David Swenson is the global leader of PwC’s tax controversy and dispute resolution (TCDR) network and is resident in the Washington, DC office. The TCDR global network includes more than 1000 tax controversy professionals, located in upwards of 80 countries across the globe, who assist multinational enterprises to prevent, manage, and resolve tax audits and disputes worldwide.
Following a prominent legal career spanning 25 years, David has substantial experience in advising multinational enterprises (MNEs) on international tax matters, and assisting companies in their efforts to pursue a variety of measures aimed at proactively preventing, efficiently managing, and favourably resolving tax audits and disputes worldwide. Over the years, David has participated in more than 250 tax controversies involving audits and disputes between MNEs and the Internal Revenue Service (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 US court of law, proceeded to trial, and resulted in important decisions for MNEs, including cases involving transfer pricing (Bausch & Lomb I), the foreign tax credit (Ampex), Competent Authority matters (Yamaha), 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 landmark tax cases before the US 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 US”, and he received recognition as a “leading attorney” in US tax litigation by Chambers US, and as one of the world’s top 25 transfer pricing specialists.
In addition, David received a Meritorious Service Certificate from the Treasury Department and IRS, and has been an adjunct professor at Georgetown University Law Center, where he continuously taught courses for 25 years relating to international corporate income taxation. David received his MLT from Georgetown University Law School, and his JD, with honours, and BA, with distinction, from the University of Mississippi. David also has been admitted to practice before the US Tax Court, the US Court of Federal Claims, numerous US Federal Courts of Appeal, and the US Supreme Court.
