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Shawn O’Brien is nationally recognized by his peers and clients as a leading tax practitioner with a focus on tax litigation and controversies involving state, federal and international tax authorities. Drawing on his 25 years of experience, Shawn represents clients in tax examinations and administrative appeals and, when necessary, serves as a forceful advocate in litigation before the US Tax Court, US district courts, the US Court of Federal Claims, state courts and federal appellate courts. Shawn is the managing partner for the firm’s Houston office.

Clients interviewed in the Chambers USA Legal Guide 2024 shared that Shawn is “a trusted adviser and his level of service is superb” and he “has been a good strategic tax partner for our company,” particularly noting his “in-depth knowledge of our industry.”

Shawn’s experience spans a broad range of tax issues that affect many different industries, including energy, renewables, financial services, life sciences, manufacturing, media and entertainment, technology and aviation. He advises domestic, foreign and multinational corporations, partnerships, master limited partnerships, real estate investment trusts and limited liability companies on tax issues in connection with foreign and domestic transactions.

He also counsels clients in disputes involving transfer pricing, debt versus equity, loss carrybacks, international withholdings, advance pricing agreements, tax shelter disallowances, research and development tax credits, changes in accounting methods, captive insurance, related-party transactions, repatriation structures, inbound distributors, foreign credit transactions and penalty abatements. Shawn has also developed a market-leading federal and state excise tax practice that advises some of the largest corporations on excise tax planning and controversies.

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.

Samuel F. Hamer focuses his practice on US and international tax controversy matters. He advises on Internal Revenue Service examinations, supports transfer pricing analyses, and represents taxpayers in litigation before the US Tax Court and other federal courts.

Before joining McDermott Will & Schulte, Samuel served as a judicial law clerk to the Honorable Albert G. Lauber of the Tax Court. During law school, he clerked in the US Department of Justice, where he worked on tax cases before the Supreme Court of the United States and US Courts of Appeals. He also served as an editor of The Georgetown Law Journal.

Samuel maintains a long-standing pro bono practice counseling individuals on personal income tax issues.