Patrick J. McCann, Jr.
Partner
201 17th Street NW
Suite 1700
Atlanta, GA 30363
Pat focuses his practice on representing taxpayers at every stage of tax controversy, including examinations, appeals, and litigation. He has extensive experience handling federal tax matters, including individual, estate and gift, corporate, partnership, and employment tax issues. Pat has also represented individuals subject to tax shelter penalties and promoter examinations under Sections 6700 and 6701.
Pat...
Pat focuses his practice on representing taxpayers at every stage of tax controversy, including examinations, appeals, and litigation. He has extensive experience handling federal tax matters, including individual, estate and gift, corporate, partnership, and employment tax issues. Pat has also represented individuals subject to tax shelter penalties and promoter examinations under Sections 6700 and 6701.
Pat has significant experience representing small captive insurance companies that elect federal tax treatment under Section 831(b), as well as the small businesses that utilize these companies as an alternative risk management strategy. Throughout the litigation process, he works closely with business owners, their professional advisors, and captive insurance management companies to address complex tax and regulatory issues.
Pat also counsels clients on tax planning, structuring, and reporting strategies designed to withstand future scrutiny from the Internal Revenue Service. He collaborates with clients and their professional advisors to help ensure compliance with applicable federal statutory and regulatory requirements.
In addition to his client work, Pat has authored several articles addressing key issues affecting taxpayers based on Internal Revenue Service enforcement priorities.
has significant experience representing small captive insurance companies that elect federal tax treatment under Section 831(b), as well as the small businesses that utilize these companies as an alternative risk management strategy. Throughout the litigation process, he works closely with business owners, their professional advisors, and captive insurance management companies to address complex tax and regulatory issues.
Pat also counsels clients on tax planning, structuring, and reporting strategies designed to withstand future scrutiny from the Internal Revenue Service. He collaborates with clients and their professional advisors to help ensure compliance with applicable federal statutory and regulatory requirements.
In addition to his client work, Pat has authored several articles addressing key issues affecting taxpayers based on Internal Revenue Service enforcement priorities.
Experience
Previous Professional Experience
- Tax Controversy Shareholder, Chamberlain Hrdlicka (2022–2026)
- Tax Controversy Associate, Chamberlain Hrdlicka (2015-2022)
- Associate, Donahoo & McMenamy, P.A. (2013-2015)
- Associate, Salvatori, Wood & Buckel (2012-2013)
Representative Matters
- Represented multiple Section 831(b) captive insurance companies and their insured customers in tax audits and litigation.
- Represented a global privately-held group of companies in an IRS examination related to gift tax consequences of gratuitous transfers of shares in the holding company and advised on ways to improve the accuracy of valuations for future transfers.
- Represented a multi-million dollar estate on various estate and gift tax issues related to multiple intracompany transactions and intrafamily transfers.
- Represented a captive insurance management company as part of a Section 6700 promoter examination.
