Eric’s practice encompasses both tax controversy and business transactions. Eric has represented corporations, partnerships, nonprofits and individuals in federal, state and local tax disputes including audits, appeals and litigation before the Internal Revenue Service, CA Franchise Tax Board, CA Employment Development Department, CA Board of Equalization, San Diego County Assessor and other state taxing authorities. Eric’s expertise includes California residency audits and recent federal international tax enforcement initiatives, including offshore tax compliance. Eric also advises on complex business transactions, including structuring and planning corporate mergers and acquisitions, such as tax-free reorganizations, debt and equity restructuring, litigation settlements, employment and executive compensation related tax issues and the formation and operation of corporations, limited liability companies, S corporations and nonprofit organizations.
Eric is admitted to practice in the United States Tax Court, United States Court of Federal Claims and the United States District Court, Southern District of California.
Eric previously worked as an attorney for the IRS Office of Chief Counsel in San Diego and most recently at DLA Piper (formerly Gray Cary Ware & Freidenrich LLP) in San Diego.
- LL.M. (Taxation), University of San Diego School of Law
- JD, Southern Illinois University School of Law
- BS (Accounting), Millikin University
- V. Judson Klein Award for Tax Excellence – 2014
- Martindale-Hubbell® AV Preeminent Rating
- Southern California's Top Rated Lawyers – 2012-2015
- Top Rated Lawyer in Technology Law – 2013
- The State Bar of California – Chair International Tax Committee, Past Chair Income and Committee, Past Member Taxation Section Executive Committee
- Pacific Beach Community Foundation – Past Director, Past President
- San Diego County Bar Association – Past Taxation Section Chair
- University of San Diego School of Law – Past Adjunct Professor – LLM Program
Recent News Coverage
- "2015 Top Lawyers," San Diego Magazine, March 2015.
- “Procopio's Swenson to receive State Bar award for tax practice,” The Daily Transcript, September 16, 2014.
- "Procopio's Swenson to Receive V. Judson Klein Award," Procopio Press Release, September 15, 2014.
- Sherwin, Doug. “Procopio represents Cosmo Pharmaceuticals in merger,” The Daily Transcript, July 29, 2014.
- “Procopio Represents Italian Pharma Company in Merger,” Procopio Press Release, July 24, 2014.
- Fracassa, Dominic. “Procopio represents Italian drugmaker in sale to Salix,” Daily Journal, July 11, 2014.
- "2014 Top Lawyers,” San Diego Magazine, March 2014.
- "2013 Top Lawyers,” San Diego Magazine, March 2013.
- "The Internal Revenue Service Addresses the Federal Income Taxation of Per Capita," Procopio Blogging Circle, October 1, 2015.
- “Starting the Race Against the IRS in the International Income Tax World – Statute of Limitations and Lack of Filings,” International Tax Journal, CCH Wolters-Kluwer, January-February 2015.
- “FATCA: A Primer and Current Practical Developments,” International Tax Journal, CCH Wolters-Kluwer, January-February 2015.
- Co-author. "FATCA: Desarrollo Base y Practicas Actuales", January 2015 published by Consejero Empresarial
- “Tribal General Welfare Exclusion Act of 2014 provides Many New Benefits to Tribes and their Tribal Members Beyond the General Welfare Exclusion,” Procopio Blogging Circle, January 28, 2015.
- "Renewable Energy Tax Reform - Where Are We Today," December 9, 2014.
- “Year 2014 Tax Update -Sorting out the Prior 2013 Law Changes and Bracing for the Possible Tax Law Changes in Late 2014,” San Diego County Bar Association, July 14, 2014.
- Co-author with Theodore J. Griswold. “The Internal Revenue Service Issues Important Final Guidance on the Application of the General Welfare Exclusion to Certain Tribal Government Programs,” July 2, 2014.
- "Mexico and U.S. Rules Regarding The Assessment of Tax Deficiencies – A Comparative Study," International Tax Journal, CCH Wolters Kluwer, January-February 2014
- "The IRS’s Current Offshore Voluntary Disclosure Program: Is This the Only Option Available for An 'Accidental American'?", International Tax Journal, CCH Wolters Kluwer, January-February 2014
- “Privileged” Information for the World Citizen When Communicating with Tax Attorneys in Multiple Jurisdictions," International Tax Journal, CCH Wolters Kluwer, January-February 2014
- Co-author with Theodore J. Griswold. "Possible Tax Benefits Relating to the Lease of Native American Tribal Land - An Important Clarification for All Parties Subject to a Lease on Tribal Land," January 16, 2014.
- Contributing author. “Mexico’s Proposed Tax Reform: International and Cross border Highlights," October 2013.
- Moderator "International Tax Audit & Appeals Including Statute of Limitations in the International Context," 2015 California Tax Bar and California Tax Policy Conference, November 6, 2015.
- Moderator "Foreign Targets: IRS International Criminal Investigations: FIFA," USD Procopio International Tax Institute, October 23, 2015.
- Co-Presenter. “OVDP and FATCA Update: The Nuts and Bolts of Streamlined Filing and Proving Non-Willfulness,” University of San Diego, School of Law, June 25, 2015
- “A Dozen Tax Issues Every Business Attorney Must Understand,” Procopio Business and Technology Team, San Diego, CA, December 18, 2014.
- Moderator. "Recent Developments in International Criminal Tax," USD Procopio International Tax Institute, October 31, 2014.
- Moderator. "International Tax Audits & International Tax Appeals," USD Procopio International Tax Institute, October 30, 2014.
- “Money for Lunch Talk Show,” BlogTalkRadio, September 25, 2014.
- “OVDP and FATCA update: The Ever Changing Issues of International Tax Compliance,” University of San Diego, School of Law, June 26, 2014
- "How to Survive an Audit or Difficult Tax Controversy; what to expect when the tax authorities come knocking," San Diego CPA Education Association, May 13, 2014.
- “Personal Tax Issues and Strategies,” FEI San Diego, San Diego, CA, January 23, 2014.
- “FATCA, OVDI, and More…,” 17th Annual San Diego Tax and Accounting Institute, San Diego, CA, November 22, 2013.
- Moderator. “Starting the Race Against the Tax Authority in the International Tax World – Statute of Limitations & Lack of Filings,” USD School of Law-Procopio International Tax Institute, San Diego, CA, October 2013.
- “2013 Tax Update,” Business Sections of the San Diego County Bar Association, San Diego, CA, July 25, 2013.
- “Tax Considerations for Small Business Owners,” Filipino American Chamber of Commerce of San Diego County and the Filipino American Lawyers of San Diego: Small Business Legal Symposium, March 9, 2013.