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Christopher A. Baratta


Represents clients in tax-related litigation and other tax controversies, as well as in transactional tax matters.

Chris has deep experience in both tax controversy and transactional tax advice. He represents clients in tax matters involving Internal Revenue Service administrative proceedings, trials, appeals and risk management, as well as governmental and internal investigations. His work spans a wide range of tax issues, from transfer pricing to treatment of corporate transactions. His U.S. and non-U.S. clients include financial institutions and companies in the securities, manufacturing, media, software and pharmaceutical sectors.

Many of Chris’s most successful matters have resulted in favorable settlements that remain confidential. He represented a securities industry client in a U.S. Tax Court trial in a matter of first impression.

Chris also advises private equity clients on tax matters, including fund structuring and M&A, and advises clients on the tax aspects of complex capital markets offerings.

As a member of our pro bono tax practice, he has advised numerous tax-exempt organizations.


Experience highlights

Tax Controversy
  • Advising operators of options and securities exchanges in Tax Court cases involving the domestic production activities deduction
  • Representing multinational consumer products company in appeal of IRS transfer pricing adjustment
  • Assisted multinational consumer products company in IRS transfer pricing examination resulting in favorable settlement
  • Assisted software development company in settling controversy regarding research credits and domestic manufacturing deductions
Transactional Tax Matters
  • Advised Federal Express on its offering of pass through certificates
  • Advised Hudson on its $748.9 million IPO
  • Advised Dominion Energy on its $1.61 billion offering of equity units
  • Advised AbbVie on its $6 billion senior notes offering
View more experience


J.D., Harvard Law School
  • cum laude
B.A., Psychology, Columbia University
  • Dean's List

Professional history

  • Davis Polk since 2013

Qualifications and admissions

  • State of New York
  • U.S. Court of Appeals, Tenth Circuit
  • U.S. Court of Federal Claims
  • U.S. Tax Court
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