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Rachael E. Rubenstein

Member
fax +1 210.258.2714

Rachael E. Rubenstein advises high-net-worth individuals, businesses, and fiduciaries concerning federal tax matters. She has extensive experience in the following areas:

  • Tax Litigation: Litigates federal tax disputes before the U.S. Tax Court, U.S. Court of Federal Claims, and U.S. District Courts. Develops and executes litigation strategies to resolve complex procedural and substantive tax issues.
  • IRS Examinations: Represents clients in complex, high-dollar audits involving a broad range of issues, including income characterization, business deductions, valuation, cross-border assets, and BBA centralized partnership audit regime.
  • IRS Appeals: Secures case resolutions before the IRS Independent Office of Appeals through persuasive advocacy.
  • Penalty Defense: Defends against all types of high-dollar penalties proposed or assessed by the IRS by developing and presenting robust reasonable cause and hazard-of-litigation positions.
  • Compliance: Counsels clients regarding proactive tax compliance and IRS reporting obligations, as well as assists with responding to IRS notices and inquiries by leveraging deep knowledge of procedural and substantive tax law.
  • IRS Enforcement and Collection Defense: Handles select, high-stakes collection matters involving lien resolution, levy defense, and IRS collection alternatives. Defends third-party liability assertions (alter ego, nominee, successor).
  • Trusts and Estates: Represents fiduciaries in complex federal tax matters involving trusts and estates. Advises fiduciaries regarding income, estate, and gift tax issues that arise during administration and assists with tax reporting obligations.
  • International: Advises U.S. persons on reporting obligations related to foreign income, financial accounts, and offshore assets. Counsels foreign nationals and companies on U.S. tax issues arising from investments, business activities, inheritance, and immigration.
  • Planning and Advisory: Provides technical tax advice in high-impact business and personal contexts. Educates clients and professionals on compliance strategies and risk mitigation.
  • Transactional: Provides targeted federal tax guidance on select transactions to minimize exposure risk and support long-term planning objectives.
  • Specialized Advisory: Serves as expert witness or special tax counsel on federal tax matters arising in divorce, bankruptcy, and other civil disputes.
  • Employment: Advises businesses concerning employment-related tax topics, including those related to the Affordable Care Act.
  • Transactions with Liens: Assists in real property transactions complicated by federal tax liens.

Education

J.D., cum laude, St. Mary's University School of Law, San Antonio, Texas, St. Mary's Law Journal; The John M. Harlan Society
B.A., magna cum laude, Texas State University-San Marcos, San Marcos, Texas, Graduate of Mitte Honors Program

Recognitions

  • Named among Best Lawyers in America® for Litigation and Controversy–Tax & Tax Law (2024-2026)
  • Selected as San Antonio, Texas’ “Lawyer of the Year” for Litigation and Controversy–Tax by Best Lawyers in America® (2025)
  • Named a 2023 honoree for the San Antonio Business Journal Women’s Leadership Award
  • Recipient of Distinguished Service Award, State Bar of Texas, Tax Section (2021-2023)

Memberships

  • Tax Section of the State Bar of Texas
  • Tax Section of the American Bar Association
  • State Bar of Texas Pro Bono College
  • Temple Beth-El

State Bar Licenses

Texas

Court Admissions

U.S. Supreme Court
U.S. Court of Appeals, 5th Circuit
U.S. Tax Court
U.S. Court of Federal Claims
U.S. District Ct., W.D. of Texas
U.S. District Ct., S.D. of Texas
U.S. District Ct., E.D. of Texas

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