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525 B Street, Suite 2200
San Diego, California 92101
Direct Phone: 619.515.3235
Direct Fax: 619.744.5415
eric.swenson@procopio.com
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Eric D. Swenson’s practice encompasses both tax controversy and tax planning. Mr. Swenson has represented corporations, partnerships, nonprofits, and individuals in federal, state, and local tax disputes including audits, appeals, and litigation before and against 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.

Mr. Swenson’s expertise includes California residency audits and recent federal international tax enforcement initiatives, including offshore tax compliance. Mr. Swenson 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.

Mr. Swenson 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.

Mr. Swenson 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.

Education
  • LL.M. (Taxation), University of San Diego School of Law
  • JD, Southern Illinois University School of Law
  • BS (Accounting), Millikin University
Distinctions
  • Martindale-Hubbell® AV Preeminent Rating
  • Southern California's Top Rated Lawyers - 2012-2014
  • Top Rated Lawyer in Technology Law – 2013
Community Involvement
  • Pacific Beach Community Foundation – Director, Past President
  • San Diego County Bar Association – Former Taxation Section Chair
  • The State Bar of California – Former Chair Income and Other Committee of Taxation Section; Former Member Taxation Section Executive Committee
  • University of San Diego School of Law – Adjunct Professor – LLM Program

Recent News Coverage

Recent Publications
Recent Seminars
  • “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.
  • “U.S. Criminal and Civil Tax in International Transactions – Recent Developments and Forensic Accounting,” Moderator, 2012 USD School of Law – Procopio International Tax Institute, October 26, 2012.
  • “The Taxation of Judgments and Settlements,” The State Bar of California 85th Annual Meeting, Monterey, CA, October 12, 2012.
  • “International Tax Enforcement and Expanded Reporting Obligations,” 2012 Annual Income Tax Seminar, San Diego, CA, June 22, 2012.
  • "The 2011 Offshore Voluntary Disclosure Initiative: How it Works and Who May Benefit," 2011 Annual Income Tax Seminar, Costa Mesa, CA, June 17, 2011.
  • “Equity Compensation Tax Considerations for Start-Ups,” Entrepreneur's Forum: Procopio’s Winning Strategies for Start-Ups and Emerging Growth Companies, San Diego, CA, January 27, 2011.