William F. Nelson

Senior Consultant

Will Nelson’s practice encompasses all areas of federal taxation, with special emphasis on partnership taxation and tax controversy and litigation matters. Previously chief counsel for the Internal Revenue Service, Will co-authored the treatise Federal Taxation of Partnerships and Partners (Warren, Gorham & Lamont, 4th edition, 2007) as well as Structuring and Drafting Partnership Agreements: Including LLC Agreements (Warren, Gorham & Lamont, 3rd edition, 2003). Will writes on tax law for numerous journals, and he frequently lectures at tax institutes.

Noted as “technically expert, creative, and a terrific tax litigator” as well as a “tremendous thinker who always provides great guidance," Will is named one of the leading practitioners in taxation by Chambers Global and Chambers USA, among others.

Prior to joining Morgan Lewis, Will was a partner in the corporate practice of another international law firm, where he was a former co-leader of the firm’s tax practice.

Mississippi State University, 1969, Bachelor of Science, High Honors
University of Virginia School of Law, 1972, Juris Doctor

District of Columbia
Georgia
US Court of Appeals for the Eleventh Circuit
US Court of Appeals for the Federal Circuit
US Court of Appeals for the Fifth Circuit
US Court of Appeals for the First Circuit
US Court of Appeals for the Second Circuit
US Court of Appeals for the Third Circuit
US Court of Federal Claims
US Tax Court

Highly Regarded, Tax Controversy, District of Columbia, International Tax Review's World Tax Guide (2025)

Listed, The Best Lawyers in America, Litigation and Controversy – Tax, Washington, DC (2012–2025)

Listed, The Best Lawyers in America, Tax Law, Washington, DC (2010–2015, 2017, 2019, 2020, 2024, 2025)

Senior Statespeople, Tax, District of Columbia, Chambers USA (2023, 2024)

Ranked, Tax, District of Columbia, Chambers USA (2003–2015, 2018–2022)

Ranked, Tax: Controversy, Nationwide, Chambers USA (2006–2016, 2018–2022)

Ranked, Tax: Corporate, Chambers Global (2001–2017)

Recommended, Tax: US taxes: contentious, The Legal 500 US (2021, 2022)

Recommended, Tax Controversy, The Legal 500 US (2013, 2015)

Recommended, Tax – Domestic tax, The Legal 500 US (2015)

Member, Practice Group of the Year, Tax, Law360 (2017)

Recognized, Who’s Who Legal (2016)

Recognized, International Who’s Who of Corporate Tax Lawyers (2013)

Recognized, Washington, DC Super Lawyers (2007–2014)

Recognized, Euromoney’s Legal Media Group’s Guide to the World’s Leading Lawyers, Tax Advisers