Ben Willis

Ben Willis

Tax Partner, Practice Leader, National Corporate Tax


BDO Washington D.C. Office

202 644-5433


Executive Summary

Ben Willis is a Tax Partner and serves as Practice Leader for the firm’s National Corporate Tax Practice in BDO’s Washington D.C. office. Ben has substantial experience in the federal taxation of corporations and their shareholders. He regularly advises clients on issues surrounding corporate tax rates, debt and equity, substance-over-form doctrines, loss and attribute utilization, ownership/equity structuring, private letter rulings (PLRs), basis calculations, basis and earnings & profits (E&P) allocation methods, mergers and acquisitions (M&A), and internal restructurings.
Prior to joining BDO, Ben spent four years working for the U.S. government. Most recently, he was a member of the Senate Finance Committee, where he focused on drafting comprehensive tax reform and other proposals. Previously, he served as a Senior Technical Reviewer in the corporate division of the Internal Revenue Service (IRS) Office of Chief Counsel signing PLRs and reviewing dozens of publications and guidance. Prior to that, he spent two years working in the Office of Tax Policy (OTP) at the U.S. Treasury. Ben’s Treasury, IRS, and Capitol Hill experience give him a unique perspective on tax law. Before working in government, Ben spent several years in a law firm and the better half of a decade in PwC’s M&A and International Tax groups.
During Ben’s tenure as attorney-advisor to the U.S. Treasury, he reviewed and revised an important piece of guidance on the economic substance doctrine (Notice 2014-58). Ben was also the IRS reviewer on Rev. Rul. 2017-9, which covered so-called north-south transactions, where the step transaction doctrine could apply to treat separate transfers as one single taxable exchange.
Ben is a frequent speaker on corporate tax issues. He has spoken at several national and regional tax conferences, including the American Bar Association (ABA), the American Institute of Certified Public Accountants (AICPA), BNA, Practicing Law Institute, and Tax Executives Institute (TEI).
Ben has published over a dozen articles on complex corporate tax issues, addressing topics that include the business purpose requirement, bifurcation principles under the economic substance and step transaction doctrines, the “principal purpose” standard, the all-cash D reorganization, the triple-drop and check (Rev. Rul. 2015-9), “plan” of reorganization/liquidation, and the characterization under substance-over-form principles generally. Ben also authors the Tax Notes column “Willis Weighs In.”


LL.M, Taxation, Boston University
J.D., New England School of Law
B.A., Economics and Political Science, University of Rhode Island