Overview
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.
Results
- 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
- Represented Thomson Reuters in a Section 482 transfer pricing dispute regarding the arm’s-length amount of various intercompany services under Treas. Reg. § 1.482-9 (Thomson Reuters America Corporation & Subsidiaries v. Commissioner (US Tax Court, Docket No. 20288-16)) *
- Litigated the first transfer pricing case in Mauritius for a technology company*
- Successfully represented technology and automotive industry companies during their IRS audits of Section 41 research credits
- Successfully resolved a multimillion-dollar worthless stock issue at IRS Appeals for a large multinational corporation
- Successfully defended against the imposition of various multimillion-dollar accuracy-related penalties at both IRS Appeals and IRS Exam
- Obtained a full concession by IRS Exam of a withholding tax issue for a European multinational corporation*
- Obtained a full concession by IRS Exam for a technology company regarding a multibillion-dollar adjustment based on an economic substance challenge to a reorganization*
- Represented Starbucks in a dispute regarding whether certain royalty payments are deductible or must be capitalized under Section 263A (Starbucks Corporation v. Commissioner (US Tax Court, Docket No. 14432-11)) *
- Successfully resolved a dispute for a technology company regarding the deductibility versus the capitalization of acquisition costs at IRS Appeals*
- Successfully resolved a multimillion-dollar dispute involving application of the passive activity rules under Section 469 at IRS Exam
*Matter handled prior to joining the firm.
Recognitions
- Legal 500 US, Recommended, 2025
- Lawdragon, Leading Global Tax Lawyer, 2025
- Crain’s Chicago Business, Notable Woman in Law, 2022
- International Tax Review World Tax, 2015-2023 and 2025-2026
Community
Credentials
Education
The Ohio State University Moritz College of Law, JD, magna cum laude, Order of the Coif, 2006
Cornell University, BS, magna cum laude, 2003
Courts/Agencies
US Tax Court
US District Court for the Northern District of Illinois
US Court of Appeals for the Second Circuit
