Steve Barge's practice is a distinct blend of a robust tax controversy and litigation practice coupled with domestic and cross-border corporate and business tax planning and transactional knowledge. His deep experience spans multiple industries in which he has negotiated and structured acquisitions, dispositions, expansions, contractions, restructurings, and financing transactions for corporate and pass-through entities in the United States and abroad. Steve has resolved numerous complex US federal and state tax controversies at the audit, appeal, and litigation stages that span a variety of industries. His deep understanding of tax law and strategic approach have been instrumental in successfully defending clients against a wide range of tax assessments and penalties. Steve's transactional work focuses not only on pre-transaction design and execution but also on post-transaction integration structures that obtain maximum tax benefits and preserve favorable tax attributes while balancing non-tax issues of other stakeholders. He has prepared and received numerous private rulings and technical advice memoranda from the IRS National Office and foreign taxing authorities. Steve is experienced in virtually all aspects of United States federal taxation that affect business activities and brings a practical and collaborative approach to the most sophisticated issues facing taxpayers in the United States taxing regimes.