Publications
- Author, “IRS’ Increased Funding Means More Scrutiny,” Daily Report (Nov. 9, 2022)
- Co-Author, “What IRS Funding Increase Means for Taxpayers,” Law360 (Oct. 21, 2022)
- Author, “Small Captive Insurance Concession May Mean New Enforcement Phase,” Tax Notes (Jan. 10, 2022)
- Co-Author, “Looking at Small Captives in a Post-Pandemic World,” Bloomberg Tax (Dec. 21, 2020)
- Author, “Preparing for the Wealth Squad: From Planning to Resolution,” Tax Notes Federal (Dec. 7, 2020)
- Author, “Defensive Strategies for High-Net-Worth Individual Tax Audits,” Law360 (Oct. 26, 2020)
- Author, “Captive Insurance May Help in a Pandemic, but Caution Is Key,” Law360 (July 2, 2020)
- Co-Author, “IRS Letter 6336: To Respond or Not to Respond, That Is the Question,” Tax Notes Federal (June 1, 2020)
- Co-Author, “The Letter in Question,” Captive Insurance Times (May 27, 2020)
- Co-Author, “IRS Announcement Likely Overstates True Impact of Captive Insurance Settlement,” Bloomberg Tax (Feb. 28, 2020)
Education
-
University of Florida Levin College of Law,
LLM,
Taxation
(2012)
- Graduate Editor, Florida Tax Review
-
University of Virginia School of Law,
JD
(2009)
- Senior Editor, Virginia Tax Review
- Wake Forest University, BA (2005)
Admissions
- Florida
- New York
- Georgia
- Supreme Court of the United States
- U.S. Court of Appeals for the Eleventh Circuit
- U.S. Court of Appeals for the Federal Circuit
- U.S. District Court for the Northern District of Georgia
- U.S. Tax Court
- Supreme Court of Georgia
- Court of Appeals of Georgia
Clerkships
- Law Clerk, the Honorable Cheryl V. Higgins, 16th Judicial Circuit of Virginia, Circuit Court for Albemarle County (2007)
Practice Areas
Previous Professional Experience
- Tax Controversy Shareholder, Chamberlain Hrdlicka (2022–2026)
- Tax Controversy Associate, Chamberlain Hrdlicka (2015-2022)
- Associate, Donahoo & McMenamy, P.A. (2013-2015)
- Associate, Salvatori, Wood & Buckel (2012-2013)
Representative Matters
- Represented multiple Section 831(b) captive insurance companies and their insured customers in tax audits and litigation.
- Represented a global privately-held group of companies in an IRS examination related to gift tax consequences of gratuitous transfers of shares in the holding company and advised on ways to improve the accuracy of valuations for future transfers.
- Represented a multi-million dollar estate on various estate and gift tax issues related to multiple intracompany transactions and intrafamily transfers.
- Represented a captive insurance management company as part of a Section 6700 promoter examination.
Publications
- Author, “IRS’ Increased Funding Means More Scrutiny,” Daily Report (Nov. 9, 2022)
- Co-Author, “What IRS Funding Increase Means for Taxpayers,” Law360 (Oct. 21, 2022)
- Author, “Small Captive Insurance Concession May Mean New Enforcement Phase,” Tax Notes (Jan. 10, 2022)
- Co-Author, “Looking at Small Captives in a Post-Pandemic World,” Bloomberg Tax (Dec. 21, 2020)
- Author, “Preparing for the Wealth Squad: From Planning to Resolution,” Tax Notes Federal (Dec. 7, 2020)
- Author, “Defensive Strategies for High-Net-Worth Individual Tax Audits,” Law360 (Oct. 26, 2020)
- Author, “Captive Insurance May Help in a Pandemic, but Caution Is Key,” Law360 (July 2, 2020)
- Co-Author, “IRS Letter 6336: To Respond or Not to Respond, That Is the Question,” Tax Notes Federal (June 1, 2020)
- Co-Author, “The Letter in Question,” Captive Insurance Times (May 27, 2020)
- Co-Author, “IRS Announcement Likely Overstates True Impact of Captive Insurance Settlement,” Bloomberg Tax (Feb. 28, 2020)
Media
Recognitions
- The Best Lawyers in America® - Litigation and Controversy - Tax (2027)
- The Best Lawyers in America® - Tax Law (2027)
- Best Lawyers: Ones to Watch® in America – Litigation and Controversy - Tax (2023-2026)
- Best Lawyers: Ones to Watch® in America – Tax Law (2023-2026)
- Georgia Super Lawyers: Rising Star® - Tax (2023)
- Super Lawyers: "Rising Star" (2023)
Professional Activities
- Atlanta Tax Forum, Board Member
- American Bar Association
- Georgia Bar Association
- Florida Bar Association
Pat focuses his practice on representing taxpayers at every stage of tax controversy, including examinations, appeals, and litigation. He has extensive experience handling federal tax matters, including individual, estate and gift, corporate, partnership, and employment tax issues. Pat has also represented individuals subject to tax shelter penalties and promoter examinations under Sections 6700 and 6701.
