S. Court of Appeals for the District of Columbia Circuit and to Justice Clarence Thomas of the Supreme Court of the United States. Mr. Toro earned his B.A., summa cum laude, from Palm Beach Atlantic University and his J.D., with highest honors, from the University of North Carolina School of Law, where he was inducted into the Order of the Coif and served as an articles editor of the North Carolina Law Review. Emin Toro’s practice concentrates on the needs of multinational companies, including both tax controversies and counseling. Mr. Toro’s controversy experience includes audits, administrative appeals, litigation, as well as advance pricing agreement and competent authority proceedings. Mr. Toro has handled controversies in a number of subject matter areas, including cross-border trading structures, cost sharing arrangements, income and expense reallocations under Section 482, foreign tax credits, treatment of corporate reorganizations and restructurings, computation of allowable FSC benefits, and allowance of losses on subsidiary stock and debt. Mr. Toro has provided counseling on tax-efficient cross-border distribution structures, cross-border services, cross-border transfer pricing, international asset transfers, and tax optimal corporate structures, as well as acquisitions and dispositions.