Overview

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.

  • U.S. Supreme Court, Moore v. United States: Co-authored an amicus brief on behalf of the American College of Tax Counsel, urging the Court to avoid ruling on the constitutionality of the “realization” requirement.
  • U.S. Supreme Court, In Re Grand Jury: Co-authored an amicus brief on behalf of the Buckeye Institute, advocating for a commonsense approach to applying the attorney-client privilege to “dual-purpose communications” to provide uniformity across judicial circuits.
  • New York University School of Law, LL.M., taxation
  • University of Maryland School of Law, J.D., magna cum laude, Order of the Coif
    • Mid-Atlantic Journal of Legislation and Public Policy, managing editor
  • Shippensburg University, B.S.B.A., finance
  • Maryland
  • Pennsylvania
  • District of Columbia
  • United States Tax Court
  • Supreme Court of Maryland
  • Supreme Court of Pennsylvania
  • Best Lawyers: Ones to Watch® in America, 2022 – 2025
  • American Bar Association, Tax Section
  • District of Columbia Bar Association
  • Maryland Bar Association
  • Pennsylvania Bar Association
  • Tax Court Holds that an Offshore Fund is Engaged in a U.S. Trade or Business, Tax Talks, Jan. 2, 2024

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