John Barry

Creatively solving high-stakes tax controversy matters 

John Barry focuses his practice on taxation and mergers and acquisitions (M&A) involving both public and private companies. He concentrates on:

• Tax controversy matters, including complex, multi-million-dollar disputes before federal, state and local taxing authorities
• Taxable stock and asset sales and purchase transactions
• Tax-free reorganizations and spin-offs
• Partnership transactions, including the formation and structuring of private equity funds
• Comprehensive general tax counsel

Clients turn to John for solutions to tax problems they thought difficult, if not impossible, to resolve. Bringing extensive experience in tax matters along with a fresh look and creativity to his examination of a client’s tax problems, John develops solutions tailored to a client’s long-term business objectives.

John is a former chair of the Wisconsin State Bar tax section.

• Defending clients in tax controversy matters before the Internal Revenue Service, Wisconsin Department of Revenue and other state taxing entities.
• Resolving administrative and judicial disputes with taxing authorities, including the Internal Revenue Service, Wisconsin Department of Revenue and various state and local taxing authorities.
• Negotiating voluntary disclosure agreements with various state taxing authorities to obtain significant tax savings for clients.
• Representing clients in disclosing their foreign financial accounts to the IRS.
• Providing tax opinions to clients in connection with tax-free reorganizations and other M&A transactions.
• Representation of investment funds and investors in private placement investments in limited partnerships and limited liability companies.
• Consulting on a variety of federal, international, state and local tax planning opportunities for clients.
• Advising on applications for private letter rulings from the Internal Revenue Service.

• Successfully defended Fortune 100 global equipment manufacturer in Wisconsin Court of Appeals against Wisconsin Department of Revenue's effort to tax dividends received from a foreign subsidiary. The court decision established that Wisconsin’s dividends received deduction is not limited to dividends received from entities that are legally formed as corporations and is instead applicable to dividends received from all entities classified as corporations for income tax purposes.
• Assisted Illinois corporate taxpayer in obtaining $6 million refund of Illinois corporate income tax by challenging the adverse outcome in an Illinois Department of Revenue audit.