Derek Rose’s practice focuses primarily on federal and state tax controversy matters. With respect to federal tax controversy, he has successfully defended tax deductions in excess of $1 Billion in a transfer pricing audit as well as on issues including Subpart F income, permanent establishment, debt capacity, depreciation disputes, research tax credits, captive insurance and privilege issues. He has successfully argued in the Federal Circuit Court of Appeals and resolved numerous cases in the United States Tax Court.
With respect to state tax matters, in addition to successfully litigating cases on a variety of issues, including cost of performance, apportionment, classification of business income and the scope of legislative authority to tax, he has advised on nexus issues, property tax and unclaimed property. He also served as quasi-internal tax counsel for a Fortune 50 corporation during that client’s position vacancy supervising tax counsel and accountants on more than 100 active state tax controversies while interacting with corporate legal counsel to create issue resolutions consistent with broader corporate goals.
Mr. Rose is an adjunct professor at Washington University School of Law, where he teaches State and Local Taxation as part of the Masters in Taxation program. He has also taught and Fontbonne University and has spoken on a variety of federal and state tax issues.