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Partnership Representative

Education

  • LL.M. in Taxation, Georgetown University Law Center, 1999
  • J.D., Syracuse University College of Law, 1993, cum laude
  • B.S., George Mason University, 1990, with distinction

Bar and Court Admissions

  • New York
  • District of Columbia
  • U.S. Tax Court
  • U.S. District Court, District of Columbia
  • U.S. District Court, Southern District of New York
  • U.S. Court of Federal Claims
  • U.S. Court of Appeals, Federal Circuit
  • U.S. Court of Appeals, Seventh Circuit
  • U.S. Bankruptcy Court, District of Columbia
  • District of Columbia Court of Appeals

Other Professional Affiliations

Past Chair, D.C. Bar (Tax Section, Tax Audits and Litigation Committee)

American Bar Association (Section of Taxation)

U.S. Tax Court's J. Edgar Murdock Inn of Court

Government Experience

U.S. Department of Justice, Tax Division, 1996-2003

IRS Office of Chief Counsel, 1993-1996

Charles M. Ruchelman

Member, Washington, D.C.
(202) 862-7834
cruchelman@capdale.com | v-card | PDF

"a great litigator, a good strategic thinker and an excellent advocate"   - Chambers USA

Mr. Ruchelman is a Member in Caplin & Drysdale's Washington, D.C., office, where he concentrates his practice in tax litigation and controversies with the Internal Revenue Service and other tax authorities. He also represents clients in general tax matters.

Services

Mr. Ruchelman has extensive experience in resolving tax matters at all stages of tax disputes including IRS examinations, IRS appeals, post-appeals mediation, trial court litigation, and appellate litigation. He has litigated cases in the U.S. Tax Court, various U.S. district courts, and the U.S. Court of Federal Claims.

Building on his experience with the TEFRA partnership provisions, 
Mr. Ruchelman has spent a significant amount of time studying, speaking on, and writing about the new IRS tax and collection procedures relating to partnerships and limited liability companies that were recently enacted under the Bipartisan Budget Act of 2015. Since enactment of the new statute, Mr. Ruchelman has spoken on panels with a Tax Court judge, government officials from the Treasury Department and IRS Office of Chief Counsel, as well as other practitioners before the American Bar Association, American Institute of CPAs, DC Bar Association, and Bloomberg/BNA.

Highlights

  • Currently representing numerous clients in all stages of Internal Revenue Service examinations and Government investigations involving foreign accounts and foreign entities.
  • Reached global settlement with IRS Office of Chief Counsel in 80 separate Tax Court cases involving common employee benefit plan tax issues.
  • Represented third-party witness in Amazon.com Inc. & Subsidiaries transfer pricing case before the U.S. Tax Court.
  • Represented a large Wall Street financial services firm in appeal to the 7th Circuit Court of Appeals (JPMorgan Chase & Co. v. C.I.R., 530 F.3d 634 (7th Cir. 2008)).
  • Represented a hedge fund and its tax matters partner in a three-way IRS examination that led to litigation with the IRS and an adverse partner in the U.S. Court of Federal Claims (Imprimis Investors LLC v. United States, 83 Fed. CI. 46 (2008)).
  • Successfully defended Hawaii Department of Taxation and its employees against unlawful disclosure claims in the U.S. District Court (Marsoun v. United States, 525 F. Supp.2d 206 (D. D.C. 2007)).
  • Represented an international accounting firm in litigation concerning privilege issues (United States v. BDO Seidman LLP, 2004 WL 1470034 (N.D. Ill, June 28, 2004)).
  • Represented a tax attorney in proceedings brought by the IRS Office of Professional Responsibility in the U.S. administrative court. IRS conceded significant issues on the eve of trial.
  • Achieved a favorable settlement for a high-net-worth family in an IRS examination involving family limited partnership issues.
  • Attained a favorable settlement for a high-net-worth individual in an IRS examination involving a contribution of a conservation easement.
  • Successfully resolved an examination involving promoter penalty issues in IRS post-appeals mediation.
  • Obtained a complete abatement and refund of over $600,000 of late filing, late payment, and late deposit penalties for multiple years for an oil services company relating to cross-border leasing payments and Form 1042.

Other Representative Matters

Mr. Ruchelman has represented clients before the IRS examination division, IRS Appeals, or in court involving the following substantive tax issues: IRS collections, family limited partnerships, contributions of conservation easements; estate and gift taxes, oil and gas partnerships, residency issues, restricted interest, employee benefits, and tax shelter disclosures. He also has considerable experience responding to IRS third-party summonses.

Government Experience

Before joining Caplin & Drysdale, Mr. Ruchelman was a Trial Attorney with the U.S. Department of Justice, Tax Division, and an Attorney with the Internal Revenue Service, Office of Chief Counsel.

While at the Department of Justice, he litigated tax cases in the federal district courts and the U.S. Court of Federal Claims. For his work representing the government in extended trials involving the IRS's attack on leveraged corporate-owned life insurance as a tax shelter, Mr. Ruchelman received the Attorney General's Distinguished Service Award.

