David Fischer represents clients in complex, high-stakes tax controversies.
For nearly 40 years, David has worked with IRS Appeals, the Advance Pricing Agreement (APA) program and US Competent Authority, and fast-track and other IRS alternative dispute resolution programs to resolve complex tax matters, and he has litigated against the IRS in US Tax Court, the Court of Federal Claims, and district courts.
David’s current emphasis is international tax issues, transfer pricing, environmental tax credits, domestic manufacturing production deductions and complex financial transactions. He has extensive experience working in a variety of industries including software, health care, financial, oil and gas, and hospitality.
David is recognized as a top tax lawyer in Chambers USA in the area of Nationwide Tax Controversy and in Best Lawyers in America in the Tax Law Practice area. He is a member of the Court Practice and Procedure Committee of the American Bar Association Section of Taxation and a regular speaker before the Tax Executives Institute, the ABA, and other professional organizations. David has an active pro bono practice, assisting individuals in claiming Child Tax Credits and representing charitable organizations before the IRS in tax controversies.
Latest Insights
- legal updatesTax Bytes: Week of January 12, 2026
- legal updatesIRS provides new option for navigating differences between customs and transfer pricing values
- legal updatesExpected flurry of executive actions leaves open questions for the energy tax credits under the IRA at the start of Trump’s second term
Latest News
- firm news34 Eversheds Sutherland Practice Areas, 81 Attorneys Named Among Nation’s Best in 2023 Chambers USA
- media mentionsLaw360: Eversheds Adds Crowell & Moring Tax Trio In DC
- firm newsEversheds Sutherland Continues to Strengthen Premier Tax Practice Group with Prominent Federal Tax Controversy Trio
- Led industry-wide resolution of amortization of baseball player contracts through the IRS industry issue resolution program.
- Represented public companies concerning cost sharing buy-in payments before IRS Appeals, including case considered for designation for litigation.
- Represented multinational retail company in transfer pricing dispute before U.S. Competent Authority, fully conceded without need for government-to-government negotiation.
- Represented public software company on US taxation of transfer of intellectual property to Luxembourg.
- Representing public hospitality company on multilateral advance pricing agreement.
- Transfer Pricing Hot Topics, March 4, 2026, Eversheds Sutherland Developments in Tax Administration, Controversy and Enforcement (ACE) Seminar
- State of the IRS, November 13, 2025, TEI St. Louis Federal Tax Program
- 2025 Federal Tax Case Highlights, November 6, 2025, Eversheds Sutherland and TEI Philadelphia Chapter Year-End Tax and Legal Seminar
- Litigation Hot Topics, September 11, 2025, Eversheds Sutherland Developments in Tax Administration, Controversy and Enforcement (ACE) Seminar
- Mistakes were Made: Considerations for Addressing Errors in Tax Filings (Ethics Panel), September 11, 2025, Eversheds Sutherland Developments in Tax Administration, Controversy and Enforcement (ACE) Seminar
- State of the IRS, September 11, 2025, Eversheds Sutherland Developments in Tax Administration, Controversy and Enforcement (ACE) Seminar
- Key Developments in Tax Controversy, May 29, 2025, FBA Insurance Tax Seminar
- Transfer Pricing Hot Topics, May 1, 2025, Eversheds Sutherland Developments in Tax Administration, Controversy and Enforcement (ACE) Seminar
- The Role of Substance in Tax Planning, April 24, 2025, TEI Silicon Valley Chapter Spring Federal Tax Update
- A Supreme Year for Tax Controversy: Understanding the Significance of Recent Tax Cases, November 7, 2024, Eversheds Sutherland Philly Tax Day Year-End Seminar
- The Ever-Changing Tax Landscape, Part 2 | The View from Abroad: International Tax Reforms and Implications for U.S. Multinationals, November 7, 2024, Eversheds Sutherland Philly Tax Day Year-End Seminar
- Implicit support from group membership – An emerging global transfer pricing issue, February 7, 2024
- Mistakes were Made: Considerations for Addressing Errors in Tax Filings, November 2, 2023, Philly Tax Day
- Developments in Tax Controversy and Transfer Pricing, September 22, 2023, TEI New England
- Global viewpoints on Transfer Pricing litigation, June 13, 2023
- Demystifying APA and Competent Authority Procedures: The Good, the Bad, and the Ugly, February 14, 2023, TEI Houston Chapter Tax School
- International Tax Controversy – APAs, Competent Authority, and MAP Proceedings, October 26, 2022, TEI 77th Annual Conference
- Recent Developments at IRS Appeals, October 7, 2022, Managing Tax Audits and Appeals Seminar 2022
- Transfer Pricing in Flux, October 6, 2022, Managing Tax Audits and Appeals Seminar 2022
- IRS Update, May 3, 2022, 87th Annual Federal Tax Forum
- Tax Reform Redux; Seizing Opportunities and Mitigating Risks, March 22, 2022, Tax Executives Institute Hybrid 72 Midyear Conference
- Developments at the Independent Office of Appeals, October 8, 2021, Crowell & Moring's Managing Tax Audits and Appeals Seminar 2021
- Recognized by Chambers USA: Guide to Leading Business Lawyers in the area of tax controversy (2021-2025) and tax (2025)
- Named to Best Lawyers in the area of tax law (2024-2026)
- Recognized by The Legal 500 United States in the area of US taxes: contentious (2023-2025); international tax (2024)
- District of Columbia
- U.S. Tax Court
- U.S. Court of Federal Claims
- U.S. Court of Appeals for the Sixth Circuit
- U.S. Court of Appeals for the Seventh Circuit
- J.D., with high honors, George Washington University Law School
- B.A., with high honors, Michigan State University