attorneys
attorneys
Practice Areas
Education
  • Montclair State University, B.A., 2005, graduated Magna Cum Laude
  • Georgia State University College of Law, J.D., 2008, graduated Magna Cum Laude
Bar Admissions
  • Pennsylvania
Court Admissions
  • U.S. Tax Court
  • U.S. Court of Federal Claims
  • Supreme Court of Pennsylvania
Dustin Covello
Associate

300 Conshohocken State Road
Suite 570
West Conshohocken, PA 19428
TEL: 610.772.2327
FAX: 610.772.2305

I am a tax attorney, specializing in international tax. I help growing manufacturing and technology companies reduce their tax and simplify their tax compliance obligations. I also help these companies and other taxpayers resolve their tax issues with the IRS. I work with international companies when they invest into the U.S. market and U.S. companies when they expand abroad.

International tax planning

I have helped clients establish new international operations, structure acquisitions and dispositions, issue debt and equity across borders, and minimize their worldwide effective tax rates. My recent international tax planning includes:

  • Planning a European beer company's acquisition of a U.S. craft brewer.
  • Advising a manufacturing company on transferring intangibles to its Swiss IP holding company.
  • Establishing U.S. operations for growing South African software company.
  • Helping foreign software company issue equity compensation to it U.S.-based executives.
  • Counseling foreign company on tax implications of factoring activities by U.S. subsidiary.
  • Advising foreign professional services firm in its establishment of office in first U.S. office.

International tax controversy

I have represented individuals, companies, and multinational conglomerates in international tax controversy matters. My experience runs the gamut from providing pre-filing advice, representing clients in IRS audits and appeals, and litigating cases. My recent tax controversy matters include:

  • Advising clients in tax compliance issues for their offshore holdings.
  • After a week-long trial, winning almost ninety percent of a $9 million tax case regarding the client's investment in a historic rehabilitation project. Gateway Hotel Partners, LLC v. Commissioner, T.C. Memo 2014-5 (2014).
  • Winning complete summary judgment in an $18 million case regarding the tax characterization of a company's settlement payment to its former minority shareholder. Colorcon, Inc. v. United States, 110 Fed.Cl. 650 (2013).
  • Winning full concession from IRS counsel in a transfer pricing dispute concerning intercompany sales by client's Thai subsidiary. Kohler Co. v. Commissioner, Docket No. 17477-12 (U.S. Tax Court, filed 2012).

Pro bono

I provide pro bono assistance to low-income taxpayers. I have represented them in tax controversies before the IRS and in the U.S. Tax Court, and I have prepared their tax returns under the IRS' Volunteer Income Tax Assistance program.

    News

    Articles & Publications

    • Rethinking the Tax Treatment of Government Assistance to Financial Institutions in Light of Treasury’s 2008 Capital Purchase Program, Journal of Taxation and Regulation of Financial Institution (Jan. 2012) (with Jonathan Prokup)
    • Transfer Pricing Dispute Resolution, United States, BNA Transfer Pricing Forum Vol. 2, No. 4 (Sept. 2011) (with Jonathan Prokup)
    • Federal Tax Law, 60 Mercer Law Review 1235 (2009) (with Svet Minkov and Jacquelyn Griffin) (surveying significant federal tax decisions decided in the 11th Circuit during 2008)
    • Federal Tax Law, 61 Mercer Law Review 1133 (2010) (with Gus Makris) (surverying significant federal tax decisions decided in the 11th Circuit during 2009)

    Speaking Engagements

    • Panelist, Exit Planning for Growth Companies at The Synergy of Legal and Accounting Strategies (December 2013)
    • Speaker, 2013 Tax Changes (focusing on impact of tax changes on the real estate industry) at Federation of Exchange Accommodators 2013 Northeast Regional Meeting (April 2013)
    • Presenter, What's Next For Offshore Bank Account Holders? at Hot Topics in Federal, State, and Local Taxation (May 2012)
    • Panelist, Financial Statements 101, An Accounting Primer for Tax Attorneys at ABA Tax Section 2011 Joint Fall CLE Meeting (October 2011)
    • Panelist, Find a Career in Tax at ABA Tax Section 2010 May Meeting (May 2010)