Davis Polk partner and head of Litigation Jim Rouhandeh and partners Tony Perez-Marques and Lara Samet Buchwald were named “Litigators of the Week” by AmLaw Litigation Daily for securing a victory for ExxonMobil in litigation concerning the tax treatment of a 2006 transaction with the State of Qatar.

The litigation concerned a partnership between ExxonMobil and the State of Qatar called Al Khaleej Gas. Al Khaleej Gas was formed in 2000 to develop and market valuable minerals in the North Field, the largest non-associated gas field in the world. In 2006, the parties amended their original agreement that governed the partnership to significantly expand its production capacity, making it large enough to generate electricity sufficient to power the equivalent of approximately eight million homes in the United States on an average day.

“This tax refund litigation related to a transaction that began two decades ago on the other side of the globe,” Jim explained in a Q&A with AmLaw. “The IRS rejected ExxonMobil’s tax position, ExxonMobil paid the disputed taxes and penalties years ago, and ExxonMobil was the plaintiff seeking the return of those payments. As the plaintiff, we carried the burden of unearthing the relevant factual record, which required an enormous effort. Sometimes we have a dual role in these types of trials – part lawyer and part archaeologist.”

In November 2024, the same Davis Polk team received runner-up honors for securing a victory in the first phase of the tax dispute. In a post-trial decision, the court held that ExxonMobil was lawfully entitled to claim the interest expense deductions disallowed by the Internal Revenue Service and at issue in the case.

“We were engaged by ExxonMobil in 2021 well in advance of our filing of a complaint in March 2022. We were not hired to try this case because we were tax litigators; we were hired for our ability to streamline and present complex issues for trial,” Jim said. 

In a subsequent ruling this week, the court again ruled for ExxonMobil, granting the company’s motion for summary judgment and denying the government’s cross-motion.

When asked how the work was divided, Tony said, “ExxonMobil brought on a virtual team from both Davis Polk and Holland & Knight [co-counsel on the case] – we were deliberate from the outset that this was an integrated team and one that worked together closely… As a practical matter, the Davis Polk members of the team were the trial lawyers that developed and executed on our litigation strategy, and the Holland & Knight members of the team had significant tax expertise, which was critical to that strategy. But our goal was to ensure that we were not siloed and that strategic decisions were collaborative.” The Davis Polk team also included counsel Sean Stefanik and associates Kyra Macy Kaufman and Kaitlin Campanini. 

“The talent on our legal team – across the board – was striking,” Lara said. “We know how talented our colleagues are, but it is always valuable when our adversaries and the court get to see what we see each day.”

When asked what he will remember most from this matter, Tony noted, “We brought this case from complaint to trial in two years. We did it while staying focused on our key objectives, steadily building the case brick by brick and without getting waylaid by disputes that can sidetrack overall strategy.” 

“Litigators of the Week: A Nine-Digit Tax Win for ExxonMobil Over Qatari Gas Deal,” AmLaw Litigation Daily (September 25, 2026) 

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