Tyler advises public and private clients on a broad range of U.S. federal corporate, partnership, and individual tax matters.
His practice includes advising on international and domestic mergers, acquisitions and divestitures, financial instruments and derivatives, lending transactions and other financings, debt and equity issuances, public charities and private foundations, and general tax planning. His experience spans various sectors, including banking, finance, real estate, private equity, life sciences, technology, consumer products, energy, and sports and entertainment.
Tyler focuses not only on structuring and executing transactions in a tax-efficient manner but also on integrating post-transaction operational strategies to optimize tax benefits while balancing non-tax considerations for other stakeholders. He also counsels non-profit clients on matters such as applying for and maintaining exemption from U.S. federal income tax, minimizing unrelated business taxable income, and structuring joint ventures and partnerships.
He has extensive experience assisting clients with renewable energy investments and credits, the partnership audit rules, the Foreign Investment in Real Property Tax Act (FIRPTA), the Foreign Account Tax Compliance Act (FATCA), Reports of Foreign Bank and Financial Accounts (FBAR), and information reporting compliance.
In addition to his transactional tax practice, Tyler represents both individual and business taxpayers in tax controversies and litigation, and has successfully assisted clients in resolving federal, state, and local tax disputes at the audit, appeal, and litigation stages.
Before joining the firm, Tyler practiced at two AmLaw 100 law firms and worked at Deloitte’s national tax office in Washington, D.C. He began his legal career as a law clerk to Judge Robert P. Ruwe of the United States Tax Court and Judge Patrick L. Woodward of the Maryland Court of Appeals.
New York University School of Law, LL.M., taxation
University of Maryland School of Law, J.D., magna cum laude, Order of the Coif
Shippensburg University, B.S.B.A., finance
American Bar Association, Tax Section
District of Columbia Bar Association
Maryland Bar Association
Pennsylvania Bar Association
United States Tax Court
Supreme Court of Maryland
Supreme Court of Pennsylvania
District of Columbia Court of Appeals
Co-authored amicus brief in Moore v. United States (docket no. 22-800, cert. granted June 26, 2023): Co-authored an amicus brief filed before the U.S. Supreme Court on behalf of the American College of Tax Counsel in connection with Moore v. U.S. The amicus, among other things, urged the Supreme Court to avoid ruling on the constitutionality of the “realization” requirement.
Co-authored amicus brief in In Re Grand Jury (docket no. 21-1397, cert. granted October 3, 2022): Co-authored an amicus brief filed before the U.S. Supreme Court on behalf of the Buckeye Institute in connection with In Re Grand Jury. The amicus advocated that the Court adopt a commonsense approach to applying the attorney-client privilege to so-called “dual-purpose communications” to provide confidence and uniformity across judicial circuits.
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