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Rachael E. Rubenstein

Member
fax +1 210.258.2714

Rachael E. Rubenstein maintains a broad federal tax practice encompassing the following areas:

  • Trusts and Estates: Represents fiduciaries in matters involving routine and complex income, estate, and gift tax issues.
  • Tax Advisory: Advises high-net-worth individuals, fiduciaries, tax professionals, and closely held business owners on contractual tax provisions, projected tax consequences, reporting and disclosure obligations, transaction structuring, and controversy risks.
  • International: Advises U.S. persons on foreign income and asset reporting obligations; counsels foreign nationals on U.S. tax issues involving investments, business activities, inheritance, and immigration.
  • Compliance: Advises clients on proactive tax compliance strategies and the resolution of significant compliance issues.
  • IRS Examinations: Represents clients in high-stakes audits involving a broad range of issues, including income characterization, deductions, related-party transactions, valuation, cross-border assets, and the BBA centralized partnership audit regime.
  • IRS Appeals: Advocates for favorable resolutions of complex federal tax disputes before the IRS Independent Office of Appeals.
  • Penalty Defense: Defends against significant IRS penalties through reasonable cause and hazards-of-litigation arguments.
  • Tax Litigation: Litigates federal tax disputes involving complex procedural and substantive issues before the U.S. Tax Court, U.S. Court of Federal Claims, and U.S. District Courts.
  • Specialized Advisory: Serves as an 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 issues, including those arising under the Affordable Care Act.
  • Tax Returns: Prepares and reviews select tax returns for individuals, trusts, estates, partnerships, and corporations.

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

  • Recognized in The Best Lawyers in America ® for Litigation and Controversy–Tax, Tax Law (2024-2027)
  • Named San Antonio, Texas’ Litigation and Controversy–Tax “Lawyer of the Year” by Best Lawyers (2025, 2027)
  • 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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