Eman Arabi-Katbi
Counsel
1111 Bagby Street
Suite 2100
Houston, TX 77002
Eman Arabi-Katbi advises businesses and their owners on federal tax planning, transactions, and disputes, with particular experience in international tax and transfer pricing. Before joining Nelson Mullins, she served as an Associate Area Counsel and Senior Attorney in the IRS Office of Chief Counsel. Her background also includes private practice and public accounting, and she...
Eman Arabi-Katbi advises businesses and their owners on federal tax planning, transactions, and disputes, with particular experience in international tax and transfer pricing. Before joining Nelson Mullins, she served as an Associate Area Counsel and Senior Attorney in the IRS Office of Chief Counsel. Her background also includes private practice and public accounting, and she is a Certified Public Accountant.
Eman’s planning work includes corporate restructurings, entity planning, cross-border operations, consolidated return issues, and other corporate and partnership tax matters. At IRS Chief Counsel, she worked on proposed and completed transactions involving large domestic and multinational businesses, evaluating tax consequences, structuring alternatives, potential risks, and documentation needs. In private practice, she advised business owners and sellers on transaction structuring, negotiated deal terms, and drafted agreements.
Eman also handles tax controversy and litigation. At IRS Chief Counsel, she advised Large Business and International examination teams on federal income tax issues affecting large domestic and multinational taxpayers and led transfer pricing issue development. Her work included foreign tax credits, research credits, Subchapter C and Subchapter K matters, privilege issues, cross-border information gathering, GDPR considerations, and IRS administrative summonses.
She served as counsel of record on an active U.S. Tax Court docket of more than 80 matters, handling cases from issue development through resolution. Her litigation experience extends beyond the Tax Court: she has argued before the U.S. Court of Appeals for the Fifth Circuit and prepared and filed a petition for a writ of certiorari with the Supreme Court of the United States.
is a Certified Public Accountant.
Eman’s planning work includes corporate restructurings, entity planning, cross-border operations, consolidated return issues, and other corporate and partnership tax matters. At IRS Chief Counsel, she worked on proposed and completed transactions involving large domestic and multinational businesses, evaluating tax consequences, structuring alternatives, potential risks, and documentation needs. In private practice, she advised business owners and sellers on transaction structuring, negotiated deal terms, and drafted agreements.
Eman also handles tax controversy and litigation. At IRS Chief Counsel, she advised Large Business and International examination teams on federal income tax issues affecting large domestic and multinational taxpayers and led transfer pricing issue development. Her work included foreign tax credits, research credits, Subchapter C and Subchapter K matters, privilege issues, cross-border information gathering, GDPR considerations, and IRS administrative summonses.
She served as counsel of record on an active U.S. Tax Court docket of more than 80 matters, handling cases from issue development through resolution. Her litigation experience extends beyond the Tax Court: she has argued before the U.S. Court of Appeals for the Fifth Circuit and prepared and filed a petition for a writ of certiorari with the Supreme Court of the United States.
Experience
Previous Professional Experience
- Associate Area Counsel, Litigation and Advisory, IRS Office of Chief Counsel (2024–2026)
- Senior Attorney, Large Business and International, IRS Office of Chief Counsel (2022–2024)
- Of Counsel, Full-Service Law Firm (2018–2022)
- Adjunct Professor, Tax Ethics, University of Houston Law Center (2023–2024)
- Tax Associate, National Accounting Firm (2016–2017)
Representative Matters
- Advised on the federal income tax consequences of proposed and completed transactions involving large domestic and multinational businesses, including corporate restructurings, cross-border operations, and consolidated return matters.
- Advised business owners and sellers on tax structuring and entity planning in connection with business transactions, and negotiated and drafted related agreements.
- Led the factual and legal development of transfer pricing issues involving multinational taxpayers, including development of the administrative record and assessment of litigation risk.
- Addressed privilege and procedural issues arising from cross-border information gathering, including attorney-client privilege, IRC § 7525 practitioner privilege, GDPR considerations, and IRS administrative summonses.
- Handled U.S. Tax Court matters involving net operating losses, partnership issues, accumulated earnings tax, and other federal income tax disputes, including pleadings, motions practice, settlement, and case resolution.
- Argued a Fourth Amendment matter before the U.S. Court of Appeals for the Fifth Circuit and prepared a petition for writ of certiorari filed with the Supreme Court of the United States.
