• J.D., University of Washington School of Law, 1991
  • Fellowship, Columbia University, 17th & 18th Century Chinese History, 1986-1988
  • B.A., Reed College, Anthropology, 1985, Phi Beta Kappa
Bar Admissions
  • Washington
Professional Recognition
  • Fellow, American College of Tax Counsel, 2012-2017
  • Listed in The Best Lawyers in America, 2013-2018 for:
    • Criminal Defense: White-Collar
    • Litigation and Controversy – Tax
  • Selected to Super Lawyers, Washington Law & Politics,  2013-2017
  • Fellow, American Bar Foundation, 2014- 2017

John employs his encyclopedic knowledge of tax law to develop legal theories and strategies in defense of his clients.  John keeps a vigilant finger on developments in the tax law, providing clients an unparalleled awareness of current developments and their implications.  In particular, he has a comprehensive command of international tax compliance rules and regulations, an area of the law that changes frequently.

John is a very active and respected member of the American Bar Association, serving as Chair of the Committee covering tax controversy matters.  He is often sought out to speak at a national level on various tax law issues, and has been intimately involved in drafting comments to proposed regulations on a variety of topics on behalf of the ABA Tax Section.  He also teaches Tax Crimes: Investigations, Prosecutions, and Penalties at the University of Washington School of Law.

John is a wine and food connoisseur and is always on the lookout for Seattle’s next great restaurant. He enjoys swimming and, in addition to tax news, is an avid reader of non-tax materials.

Professional Activities   

  • American Bar Association, Taxation Section Civil and Criminal Tax Penalties Committee, Vice-chair (2011-2015), Chair (2015- 2017)
  • Seattle Tax Group, Chair (2014), Member (2010- present)
  • Adjunct Lecturer, UW School of Law (2016, 2017)
  • ABA Taxation Section, Subcommittee for Legislative and Administrative Developments, Chair (2004-2012)
  • ABA Taxation Section, primary drafter of comments to preparer penalty regulations (§ 6694)
  • ABA Taxation Section, assisted drafting comments to list maintenance regulations (§ 6708)
  • ABA Taxation Section, assisted drafting comments to penalty regulations for failure to report IRS “reportable transactions” to the SEC (§ 6707A(e))

Presentations + Publications   

  • Captive Transaction Disclosures Remain for Now: Federal Court Rejects Last-Minute Injunction Request and Affirms Anti-Injunction Act Applies to Penalties, ABA Tax Times, June 2017
  • QDROs and Complex Retirement Plans, National Business Institute, 2015, 2017
  • Tax Litigation, Oregon Tax Institute, 2016
  • Privilege Issues In Criminal Investigations, ABA Nat’l Institute on Tax Fraud and Tax Controversy, 2016
  • Owe the IRS? Passports at Risk Under New Code Sec. 7345, Journal of Tax Practice and Procedure, Feb. 2016
  • International Taxation, Sterling Education, 2016
  • U.S. District Judge Rejects Tax Promoters’ Plea Agreement in United States v. Crithfield: A Rare Event, but a Warning to Defense Counsel, ABA Tax Times, June 2017
  • Challenging IRS Penalties, NYU Tax Controversy Forum, 2015
  • Tax Controversy Issues Pertaining to Captive Insurance Companies, Strafford Group, 2015
  • Litigation Valuation Issues in Tax Cases, ABA Institute on Criminal Tax Fraud, 2014
  • FBAR Requirements for Business Foreign Bank Accounts, Strafford Group, 2014
  • Audit Issues in Captive Insurance, ABA Business Law Section, 2014
  • Developments in Criminal Tax, AFDA White Collar Roundtable, 2014
  • FATCA Compliance and Implementation for FFIs: Mastering the Complexities Before the July 1 Deadline, Strafford Group, 2014
  • Ask the Experts: Top Tax Practice Tips and Representation Strategies, ABA Institute on Criminal Tax Fraud, 2013
  • FBAR Requirements for Business Foreign Bank Accounts, Strafford Group, 2013
  • Subcommittee Report on Legislative and Administrative Developments, ABA Section of Taxation, Civil and Criminal Tax Penalties, prepared three times a year 2004-2012
  • Preparer and Promoter Penalty Defenses, ABA Institute on Criminal Tax Fraud, 2012
  • International Audit Developments, Seminar Group, 2012
  • Flaws in the Façade: The Anti-Injunction Act After NFIB v. Sibelius and Cohen v. United States, ABA Section of Taxation, 2012
  • Drafting Pleadings in the Federal Courts in Tax Cases, The American Association of Attorney-CPAs, 2012
  • Tax Treatment and Consequences of Divorce, National Business Institute, 2011
  • IRS FBAR Enforcement, Stafford Group, 2011
  • Update on the Accuracy Penalty: The Slippery Slope to Strict Liability, ABA Section of Taxation; National “Last Wednesday” teleconference for the ABA, 2011

Millennium Tower
719 Second Ave. Suite 1450
Seattle, WA 98104