Raj Madan concentrates in the area of federal tax controversy and litigation. Mr. Madan has represented clients in a variety of industries, including financial services, pharmaceuticals and manufacturing, in all stages of IRS administrative practice, federal district court litigation and tax court litigation. His experience includes a wide range of complex tax issues, including foreign tax credits, structured finance, transfer pricing, cross-border withholding, life insurance, investment tax credits and the business purpose doctrine. Prior to joining Skadden, Mr. Madan was a partner at another global law firm. He previously served as a trial attorney for the Internal Revenue Service, Manhattan District, where he was a three-time recipient of the Chief Counsel’s Special Act Award. Noted by Chambers USA: America’s Leading Lawyers for Business as being “fantastic,” “strategic, creative and committed to the client” and “one of the best of the next generation,” Mr. Madan repeatedly has been selected for inclusion in that publication, as well as in The Best Lawyers in America and The Legal 500 U.S. He was profiled in an article by The American Lawyer (“Rough Crossing”), which highlighted prominent litigators who have made a seamless transition from public to private practice. Mr. Madan’s recent cases include: Santander Holdings USA, Inc. v. United States, (U.S. District Court, Massachusetts). Pending following the trial court’s decision on partial summary judgment regarding an economic substance issue in a case involving foreign tax credits. Salem Financial, Inc. v. United States (BB&T), (Court of Federal Claims; Federal Circuit). Trial court decision in the government’s favor in an IRS challenge to a financing transaction involving foreign tax credits. Lehman Brothers Holdings Inc. v. United States (U.S. District Court, S.D.N.Y.). Upcoming trial scheduled for a case involving treaty interpretation. Representative cases in which Mr. Madan has served as a principal participant prior to joining Skadden include: The Dow Chemical Company v. United States (U.S. District Court, Michigan; 6th Circuit). Involved corporate-owned life insurance and economic substance. GlaxoSmithKline Holdings (Americas) Inc. v. Commissioner (Tax Court). Involved transfer pricing. Nestle Holdings, Inc. v. Commissioner (Tax Court). Represented the IRS in a matter involving transfer pricing and valuation. Riggs Nat’l Corp. and Subsidiaries v. Commissioner (Tax Court). Represented the IRS in a matter involving foreign tax credits.
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