Dustin R. Webber
Counsel
1111 Bagby Street
Suite 2100
Houston, TX 77002
Dustin advises high-net-worth families, family offices, closely held enterprises, and multinational businesses on sophisticated tax planning, corporate transactions, and complex tax controversy. His practice unites strategic transactional counsel with seasoned trial advocacy, enabling him to guide clients through the full life cycle of their most consequential matters—from cross-border investment structuring and the negotiation of mergers,...
Dustin advises high-net-worth families, family offices, closely held enterprises, and multinational businesses on sophisticated tax planning, corporate transactions, and complex tax controversy. His practice unites strategic transactional counsel with seasoned trial advocacy, enabling him to guide clients through the full life cycle of their most consequential matters—from cross-border investment structuring and the negotiation of mergers, acquisitions, and reorganizations, to litigation before the United States Tax Court, the federal district and circuit courts, and the trial and appellate courts of Texas.
In tax controversy, Dustin draws on his prior service as a Senior Attorney with the Office of Chief Counsel for the Internal Revenue Service, where he worked at the front line of federal tax enforcement and litigation, involving many billions of dollars in tax per case. That vantage point shapes his representation of taxpayers at every stage of an IRS engagement, including pre-assessment positioning, examination defense, and IRS Appeals, collection due process relief, installment agreements, offers in compromise, and trial work.
Dustin’s controversy experience extends to the representation of business entities involved in complex international taxation and base erosion or profit shifting issues, energy-related, R&D, and other business credits, conservation easement transactions, micro captive insurance transactions, and numerous other matters of meaningful consequence. Dustin has also published a two-part Special Report in Tax Notes Federal and Tax Notes State examining the intersection of blockchain technology, convertible virtual currencies, and the federal anti-money-laundering and tax-administration regimes administered by the Financial Crimes Enforcement Network and the Internal Revenue Service.
On the transactional side, Dustin serves as lead counsel to founders, executives, and investors on tax-efficient acquisitions, dispositions, recapitalizations, and reorganizations, with particular depth in cross-border structures. He has advised multinational suppliers and manufacturers, real estate enterprises with operations in the United States, Canada, and Mexico, and acquirers of equity in Canadian and Chinese operating companies. His matters have ranged from a $3 million sale of a metal fabrication business to a $6.7 billion reorganization of a global oil & gas organization, and have routinely involved tax-free reorganizations, Section 1031 like-kind exchanges, Qualified Opportunity Fund formation and investment, Section 338 and Section 336(e) elections, Section 355 spin-offs, split-offs, and split-ups, Section 368 reorganizations, executive incentive and succession arrangements, and numerous private equity offerings.
Beyond his legal practice, Dustin brings a perspective forged in service and operational leadership. He served in a United States Army special operations unit during Operation Enduring Freedom, earning multiple decorations. He later founded and led Webber Aerospace Co. as Chief Executive Officer, and most recently served as Chief Operations Officer of American Revitalization Company, a private equity fund manager focused on industry revitalization and historic preservation. That combination of disciplined military experience, executive leadership, and sophisticated legal practice gives Dustin a grounded, business-aware perspective—one his clients rely on when stakes are highest and timelines unforgiving.
acquisitions, and reorganizations, to litigation before the United States Tax Court, the federal district and circuit courts, and the trial and appellate courts of Texas.
In tax controversy, Dustin draws on his prior service as a Senior Attorney with the Office of Chief Counsel for the Internal Revenue Service, where he worked at the front line of federal tax enforcement and litigation, involving many billions of dollars in tax per case. That vantage point shapes his representation of taxpayers at every stage of an IRS engagement, including pre-assessment positioning, examination defense, and IRS Appeals, collection due process relief, installment agreements, offers in compromise, and trial work.
Dustin’s controversy experience extends to the representation of business entities involved in complex international taxation and base erosion or profit shifting issues, energy-related, R&D, and other business credits, conservation easement transactions, micro captive insurance transactions, and numerous other matters of meaningful consequence. Dustin has also published a two-part Special Report in Tax Notes Federal and Tax Notes State examining the intersection of blockchain technology, convertible virtual currencies, and the federal anti-money-laundering and tax-administration regimes administered by the Financial Crimes Enforcement Network and the Internal Revenue Service.
