Global Network Leader, Tax Controversy and Dispute Resolution, PwC US
David Swenson is the Global Leader of PwC’s Tax Controversy and Dispute Resolution (TCDR) Network, and is resident in Washington, D.C. The TCDR Global Network includes over 650 tax controversy professionals, located in 45 countries across the globe, who assist multinational companies in dealing with tax audits and disputes worldwide.
Following a prominent legal career spanning 25 years, David has substantial experience in advising multinational corporations (MNCs) on international tax matters, and assisting MNCs pursue a variety of strategies and measures aimed at proactively preventing, efficiently managing, and favorably resolving tax audits and disputes across the globe. Over the years, David has participated in more than 300 tax controversies involving audits and disputes between MNCs and the IRS, as well as dozens of other revenue authorities around the world.
Many of these tax disputes were resolved at the audit level or through the proactive use of administrative appeals, mediation, arbitration, APAs, or the competent authority / MAP process. Other controversies were docketed in a U.S. court of law, proceeded to trial, and resulted in landmark decisions for MNCs, including cases involving transfer pricing (Eli Lilly, Bausch & Lomb I, and Xilinx), the foreign tax credit (Ampex), competent authority matters (Yamaha Motors I), the definition of "manufacturing" for Subpart F purposes (Bausch & Lomb II), foreign currency (Carborundum), and intellectual property rights (Exide / Exxon). David also participated in several seminal tax cases before the U.S. Supreme Court, including the Barclays Bank, Boeing, and Goodyear cases.
David has been described as "one of the top five tax controversy experts in the U.S.," and he received recognition as a "Leading Attorney" in the area of U.S. Tax Litigation by Chambers U.S., as one of the world's top 25 transfer pricing specialists, as a “First Tier” leading tax controversy advisor by the International Tax Review, and received a Meritorious Service Certificate from the Treasury Department and IRS.