Tax doesn’t have to be complicated, and it can drive measurable value. My favorite parts of working with our clients is cutting through the tax speak to the bottom line and then helping find and capture real tax savings through simple changes to their ownership structure or operations.


Dustin Covello provides clients tax advice in business transactions and personal investments. His client base primarily includes growing and middle-market businesses, as well as their owners and investors. Dustin helps his clients plan to maximize tax efficiency when engaging in key transactions such as capital raises, mergers and acquisitions.

Dustin’s most recent focus has been on helping sell-side clients with exit planning in anticipation of selling a closely held or middle-market business. With sophisticated planning and creativity, Dustin is often able to create demonstrable value that saves sellers substantial cash taxes.

Dustin also helps investors and families with tax planning when they seek to cross borders – whether that is investing into the United States, expanding or acquiring a business abroad or immigrating to or from the United States.

Further, although Dustin's primary expertise is tax planning, he brings a practicality to his role, and clients come to rely on him for general legal and business advice.

Finally, Dustin represents clients in federal tax controversies at the examination, appeals and litigation phases of a dispute with the IRS.

Representative Matters

  • Helps clients implement innovative tax planning techniques to save substantial taxes in connection with liquidity events.

  • Advises and plans on choice of entity questions, such as tax rate planning, the section 199A deduction, section 1202 (qualified small business) exclusion from capital gains, entity conversions.

  • Structures taxable and tax-deferred mergers and acquisitions involving U.S. and foreign acquirers and targets.

View more.

  • Won Gateway Hotel Partners, LLC et al. v. Commissioner, T.C. Memo 2014-5 (Jan. 9, 2014), a case involving the federal tax treatment of state historic rehab credits earned by a real estate partnership, after a trial in the U.S. Tax Court.

  • Won Colorcon, Inc. v. United States, 110 Fed. Cl. 650 (2013), a case involving the tax treatment of a $191 million settlement payment, at the summary judgment stage.

  • Resolved dozens of IRS tax disputes for companies and high net worth individuals at the IRS audit and appeals level.

  • Represented over 200 taxpayers in voluntary disclosure matters of streamlined foreign disclosures.

Personal Insights

My Greatest Strengths
  • Tax can sound complex, but I try to make it simple for our clients. 

  • I also help client navigate the host of tax issues to focus on the ones involving real value – whether that is a substantial tax savings or avoiding a thorny tax trap or compliance headache.
  • Clients also appreciate that I place tax matters into the context of their business or investments. Rather than focus on tax for the sake of tax, I take the approach of how does tax fit into and complement your priorities.
  • I was selected as a 2021 Legal Intelligencer Lawyer on the Fast Track.

  • I enjoy leveraging frequent-flyer mile programs to travel the world in first class.

  • While working full time to build my tax practice, I earned my LLM part time from NYU in only two years.

What Drives Me
  • Creating value for our clients. 


Practice Focus
  • Tax

  • Tax Controversy & Litigation

  • International Tax


  • Manufacturing and distribution

  • Software, medical devices and other intellectual property

  • Service businesses

  • Real estate

  • Funds, investors, and financial services

  • Family offices

  • Technology


  • Publication, RCCB Tax Alert, May 2020
  • Prospective Tax Planning in a Down Economy
    Publication, RCCB Tax Alert, April 2020
  • COVID-19 Tax Alert
    Publication, RCCB Tax Alert, April 2020
  • Seizing “Opportunities” to Create and Invest in Tax-Favored Qualified Opportunity Funds
    Publication, RCCB Tax Alert, August 2018
Videos & Podcasts
  • Intricacies that Allow Investors to Operate a New or Existing Business in a QOZ
    Podcast, June 19, 2019
  • The Timeline for Forming, Executing, and Exiting an QOF
    Podcast, May 15, 2019
  • New Regulations:  On April 17, 2019
    Podcast, May 1, 2019
  • QOZs and Tax Filings
    Podcast, March 20, 2019
  • Complementing Opportunity Zone Projects with Other Valuable Tax Credits
    Podcast, February 20, 2019
  • Current Developments in Opportunity Zone Investments
    Podcast, January 16, 2019
  • The Challenges and Solutions to Maximizing Opportunity Zone Benefits
    Podcast, December 5, 2018
  •  The Recently Issued Proposed Regulations
    Podcast, November 7, 2018
  •  Utilizing Additional Resources for High Impact Projects to Seize Opportunity Fund Investments
    Podcast, October 24, 2018
  • Developing Real Estate in an Opportunity Zone
    Podcast, October 10, 2018
  •  Structuring an Investment in an Opportunity Zone
    Podcast, September 5, 2018

Practice Areas


LL.M., Taxation, New York University School of Law, 2015

J.D., magna cum laude, Georgia State University College of Law, 2008

B.A., magna cum laude, Montclair State University, 2005


  • Pennsylvania


Best Lawyers, 2022-Present

  • Litigation and Controversy – Tax
  • Tax Law
Pennsylvania Super Lawyers Rising Star, 2017-Present
  • Tax
Legal Intelligencer Lawyer on the Fast Track, 2021

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