On the transactional side, Dustin serves as lead counsel to founders, executives, and investors on tax-efficient acquisitions, dispositions, recapitalizations, and reorganizations, with particular depth in cross-border structures. He has advised multinational suppliers and manufacturers, real estate enterprises with operations in the United States, Canada, and Mexico, and acquirers of equity in Canadian and Chinese operating companies. His matters have ranged from a $3 million sale of a metal fabrication business to a $6.7 billion reorganization of a global oil & gas organization, and have routinely involved tax-free reorganizations, Section 1031 like-kind exchanges, Qualified Opportunity Fund formation and investment, Section 338 and Section 336(e) elections, Section 355 spin-offs, split-offs, and split-ups, Section 368 reorganizations, executive incentive and succession arrangements, and numerous private equity offerings.
Beyond his legal practice, Dustin brings a perspective forged in service and operational leadership. He served in a United States Army special operations unit during Operation Enduring Freedom, earning multiple decorations. He later founded and led Webber Aerospace Co. as Chief Executive Officer, and most recently served as Chief Operations Officer of American Revitalization Company, a private equity fund manager focused on industry revitalization and historic preservation. That combination of disciplined military experience, executive leadership, and sophisticated legal practice gives Dustin a grounded, business-aware perspective—one his clients rely on when stakes are highest and timelines unforgiving.
Experience
Representative Matters
- Lead counsel to an international oil & gas conglomerate in their $6.7 billion reorganization in anticipation of impending legislation and enactment of business-related efficiencies.
- Lead counsel to an international energy company for their $370 million reorganization for real property acquisitions, advanced manufacturing facility buildouts, and infrastructure support for AI data centers.
- Lead counsel to a global private equity fund in their $239 million acquisition of real estate for development of an AI data centers.
- Lead counsel for a real estate development company in their $437 million acquisition of real estate for the development of AI data centers.
- Lead counsel to a supplier and manufacturer of electronic devices with U.S. and foreign operations in connection with the tax-free reorganization of its corporate structure, including the establishment of foreign and domestic structures.
- Lead counsel to a real estate development company with ownership interests in the United States and Mexico in connection with the tax-free reorganization of its corporate structure.
- Lead counsel to an acquirer of equity in a Canadian web-services company.
- Lead counsel to an acquirer of equity in a Chinese electronics manufacturer.
- Lead counsel to an angel investor in the acquisition of equity in a smartphone-application developer.
- Lead counsel to sellers in the $3 million sale of a metal-fabrication business.
- Lead counsel to multiple clients in acquisitions and dispositions of real property, including transactions involving Section 1031 like-kind exchanges.
- Counsel to an acquirer in connection with a $65 million acquisition of fast-food restaurants.
- Counsel to a large architecture and engineering services firm in connection with the tax-free reorganization of its ownership structure.
- Counsel to multiple private companies and their owners in reorganizations of their corporate structures and recapitalization of their equity.
- Counsel to multiple private companies and their owners in structuring incentive arrangements for key employees and in succession planning.
- Tax and corporate counsel to multiple clients with respect to the creation of, and investment in, Qualified Opportunity Funds.
- Tax counsel to multiple clients in the reorganization of their corporate structures.
- Tax counsel to multiple clients in mergers and acquisitions, including company sales involving Section 338 and Section 336(e) elections, transaction structuring, and post-closing reporting.
- Tax counsel to private companies in resolving civil tax controversies with the Internal Revenue Service through examination and IRS Appeals.
- Tax counsel to multiple clients in connection with private equity offerings.
- Tax counsel to multiple clients on Section 355 spin-offs, split-offs, and split-ups.
- Counsel to business entities in tax litigation matters, including representation in matters involving conservation easement transactions.
Previous Professional Experience
- Managing Attorney, Houston-based Boutique Law Firm (2021–2026)
- Chief Operations Officer, Global Private Equity Firm (2024–2025)
- Senior Attorney, Office of Chief Counsel, Internal Revenue Service (2022–2024)
- Attorney, Houston-based Regional Tax Law Firm (2018-2022)
- Chief Executive Officer, Aerospace & Defense Contractor (2009–2018)
Publications
- “Throw a Blockchain at It Already!” Tax Notes Federal, Vol. 171, No. 13 (June 28, 2021), at 2099 (Special Report, Part 1 of 2) (analyzing the Bank Secrecy Act, the evolution and statutory mandate of the Financial Crimes Enforcement Network, the IRS’s third-party reporting framework, the application of the federal anti-money-laundering and currency-transaction-reporting regimes, and the role of automated sale suppression devices, cryptocurrency, and the marijuana industry in propagating black-market activity).