Professional Credentials
- Certified Public Accountant
Education
- Boston University School of Law, LLM, Taxation (2022)
- University of Houston Law Center, JD (2014)
- University of Houston, C.T. Bauer College of Business, BBA, Accounting and Finance, magna cum laude (2011)
Admissions
- Texas
- Supreme Court of the United States
- U.S. Court of Appeals for the Fifth Circuit
- U.S. Tax Court
- U.S. District Court for the Northern District of Texas
- U.S. District Court for the Southern District of Texas
Practice Areas
Previous Professional Experience
- Associate Area Counsel, Litigation and Advisory, IRS Office of Chief Counsel (2024–2026)
- Senior Attorney, Large Business and International, IRS Office of Chief Counsel (2022–2024)
- Of Counsel, Full-Service Law Firm (2018–2022)
- Adjunct Professor, Tax Ethics, University of Houston Law Center (2023–2024)
- Tax Associate, National Accounting Firm (2016–2017)
Representative Matters
- Advised on the federal income tax consequences of proposed and completed transactions involving large domestic and multinational businesses, including corporate restructurings, cross-border operations, and consolidated return matters.
- Advised business owners and sellers on tax structuring and entity planning in connection with business transactions, and negotiated and drafted related agreements.
- Led the factual and legal development of transfer pricing issues involving multinational taxpayers, including development of the administrative record and assessment of litigation risk.
- Addressed privilege and procedural issues arising from cross-border information gathering, including attorney-client privilege, IRC § 7525 practitioner privilege, GDPR considerations, and IRS administrative summonses.
- Handled U.S. Tax Court matters involving net operating losses, partnership issues, accumulated earnings tax, and other federal income tax disputes, including pleadings, motions practice, settlement, and case resolution.
- Argued a Fourth Amendment matter before the U.S. Court of Appeals for the Fifth Circuit and prepared a petition for writ of certiorari filed with the Supreme Court of the United States.
Professional Credentials
- Certified Public Accountant
Media
Eman Arabi-Katbi advises businesses and their owners on federal tax planning, transactions, and disputes, with particular experience in international tax and transfer pricing. Before joining Nelson Mullins, she served as an Associate Area Counsel and Senior Attorney in the IRS Office of Chief Counsel. Her background also includes private practice and public accounting, and she... is a Certified Public Accountant.
Eman’s planning work includes corporate restructurings, entity planning, cross-border operations, consolidated return issues, and other corporate and partnership tax matters. At IRS Chief Counsel, she worked on proposed and completed transactions involving large domestic and multinational businesses, evaluating tax consequences, structuring alternatives, potential risks, and documentation needs. In private practice, she advised business owners and sellers on transaction structuring, negotiated deal terms, and drafted agreements.
Eman also handles tax controversy and litigation. At IRS Chief Counsel, she advised Large Business and International examination teams on federal income tax issues affecting large domestic and multinational taxpayers and led transfer pricing issue development. Her work included foreign tax credits, research credits, Subchapter C and Subchapter K matters, privilege issues, cross-border information gathering, GDPR considerations, and IRS administrative summonses.
She served as counsel of record on an active U.S. Tax Court docket of more than 80 matters, handling cases from issue development through resolution. Her litigation experience extends beyond the Tax Court: she has argued before the U.S. Court of Appeals for the Fifth Circuit and prepared and filed a petition for a writ of certiorari with the Supreme Court of the United States.
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.Previous Professional Experience
- Associate Area Counsel, Litigation and Advisory, IRS Office of Chief Counsel (2024–2026)
- Senior Attorney, Large Business and International, IRS Office of Chief Counsel (2022–2024)
- Of Counsel, Full-Service Law Firm (2018–2022)
- Adjunct Professor, Tax Ethics, University of Houston Law Center (2023–2024)
- Tax Associate, National Accounting Firm (2016–2017)
Representative Matters
- Advised on the federal income tax consequences of proposed and completed transactions involving large domestic and multinational businesses, including corporate restructurings, cross-border operations, and consolidated return matters.
- Advised business owners and sellers on tax structuring and entity planning in connection with business transactions, and negotiated and drafted related agreements.
- Led the factual and legal development of transfer pricing issues involving multinational taxpayers, including development of the administrative record and assessment of litigation risk.
- Addressed privilege and procedural issues arising from cross-border information gathering, including attorney-client privilege, IRC § 7525 practitioner privilege, GDPR considerations, and IRS administrative summonses.
- Handled U.S. Tax Court matters involving net operating losses, partnership issues, accumulated earnings tax, and other federal income tax disputes, including pleadings, motions practice, settlement, and case resolution.
- Argued a Fourth Amendment matter before the U.S. Court of Appeals for the Fifth Circuit and prepared a petition for writ of certiorari filed with the Supreme Court of the United States.
Professional Credentials
- Certified Public Accountant
Education
- Boston University School of Law, LLM, Taxation (2022)
- University of Houston Law Center, JD (2014)
- University of Houston, C.T. Bauer College of Business, BBA, Accounting and Finance, magna cum laude (2011)
Admissions
- Texas
- Supreme Court of the United States
- U.S. Court of Appeals for the Fifth Circuit
- U.S. Tax Court
- U.S. District Court for the Northern District of Texas
- U.S. District Court for the Southern District of Texas
Practice Areas
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