Chicago
Advises clients on federal tax controversy matters and tax litigation across the technology, healthcare, and pharmaceutical sectors
Represents high-net-worth individuals and complex partnerships
Handles all stages of federal tax controversies, including audits, administrative appeals, alternative dispute resolution, and litigation
Counsels clients on domestic and international tax issues, including transfer pricing, research credits, Subpart F, and foreign tax credits
Susan E. Ryba focuses her practice on federal tax controversy matters and tax litigation, particularly advising clients in the technology, healthcare, and pharmaceutical sectors, as well as high-net-worth individuals and complex partnerships.
Susan has substantial experience in all stages of federal tax controversies, including audits, administrative appeals, alternative dispute resolution proceedings, and litigation. She has resolved most of her matters at the Internal Revenue Service (IRS) examination level or through the IRS Independent Office of Appeals (IRS Appeals) and other dispute resolution forums. She advises clients on a broad range of domestic and international tax issues, including transfer pricing, research credit, effectively connected income, passive activity losses, Subpart F, Section 965, economic substance and other related doctrines, worthless stock and debt deductions, foreign-derived intangible income, foreign tax credits, summons enforcement, and penalties.
Susan frequently speaks at seminars sponsored by the Tax Executives Institute and teaches trial skills for the National Institute for Trial Advocacy.
Ranked in
International Tax Review World Tax
Recommended in
Legal 500 US
- Resolved on favorable grounds a multibillion-dollar transfer pricing dispute for a technology company involving several intercompany services transactions with IRS Exam
- Facebook, Inc. v. Commissioner, 164 T.C. No. 9 (May 22, 2025). Taxpayer victory in a multibillion-dollar section 482 transfer pricing dispute regarding the arm’s-length value of a platform contribution transaction between cost-sharing participants under Treas. Reg. § 1.482-7.*
- Resolved several multibillion-dollar tax controversies at the IRS Appeals for technology and pharmaceutical companies involving transfer pricing issues, including intercompany licenses of intangible property, intercompany services, and platform contribution transactions
- Legal 500 US, Recommended, 2025
- Lawdragon, Leading Global Tax Lawyer, 2025-2026
- Crain’s Chicago Business, Notable Woman in Law, 2022
- International Tax Review World Tax, 2015-2023 and 2025-2026
- The Chicago Bar Association, member
- Illinois State Bar Association, member
- American Bar Association, member
- The Ohio State University Moritz College of Law, JD, magna cum laude, Order of the Coif
- Cornell University, BS, magna cum laude
- Illinois
- US Tax Court
- US District Court for the Northern District of Illinois
- US Court of Federal Claims
- English
