July 25, 2025
State Disasters Now Qualify for Federal Tax Relief... [ read ]
Nick S. Pegelow unpacks the important expansion of the IRS's disaster relief powers that could provide a lifeline to taxpayers impacted by state-declare emergencies.
Nick Pegelow helps businesses and individuals navigate tax controversies and high-stakes tax disputes. He guides clients through IRS examinations by identifying potential tax exposure, developing risk-mitigation strategies, and implementing solutions that protect their financial interests. This proactive approach allows Nick to anticipate and address tax issues before they become problems.
Before joining the firm, Nick helped clients create tax-efficient structures and navigate tax strategies for complex business combinations at Grant Thornton. As a leader on the M&A tax team, he advised on the federal tax implications of billion-dollar mergers, corporate reorganizations, and cross-border acquisitions. Nick has assisted clients with several transaction types, including corporate restructurings, international tax planning, and partnership solutions across industries such as transportation, real estate, and financial services.
Nick is a graduate of the University of Texas School of Law who was licensed to practice in Texas during 2021. When not advising clients, Nick channels his tech skills into building custom computers and software solutions, leveraging his prior experience as a cryptocurrency miner.
Before joining the firm, Nick helped clients create tax-efficient structures and navigate tax strategies for complex business combinations at Grant Thornton. As a leader on the M&A tax team, he advised on the federal tax implications of billion-dollar mergers, corporate reorganizations, and cross-border acquisitions. Nick has assisted clients with several transaction types, including corporate restructurings, international tax planning, and partnership solutions across industries such as transportation, real estate, and financial services.
Nick is a graduate of the University of Texas School of Law who was licensed to practice in Texas during 2021. When not advising clients, Nick channels his tech skills into building custom computers and software solutions, leveraging his prior experience as a cryptocurrency miner.
- The University of Texas School of Law, J.D., 2021
- Editor, Texas Review of Law and Politics
- Saint John's University , B.A., Majors, Mathematics and Economics and Minor, Computer Science, 2017
- President, Economics Club
- Captain, Wrestling Team
- American Bar Association
- Tax Section
- State Bar of Texas
- Tax Section
- Dallas Bar Association
- Council Member, Tax Section
- Member, Business Litigation Section
- Member, Criminal Law Section
- Member, Mergers & Acquisitions
- Member, Probate, Trusts & Estates Section
- Texas Supreme Court
- U.S. Tax Court
- U.S. District Court – Eastern District of Texas
- U.S. District Court – Southern District of Texas
- U.S. District Court - District of Colorado
- U.S. Court of Appeals 5th Circuit
- Winner of Time magazine’s Person of the Year, 2006
- The University of Texas School of Law, Wayne Schiess Award for Excellence in Legal Writing
June 30, 2025
Yum! Brands Challenges IRS on "Killer B" Regulations... [ read ]
In our latest blog post, Nick S. Pegelow examines Yum! Brands' high-stakes case regarding "Killer B" anti-abuse regulations, international reorganizations and when a "B Reorg" triggers a US tax bill.
April 14, 2025
Claiming Dormant Tax Refunds Through Section 1311... [ read ]
Taxpayers should try to claim tax refunds within the statute of limitations. Sometimes they can't. Taxpayers under audit, for instance, might have a contingent claim that won't be ripe until the audit concludes. In these situations, a seasoned tax advisor will likely recommend submitting a protective claim for refund, safeguarding the statute of limitations. But if it is too late to file a protective claim, there are still avenues for taxpayers to claim a refund.
March 6, 2025
The S Corp with an Evergreen PLR... [ read ]
A Private Letter Ruling is as close as you can get to certainty in the tax world. That's why the IRS charges up to $43,700 just to look at one. But so long as you don't misrepresent the facts, a PLR is a binding interpretation of current law on both the IRS and the courts. A favorable ruling can reduce tax-return disclosures and FIN 48 adjustments included in applicable financial statements, among other benefits.
February 26, 2025
AARs: Streamlined Corrections for BBA Partnership Returns... [ read ]
Amending tax returns is a necessary evil—sometimes. Correcting a return to add $15,000 of unreported income might not make sense to taxpayers if it costs $25,000 to amend, putting aside ethical and other considerations. But suppose it's an issue with an improper method of accounting.
