JOHN COLVIN

John draws from his almost three decades of practice and experience in tax law to develop legal theories and strategies in defense of his clients.  John keeps a close eye on developments in the tax law, which enables him to provide his  clients an unparalleled awareness of current developments and their implications. 

John is a very active and respected member of the American Bar Association Tax Section, having served as Chair of the Committee covering tax controversy matters, and currently overseeing Tax Section comments on government regulatory efforts in the procedural areas as part of the Committee on Government Submissions. He is often sought out to speak at a national level on various tax law issues, and has been intimately involved in drafting comments to proposed regulations on a variety of topics on behalf of the ABA Tax Section.  He also teaches Tax Crimes: Investigations, Prosecutions, and Penalties at the University of Washington School of Law.

John is a wine and food connoisseur and is always on the lookout for Seattle’s next great restaurant. He enjoys swimming and, in addition to tax news, is an avid reader of non-tax materials.

Professional Activities   

• ABA Tax Section Committee on Government Submissions (2017-present)
• ABA Tax Section Civil and Criminal Tax Penalties Committee, Vice-chair (2011-2015), Chair (2015-2017)
• ABA Tax Council, Member (2021-present)
• Seattle Tax Group, Chair (2014), Member (2010-present)
• Adjunct Lecturer, UW School of Law (2016, 2017, 2018)
• ABA Tax Section, Subcommittee for Legislative and Administrative Developments, Chair (2004-2012)
• ABA Tax Section, primary drafter of comments to preparer penalty regulations (§ 6694)
• ABA Tax Section, assisted drafting comments to list maintenance regulations (§ 6708)
• ABA Tax Section, assisted drafting comments to penalty regulations for failure to report IRS “reportable transactions” to the SEC (§ 6707A(e))

Presentations + Publications   

• Audits of Exempt Orgs and Private Foundations: Tax Exempt Does Not Mean No Examinations, NYU Tax Forum, 2023
• A Brief Review of the Curious Saga of In re Grand Jury, ABA Tax Section May Meeting, 2023
• Bankruptcy and Tax: The Usual and the Unusual, ABA Tax Section Midyear Meeting, 2023
• In re Grand Jury Update, Seattle Tax Group, 2022
• APA and Tax Practice, NYU Tax Forum, 2022
• Trends in IRS Audits and Where It’s Going, Pacific Tax Institute, 2022
• Current Developments, ABA Tax Section May Meeting, 2022
• Ethical Issues in Precedent Setting Litigation, ABA Criminal Tax Fraud Institute, 2021
• Coming in From the Cold, WSBA Tax Section, 2020
• Mental Defenses to Tax Crimes – Declination or Mitigation, American Bar Association National Institute: Criminal Tax Fraud/Tax Controversy, 2019
• The Evil that Men Do Lives After Them:  When is an Executor or Fiduciary Personally Liable for Taxes of Another?, American Bar Association Tax Section Fall Meeting, 2019
• Is Wayfair, Way Fair? A look at the State and Federal Implications, Fourth Annual University of San Diego School of Law – RJS LAW Tax Controversy Institute, 2019
• Colvin, Gutting & Slenn: Key Issues for Micro-Captives During an IRS Audit, published in Steve Leimberg’s Asset Protection Planning Newsletter, 2019
• Litigating Foreign-Related Penalties, Presented with Thomas J. Sawyer and Zhanna A. Ziering at the ABA 35^th Annual National Institute on Criminal Tax Fraud and Eighth annual National Institute on Tax Controversy, 2018
• Representing the World Citizen: Criminal Tax Defense in a World Where Persons, Money, and Data Are Mobile, Presented at the 34^th Annual ABA Criminal Tax Fraud and the Seventh Annual National Institute on Tax Controversy Conference, 2017
• Captive Transaction Disclosures Remain for Now: Federal Court Rejects Last-Minute Injunction Request and Affirms Anti-Injunction Act Applies to Penalties, ABA Tax Times, June 2017
• QDROs and Complex Retirement Plans, National Business Institute, 2015, 2017
• Tax Litigation, Oregon Tax Institute, 2016
• Privilege Issues In Criminal Investigations, ABA Nat’l Institute on Tax Fraud and Tax Controversy, 2016
• Owe the IRS? Passports at Risk Under New Code Sec. 7345, Journal of Tax Practice and Procedure, Feb. 2016
• International Taxation, Sterling Education, 2016
• U.S. District Judge Rejects Tax Promoters’ Plea Agreement in United States v. Crithfield: A Rare Event, but a Warning to Defense Counsel, ABA Tax Times, June 2017
• Challenging IRS Penalties, NYU Tax Controversy Forum, 2015
• Tax Controversy Issues Pertaining to Captive Insurance Companies, Strafford Group, 2015
• Litigation Valuation Issues in Tax Cases, ABA Institute on Criminal Tax Fraud, 2014
• FBAR Requirements for Business Foreign Bank Accounts, Strafford Group, 2014
• Audit Issues in Captive Insurance, ABA Business Law Section, 2014
• Developments in Criminal Tax, AFDA White Collar Roundtable, 2014
• FATCA Compliance and Implementation for FFIs: Mastering the Complexities Before the July 1 Deadline, Strafford Group, 2014
• Ask the Experts: Top Tax Practice Tips and Representation Strategies, ABA Institute on Criminal Tax Fraud, 2013
• FBAR Requirements for Business Foreign Bank Accounts, Strafford Group, 2013
• Subcommittee Report on Legislative and Administrative Developments, ABA Section of Taxation, Civil and Criminal Tax Penalties, prepared three times a year 2004-2012
• Preparer and Promoter Penalty Defenses, ABA Institute on Criminal Tax Fraud, 2012
• International Audit Developments, Seminar Group, 2012
• Flaws in the Façade: The Anti-Injunction Act After NFIB v. Sibelius and Cohen v. United States, ABA Section of Taxation, 2012
• Drafting Pleadings in the Federal Courts in Tax Cases, The American Association of Attorney-CPAs, 2012
• Tax Treatment and Consequences of Divorce, National Business Institute, 2011
• IRS FBAR Enforcement, Stafford Group, 2011
• Update on the Accuracy Penalty: The Slippery Slope to Strict Liability, ABA Section of Taxation; National “Last Wednesday” teleconference for the ABA, 2011