Pat... has significant experience representing small captive insurance companies that elect federal tax treatment under Section 831(b), as well as the small businesses that utilize these companies as an alternative risk management strategy. Throughout the litigation process, he works closely with business owners, their professional advisors, and captive insurance management companies to address complex tax and regulatory issues.
Pat also counsels clients on tax planning, structuring, and reporting strategies designed to withstand future scrutiny from the Internal Revenue Service. He collaborates with clients and their professional advisors to help ensure compliance with applicable federal statutory and regulatory requirements.
In addition to his client work, Pat has authored several articles addressing key issues affecting taxpayers based on Internal Revenue Service enforcement priorities.
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
- Tax Controversy Shareholder, Chamberlain Hrdlicka (2022–2026)
- Tax Controversy Associate, Chamberlain Hrdlicka (2015-2022)
- Associate, Donahoo & McMenamy, P.A. (2013-2015)
- Associate, Salvatori, Wood & Buckel (2012-2013)
Representative Matters
- Represented multiple Section 831(b) captive insurance companies and their insured customers in tax audits and litigation.
- Represented a global privately-held group of companies in an IRS examination related to gift tax consequences of gratuitous transfers of shares in the holding company and advised on ways to improve the accuracy of valuations for future transfers.
- Represented a multi-million dollar estate on various estate and gift tax issues related to multiple intracompany transactions and intrafamily transfers.
- Represented a captive insurance management company as part of a Section 6700 promoter examination.
Publications
- Author, “IRS’ Increased Funding Means More Scrutiny,” Daily Report (Nov. 9, 2022)
- Co-Author, “What IRS Funding Increase Means for Taxpayers,” Law360 (Oct. 21, 2022)
- Author, “Small Captive Insurance Concession May Mean New Enforcement Phase,” Tax Notes (Jan. 10, 2022)
- Co-Author, “Looking at Small Captives in a Post-Pandemic World,” Bloomberg Tax (Dec. 21, 2020)
- Author, “Preparing for the Wealth Squad: From Planning to Resolution,” Tax Notes Federal (Dec. 7, 2020)
- Author, “Defensive Strategies for High-Net-Worth Individual Tax Audits,” Law360 (Oct. 26, 2020)
- Author, “Captive Insurance May Help in a Pandemic, but Caution Is Key,” Law360 (July 2, 2020)
- Co-Author, “IRS Letter 6336: To Respond or Not to Respond, That Is the Question,” Tax Notes Federal (June 1, 2020)
- Co-Author, “The Letter in Question,” Captive Insurance Times (May 27, 2020)
- Co-Author, “IRS Announcement Likely Overstates True Impact of Captive Insurance Settlement,” Bloomberg Tax (Feb. 28, 2020)
Education
-
University of Florida Levin College of Law,
LLM,
Taxation
(2012)
- Graduate Editor, Florida Tax Review
-
University of Virginia School of Law,
JD
(2009)
- Senior Editor, Virginia Tax Review
- Wake Forest University, BA (2005)
Admissions
- Florida
- New York
- Georgia
- Supreme Court of the United States
- U.S. Court of Appeals for the Eleventh Circuit
- U.S. Court of Appeals for the Federal Circuit
- U.S. District Court for the Northern District of Georgia
- U.S. Tax Court
- Supreme Court of Georgia
- Court of Appeals of Georgia
Clerkships
- Law Clerk, the Honorable Cheryl V. Higgins, 16th Judicial Circuit of Virginia, Circuit Court for Albemarle County (2007)
Practice Areas
- The Best Lawyers in America® - Litigation and Controversy - Tax (2027)
- The Best Lawyers in America® - Tax Law (2027)
- Best Lawyers: Ones to Watch® in America – Litigation and Controversy - Tax (2023-2026)
- Best Lawyers: Ones to Watch® in America – Tax Law (2023-2026)
- Georgia Super Lawyers: Rising Star® - Tax (2023)
- Super Lawyers: "Rising Star" (2023)
- Atlanta Tax Forum, Board Member
- American Bar Association
- Georgia Bar Association
- Florida Bar Association
Highlights from the Firm’s Insights