- “Throw a Blockchain at It Already, Part 2.” Tax Notes Federal, Vol. 172, No. 1 (July 5, 2021), at 23 (Special Report, Part 2 of 2) (proposing the implementation of a centrally monitored, federally supervised blockchain to harmonize federalism concerns and to support the IRS’s and FinCEN’s information-gathering, anti-money-laundering, and tax-administration mandates, and addressing IRC § 280E, the characterization of convertible virtual currency under Notice 2014-21, and the design of permissioned consortium blockchains).
Education
- New York University School of Law, LLM, Taxation (2020)
- University of Houston Law Center, JD (2019)
- University of Houston, BBA (2016)
- Rochester Institute of Technology, BS, Mechanical Engineering (1996)
Admissions
- Texas
- U.S. Tax Court
- U.S. Court of Appeals for the Fifth Circuit
- U.S. Court of Appeals for the Tenth Circuit
- U.S. District Court for the Southern District of Texas
- U.S. District Court for the Eastern District of Texas
- U.S. District Court for the District of Colorado
Practice Areas
Representative Matters
- Lead counsel to an international oil & gas conglomerate in their $6.7 billion reorganization in anticipation of impending legislation and enactment of business-related efficiencies.
- Lead counsel to an international energy company for their $370 million reorganization for real property acquisitions, advanced manufacturing facility buildouts, and infrastructure support for AI data centers.
- Lead counsel to a global private equity fund in their $239 million acquisition of real estate for development of an AI data centers.
- Lead counsel for a real estate development company in their $437 million acquisition of real estate for the development of AI data centers.
- Lead counsel to a supplier and manufacturer of electronic devices with U.S. and foreign operations in connection with the tax-free reorganization of its corporate structure, including the establishment of foreign and domestic structures.
- Lead counsel to a real estate development company with ownership interests in the United States and Mexico in connection with the tax-free reorganization of its corporate structure.
- Lead counsel to an acquirer of equity in a Canadian web-services company.
- Lead counsel to an acquirer of equity in a Chinese electronics manufacturer.
- Lead counsel to an angel investor in the acquisition of equity in a smartphone-application developer.
- Lead counsel to sellers in the $3 million sale of a metal-fabrication business.
- Lead counsel to multiple clients in acquisitions and dispositions of real property, including transactions involving Section 1031 like-kind exchanges.
- Counsel to an acquirer in connection with a $65 million acquisition of fast-food restaurants.
- Counsel to a large architecture and engineering services firm in connection with the tax-free reorganization of its ownership structure.
- Counsel to multiple private companies and their owners in reorganizations of their corporate structures and recapitalization of their equity.
- Counsel to multiple private companies and their owners in structuring incentive arrangements for key employees and in succession planning.
- Tax and corporate counsel to multiple clients with respect to the creation of, and investment in, Qualified Opportunity Funds.
- Tax counsel to multiple clients in the reorganization of their corporate structures.
- Tax counsel to multiple clients in mergers and acquisitions, including company sales involving Section 338 and Section 336(e) elections, transaction structuring, and post-closing reporting.
- Tax counsel to private companies in resolving civil tax controversies with the Internal Revenue Service through examination and IRS Appeals.
- Tax counsel to multiple clients in connection with private equity offerings.
- Tax counsel to multiple clients on Section 355 spin-offs, split-offs, and split-ups.
- Counsel to business entities in tax litigation matters, including representation in matters involving conservation easement transactions.
Previous Professional Experience
- Managing Attorney, Houston-based Boutique Law Firm (2021–2026)
- Chief Operations Officer, Global Private Equity Firm (2024–2025)
- Senior Attorney, Office of Chief Counsel, Internal Revenue Service (2022–2024)
- Attorney, Houston-based Regional Tax Law Firm (2018-2022)
- Chief Executive Officer, Aerospace & Defense Contractor (2009–2018)
Publications
- “Throw a Blockchain at It Already!” Tax Notes Federal, Vol. 171, No. 13 (June 28, 2021), at 2099 (Special Report, Part 1 of 2) (analyzing the Bank Secrecy Act, the evolution and statutory mandate of the Financial Crimes Enforcement Network, the IRS’s third-party reporting framework, the application of the federal anti-money-laundering and currency-transaction-reporting regimes, and the role of automated sale suppression devices, cryptocurrency, and the marijuana industry in propagating black-market activity).
