For twenty-five years, Richard Husseini has maintained an active federal tax planning and controversy practice. Chambers describes him as someone who “bridges planning and controversy” and who “provides clear direction, focuses on the key issues and is able to describe very complicated transactions in a simple way.” (Chambers USA 2018). His clients also note that “he is exceedingly intelligent, strategic, creative, responsive and humble” (Chambers USA 2017).
His tax controversy practice has focused primarily on advocating on behalf of large companies and high net worth individuals nationwide in IRS administrative, arbitration and federal court proceedings. Chambers USA 2018 describes him as a “very, very good litigator.” Richard is widely recognized for his experience in resolving (often amicably) complex and strategic tax disputes and for his active federal transactional tax practice.
In his controversy practice, he has specific experience in representing taxpayers in IRS examinations, IRS Appeals, RAP, IRS fast track mediations and post-Appeals mediations, Tax Court and federal court refund actions, and before the Texas Public Utility Commission. He also counsels clients on likely controversy issues flowing from the 2017 tax reform legislation.
His controversy experience extends to all areas of federal income taxation, with an emphasis in international tax; transfer pricing; competent authorities and MAP negotiations; foreign tax credit and treaty issues; research and development credits; section 199 issues; oil and gas tax issues; technology/IP tax issues; banking tax issues; partnership tax issues; MLP tax issues; tax sharing agreements; subchapter C; financial products; tax shelter defense; accounting methods; non-profit issues; renewable energy; section 1033 issues; casualty loss issues; normalization issues; receivership tax issues and federal constitutional challenges to state tax statutes.
Mr. Husseini is recognized by Chambers USA, The Legal 500 U.S. and Best Lawyers in America (Woodward White, Inc.). Chambers USA 2019 applauds him for his "ability to enter into dialogue with tax auditors and assist in reaching acceptable settlements for complex issues.” Chambers USA 2012 quoted his clients as saying that “he is non-confrontational but very strong, so fights a good fight without being rude or inconsiderate." Clients also noted that he has the "best memory of anyone I've ever met," and that he is "good at dissecting complex facts into simple one-line explanations" Chambers USA 2015. The Legal 500 U.S. 2015 notes that "he has strong technical and procedural skills and is also a strong communicator and collaborator" and The Legal 500 U.S. 2012 notes his clients assess him as "extremely smart" and "very personable" with the "intuitive skills that are rare in this type of attorney." Best Lawyers in America (Woodward White, Inc.), 2012 indicates clients as stating, "Richard Husseini is one of the best in the business. He is cordial, responsive, knowledgeable and has a sharp instinct when getting to the bottom of an issue.”
Mr. Husseini has extensive knowledge of privilege and ethical issues affecting tax practice. He has extensive experience in advising clients on FIN 48 and Schedule UTP. He regularly counsels clients on their interactions with outside auditors, tax issues affecting financial disclosure issues, and tax investigations.
Mr. Husseini also has an active federal transactional tax practice. He is a member of the Baker Botts Oil and Gas Mergers and Acquisitions Team. He has specific experience in corporate tax issues affecting the energy, oil and gas and gas and electric utility industries (including tax normalization issues). He is also experienced in tax issues affecting alternative and renewable energy projects, including production tax credits, investment tax credits and governmental grants. Chambers USA 2018 quoted one of his clients as saying "he is an outstanding corporate tax lawyer - one of the best in the business."
Following graduation from law school, Mr. Husseini served as a law clerk to the Honorable Richard A. Posner of the United States Court of Appeals for the Seventh Circuit.