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Michael QUIGLEY Attorney (Admitted in California and District of Columbia)

Michael QUIGLEY Attorney
Michael QUIGLEY Attorney

Michael QUIGLEYAttorney (Admitted in California and District of Columbia)

T.+82-2-3703-1042 F.+82-2-737-9091/9092 E.michael.quigley@kimchang.com

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Bio

Michael Quigley is a US lawyer and a tax partner at Kim & Chang in Seoul, Korea. For more than thirty years, he has concentrated on the resolution of tax disputes by negotiation, alternative dispute resolution and litigation.

Mr. Quigley has tried more than 50 civil tax cases before the US Tax Court, the US Court of Federal Claims and many US federal district courts. These cases include disputes over transfer pricing, civil fraud penalties, jeopardy assessments, debt/equity issues, valuations, tax deferred exchanges, exempt organization UBIT, excise taxes, partnerships and TEFRA procedural issues, life insurance company taxation, export incentives under the DISC/FSC regime, disallowed corporate deductions under 162(f), and many other provisions of the Internal Revenue Code. His tax litigation experience is extensive, and he has been nationally ranked in the United States by Chambers & Partners, has been a master of the Inns of Court, and is frequently called upon to serve as lead tax litigation counsel.

Mr. Quigley is a leading authority on intercompany transfer pricing, tax treaties, permanent establishment issues and other tax matters affecting multinational corporations. He has represented clients in obtaining advance pricing agreements with the IRS and the tax authorities of many other jurisdictions including obtaining some of the first APAs between the United States and Korea and Japan. He has appeared before the US Competent Authority and the competent authorities of many other countries including Korea, India and Japan, among others, and is experienced in the use of the mutual assistance provisions of tax treaties to eliminate double taxation.

For many years Mr. Quigley has studied the economic, business and political affairs of the Republic of Korea and the Korean Peninsula, with a particular emphasis on US-Korea relations. He has a developed interest in Japan and its relations with the United States and Korea and with US-India relations and the political and economic affairs of India. More broadly, Mr. Quigley is keenly focused on US relations with Asia.

Profile

Experience

  • Kim & Chang (2012-Present)
  • White & Case LLP (2006-2012)
  • Chair, Federal Bar Association Section of Taxation (1993-1994, 1995-1996)
  • Akin, Gump, Strauss, Hauer & Feld (1992-2005)
  • Cadwalader Wickersham & Taft (1987-1992)
  • U.S. Department of Justice, Tax Division (1983-1987)

Representative Activitiesshow

Awards

  • Leading Lawyer, Who’s Who Legal: Korea, Corporate Tax (Who’s Who Legal, 2019) 
  • Chambers USA – National: Tax Litigation – Tier One 
  • Euromoney's Guide to the World's Leading Transfer Pricing Advisors 
  • Euromoney's The Best of the Best – Transfer Pricing 
  • Euromoney's Guide to the World's Leading Tax Advisors 
  • International Tax Review – Tax Controversy Leaders

Education

    Pepperdine University School of Law (J.D., cum laude, 1983)

    University of California, Berkeley (B.A., 1980)

Qualifications

    Admitted to bar, California 1983; District of Columbia, 1989

    U.S. Court of Federal Claims (1991)

    U.S. Supreme Court (1988)

    U.S. Tax Court (1987)

Languages

English

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Michael QUIGLEY
Attorney (Admitted in California and District of Columbia)


T. +82-2-3703-1042      
F. +82-2-737-9091/9092
     


  




Michael Quigley is a US lawyer and a tax partner at Kim & Chang in Seoul, Korea. For more than thirty years, he has concentrated on the resolution of tax disputes by negotiation, alternative dispute resolution and litigation.

Mr. Quigley has tried more than 50 civil tax cases before the US Tax Court, the US Court of Federal Claims and many US federal district courts. These cases include disputes over transfer pricing, civil fraud penalties, jeopardy assessments, debt/equity issues, valuations, tax deferred exchanges, exempt organization UBIT, excise taxes, partnerships and TEFRA procedural issues, life insurance company taxation, export incentives under the DISC/FSC regime, disallowed corporate deductions under 162(f), and many other provisions of the Internal Revenue Code. His tax litigation experience is extensive, and he has been nationally ranked in the United States by Chambers & Partners, has been a master of the Inns of Court, and is frequently called upon to serve as lead tax litigation counsel.

Mr. Quigley is a leading authority on intercompany transfer pricing, tax treaties, permanent establishment issues and other tax matters affecting multinational corporations. He has represented clients in obtaining advance pricing agreements with the IRS and the tax authorities of many other jurisdictions including obtaining some of the first APAs between the United States and Korea and Japan. He has appeared before the US Competent Authority and the competent authorities of many other countries including Korea, India and Japan, among others, and is experienced in the use of the mutual assistance provisions of tax treaties to eliminate double taxation.

For many years Mr. Quigley has studied the economic, business and political affairs of the Republic of Korea and the Korean Peninsula, with a particular emphasis on US-Korea relations. He has a developed interest in Japan and its relations with the United States and Korea and with US-India relations and the political and economic affairs of India. More broadly, Mr. Quigley is keenly focused on US relations with Asia.






    •   Kim & Chang (2012-Present)
    •   White & Case LLP (2006-2012)
    •   Chair, Federal Bar Association Section of Taxation (1993-1994, 1995-1996)
    •   Akin, Gump, Strauss, Hauer & Feld (1992-2005)
    •   Cadwalader Wickersham & Taft (1987-1992)
    •   U.S. Department of Justice, Tax Division (1983-1987)





Awards

  •   Leading Lawyer, Who’s Who Legal: Korea, Corporate Tax (Who’s Who Legal, 2019) 
  •   Chambers USA – National: Tax Litigation – Tier One 
  •   Euromoney's Guide to the World's Leading Transfer Pricing Advisors 
  •   Euromoney's The Best of the Best – Transfer Pricing 
  •   Euromoney's Guide to the World's Leading Tax Advisors 
  •   International Tax Review – Tax Controversy Leaders





Education

    Pepperdine University School of Law (J.D., cum laude, 1983)

    University of California, Berkeley (B.A., 1980)


Qualifications

    Admitted to bar, California 1983; District of Columbia, 1989

    U.S. Court of Federal Claims (1991)

    U.S. Supreme Court (1988)

    U.S. Tax Court (1987)


Languages
  •    English





Tax ,  Transfer Pricing ,  Tax Audit & Tax Dispute Resolution