- “Throw a Blockchain at It Already, Part 2.” Tax Notes Federal, Vol. 172, No. 1 (July 5, 2021), at 23 (Special Report, Part 2 of 2) (proposing the implementation of a centrally monitored, federally supervised blockchain to harmonize federalism concerns and to support the IRS’s and FinCEN’s information-gathering, anti-money-laundering, and tax-administration mandates, and addressing IRC § 280E, the characterization of convertible virtual currency under Notice 2014-21, and the design of permissioned consortium blockchains).
Recognitions
- Ones to Watch in America, Best Lawyers® (Tax Law; Tax Controversy and Litigation) (2021–2026)
- Rising Stars, Texas Super Lawyers (Tax; Tax Controversy and Litigation) (2021–2026)
Professional Activities
- American Bar Association, Section of Taxation
- State Bar of Texas, Tax Section
Community
- Pro bono representation of low-income and indigent clients in their legal needs.
- Active engagement in community and school affairs, including service through the Parent-Teacher Organization.
Military
- United States Army, Team Leader / Instructor (2002–2003); Special Operations Supervisor (1996–2002). Service during Operation Enduring Freedom; multiple decorations.
Dustin advises high-net-worth families, family offices, closely held enterprises, and multinational businesses on sophisticated tax planning, corporate transactions, and complex tax controversy. His practice unites strategic transactional counsel with seasoned trial advocacy, enabling him to guide clients through the full life cycle of their most consequential matters—from cross-border investment structuring and the negotiation of mergers,... acquisitions, and reorganizations, to litigation before the United States Tax Court, the federal district and circuit courts, and the trial and appellate courts of Texas.
In tax controversy, Dustin draws on his prior service as a Senior Attorney with the Office of Chief Counsel for the Internal Revenue Service, where he worked at the front line of federal tax enforcement and litigation, involving many billions of dollars in tax per case. That vantage point shapes his representation of taxpayers at every stage of an IRS engagement, including pre-assessment positioning, examination defense, and IRS Appeals, collection due process relief, installment agreements, offers in compromise, and trial work.
Dustin’s controversy experience extends to the representation of business entities involved in complex international taxation and base erosion or profit shifting issues, energy-related, R&D, and other business credits, conservation easement transactions, micro captive insurance transactions, and numerous other matters of meaningful consequence. Dustin has also published a two-part Special Report in Tax Notes Federal and Tax Notes State examining the intersection of blockchain technology, convertible virtual currencies, and the federal anti-money-laundering and tax-administration regimes administered by the Financial Crimes Enforcement Network and the Internal Revenue Service.
On the transactional side, Dustin serves as lead counsel to founders, executives, and investors on tax-efficient acquisitions, dispositions, recapitalizations, and reorganizations, with particular depth in cross-border structures. He has advised multinational suppliers and manufacturers, real estate enterprises with operations in the United States, Canada, and Mexico, and acquirers of equity in Canadian and Chinese operating companies. His matters have ranged from a $3 million sale of a metal fabrication business to a $6.7 billion reorganization of a global oil & gas organization, and have routinely involved tax-free reorganizations, Section 1031 like-kind exchanges, Qualified Opportunity Fund formation and investment, Section 338 and Section 336(e) elections, Section 355 spin-offs, split-offs, and split-ups, Section 368 reorganizations, executive incentive and succession arrangements, and numerous private equity offerings.
Beyond his legal practice, Dustin brings a perspective forged in service and operational leadership. He served in a United States Army special operations unit during Operation Enduring Freedom, earning multiple decorations. He later founded and led Webber Aerospace Co. as Chief Executive Officer, and most recently served as Chief Operations Officer of American Revitalization Company, a private equity fund manager focused on industry revitalization and historic preservation. That combination of disciplined military experience, executive leadership, and sophisticated legal practice gives Dustin a grounded, business-aware perspective—one his clients rely on when stakes are highest and timelines unforgiving.
Experience
The following is a selected sampling of matters and is provided for informational purposes only. Past success does not indicate the likelihood of success in any future matter.Representative Matters
- Lead counsel to an international oil & gas conglomerate in their $6.7 billion reorganization in anticipation of impending legislation and enactment of business-related efficiencies.
- Lead counsel to an international energy company for their $370 million reorganization for real property acquisitions, advanced manufacturing facility buildouts, and infrastructure support for AI data centers.
- Lead counsel to a global private equity fund in their $239 million acquisition of real estate for development of an AI data centers.
- Lead counsel for a real estate development company in their $437 million acquisition of real estate for the development of AI data centers.
- Lead counsel to a supplier and manufacturer of electronic devices with U.S. and foreign operations in connection with the tax-free reorganization of its corporate structure, including the establishment of foreign and domestic structures.