Professional Activities

Mr. Ruchelman recently completed his tenure as Chairman of the Tax Audits and Litigation Committee for the Tax Section of the D.C. Bar. This committee presented monthly panel discussions on hot topics in the tax audits and litigation arena and frequently interacted with IRS and DOJ tax officials. He is also an active member of the American Bar Association Section of Taxation, the Court of Federal Claims Bar Association, and the U.S. Tax Court's J. Edgar Murdoch Inns of Court.

Awards & Rankings

  • Chambers USA, 2016-Present
  • The Legal 500, Top-Tier Firm, Tax - US Taxes - Contentious, 2010, 2015-Present
  • The Legal 500, Leading Lawyer, 2011, 2012; Recommended, 2014
  • Super Lawyers, Washington, D.C., 2013-Present
  • Above the Law, Tax Firm Power List, 2016
  • The Washington Post, Top Attorneys in D.C., 2014

Recent News

Click here for a full list of media coverage.

Recent Speaking Engagements

  • Panelist, Captive Legal and Tax Insights, Kentucky Captive Association, 2017 Kentucky Captive Association Educational Conference, June 16, 2017
  • Panelist, TOIs, Investigations, and Campaigns – the Tools of the IRS, Delaware Captive Insurance Association Spring Forum, May 8, 2017
  • Panelist, Part 5 of 6 Pass-Throughs and Real Estate and Part 6 of 7 Tax Audits and Litigation Tax Series: Exploring the Proposed BBA Partnership Audit Regulations, D.C. Bar, April 5, 2017
  • Speaker, Captive Insurance: New IRS Tax Reporting Regime, AICPA, December 19, 2016
  • Speaker, Captive Insurance: New IRS Tax Reporting Regime Potential for Penalties and Examinations, Bloomberg BNA, December 9, 2016
  • Speaker, Small Captive Insurers and the New IRS Reporting Regime, Delaware Captive Insurance Association, December 1, 2016
  • Moderator, Fundamental Partnership Audit Reform, Part 2 - What's a Practitioner to Do?, District of Columbia Bar, Taxation Section, June 23, 2016
  • Speaker, New Tax Laws Relating to IRS Examination of and Tax Collection from Partnerships, American Institute of CPAs, May 16, 2016
  • Moderator, Litigating Partnership Tax Cases Under the New Partnership Tax Rules of the Bipartisan Budget Act of 2015, American Bar Association Section of Taxation, May 6, 2016
  • Speaker, New Tax Laws Relating to IRS Examination of and Tax Collection from Partnerships: Understanding the Nuances of the New Legislation, Bloomberg BNA, April 21, 2016
  • Speaker, New Tax Laws Relating to IRS Examination of and Tax Collection from Partnerships, District of Columbia Bar, February 2, 2016
  • Speaker, New Tax Laws Relating to IRS Examination of and Tax Collection from Partnerships, Bloomberg BNA, January 26, 2016
  • Panelist, IRS Summons Update - Trends and Recent Developments in the Use and Enforcement of IRS Summonses, District of Columbia Bar, Tax Audits and Litigation Tax Series, December 12, 2013
  • Speaker, Ins and Outs of IRS Audits of Partnerships and S Corps, University of Virginia, School of Law, 65th Annual Virginia Conference on Federal Taxation, June 7, 2013
  • Moderator, The Outer Limits of Tax Jurisdiction in the U.S. Court of Federal Claims, Court of Federal Claims Bar Association and Caplin & Drysdale, April 23, 2013
  • Panelist, Global High Wealth Industry Group Examinations, District of Columbia Bar, Tax Audits and Litigation Tax Committee, February 26, 2013
  • Presenter, Bank of New York v. Commissioner Case, Federal Bar Association, Practice and Procedure Discussion Group, February 25, 2013
  • Panelist, Tax Court Law Clerk CLE Presentation, U.S. Tax Court CLE Program, December 11, 2012
  • Speaker, Resolving IRS Tax Controversies, How to Prepare for Audits and Appeals, Resolve IRS Disputes, Mitigate Penalties and Understand Alternative Dispute Resolution Methods, Bloomberg BNA, June 13, 2011
  • Moderator, Common Evidentiary Issues in Tax Cases, American Bar Association, 2011 May Meeting, May 6, 2011
  • Moderator, When, Where, and How, District of Columbia Bar, The Employment Tax National Research Program, May 27, 2010
  • Moderator, Shelter Controversies: Penalties and Recent Developments, Federal Bar Association, 34th Annual Tax Law Conference, March 5, 2010
  • Panelist, Stipulations in the Tax Court, American Bar Association, 2010 Midyear Meeting, January 22, 2010
  • Litigating for the IRS: How It's Done and Where It Leads, November 20, 2009
  • FOIA - It Doesn't Hurt (And May Help) To Ask, September 24, 2009
  • Codification of Economic Substance: Its Potential Impact on Audits and Litigation, May 17, 2007
  • Spotlight on Procedure: Privilege Claims Relating to Email Chains, January 19, 2007
  • The Intersection of FOIA and Tax Litigation with Emphasis on New Chief Counsel Notice 2006-16, October 12, 2006

Click here for a full list of speaking engagements.

Recent Publications

Click here for a full list of publications.