- Lead counsel to a real estate development company with ownership interests in the United States and Mexico in connection with the tax-free reorganization of its corporate structure.
- Lead counsel to an acquirer of equity in a Canadian web-services company.
- Lead counsel to an acquirer of equity in a Chinese electronics manufacturer.
- Lead counsel to an angel investor in the acquisition of equity in a smartphone-application developer.
- Lead counsel to sellers in the $3 million sale of a metal-fabrication business.
- Lead counsel to multiple clients in acquisitions and dispositions of real property, including transactions involving Section 1031 like-kind exchanges.
- Counsel to an acquirer in connection with a $65 million acquisition of fast-food restaurants.
- Counsel to a large architecture and engineering services firm in connection with the tax-free reorganization of its ownership structure.
- Counsel to multiple private companies and their owners in reorganizations of their corporate structures and recapitalization of their equity.
- Counsel to multiple private companies and their owners in structuring incentive arrangements for key employees and in succession planning.
- Tax and corporate counsel to multiple clients with respect to the creation of, and investment in, Qualified Opportunity Funds.
- Tax counsel to multiple clients in the reorganization of their corporate structures.
- Tax counsel to multiple clients in mergers and acquisitions, including company sales involving Section 338 and Section 336(e) elections, transaction structuring, and post-closing reporting.
- Tax counsel to private companies in resolving civil tax controversies with the Internal Revenue Service through examination and IRS Appeals.
- Tax counsel to multiple clients in connection with private equity offerings.
- Tax counsel to multiple clients on Section 355 spin-offs, split-offs, and split-ups.
- Counsel to business entities in tax litigation matters, including representation in matters involving conservation easement transactions.
Previous Professional Experience
- Managing Attorney, Houston-based Boutique Law Firm (2021–2026)
- Chief Operations Officer, Global Private Equity Firm (2024–2025)
- Senior Attorney, Office of Chief Counsel, Internal Revenue Service (2022–2024)
- Attorney, Houston-based Regional Tax Law Firm (2018-2022)
- Chief Executive Officer, Aerospace & Defense Contractor (2009–2018)
Publications
- “Throw a Blockchain at It Already!” Tax Notes Federal, Vol. 171, No. 13 (June 28, 2021), at 2099 (Special Report, Part 1 of 2) (analyzing the Bank Secrecy Act, the evolution and statutory mandate of the Financial Crimes Enforcement Network, the IRS’s third-party reporting framework, the application of the federal anti-money-laundering and currency-transaction-reporting regimes, and the role of automated sale suppression devices, cryptocurrency, and the marijuana industry in propagating black-market activity).
- “Throw a Blockchain at It Already, Part 2.” Tax Notes Federal, Vol. 172, No. 1 (July 5, 2021), at 23 (Special Report, Part 2 of 2) (proposing the implementation of a centrally monitored, federally supervised blockchain to harmonize federalism concerns and to support the IRS’s and FinCEN’s information-gathering, anti-money-laundering, and tax-administration mandates, and addressing IRC § 280E, the characterization of convertible virtual currency under Notice 2014-21, and the design of permissioned consortium blockchains).
Education
- New York University School of Law, LLM, Taxation (2020)
- University of Houston Law Center, JD (2019)
- University of Houston, BBA (2016)
- Rochester Institute of Technology, BS, Mechanical Engineering (1996)
Admissions
- Texas
- U.S. Tax Court
- U.S. Court of Appeals for the Fifth Circuit
- U.S. Court of Appeals for the Tenth Circuit
- U.S. District Court for the Southern District of Texas
- U.S. District Court for the Eastern District of Texas
- U.S. District Court for the District of Colorado
Practice Areas
- Tax Controversy
- Tax Planning & Consulting
- Mergers & Acquisitions
- Corporate & Securities
- International Taxation
- Energy
Industries
- Ones to Watch in America, Best Lawyers® (Tax Law; Tax Controversy and Litigation) (2021–2026)
- Rising Stars, Texas Super Lawyers (Tax; Tax Controversy and Litigation) (2021–2026)
- American Bar Association, Section of Taxation
- State Bar of Texas, Tax Section
- Pro bono representation of low-income and indigent clients in their legal needs.
- Active engagement in community and school affairs, including service through the Parent-Teacher Organization.
- United States Army, Team Leader / Instructor (2002–2003); Special Operations Supervisor (1996–2002). Service during Operation Enduring Freedom; multiple decorations.
Highlights from the Firm’s Insights
