| Tax Controversies and Litigation |
To serve clients involved in tax-related controversies, our team has experience in all levels of tax law and is a cross-disciplinary group that draws on nationally renowned trial lawyers in the firm’s litigation group. We regularly defend corporations and individuals in audits and appeals by the IRS and state tax authorities, and on a variety of tax issues in the federal and state courts. When tax controversies progress beyond the administrative stages, we seek to obtain favorable outcomes for clients through litigation or declaratory judgments at all levels of the judicial system. In recent controversy matters, we:
- Successfully represented various clients in federal income tax audits relating to employee and independent contractor issues, offshore investments and amortization of intangibles following an acquisition
- Obtained abatement of substantial penalties imposed on a multinational corporation for failure to comply with information reporting rules
- Negotiated an amnesty arrangement, ultimately offered to all taxpayers, on behalf of a large coalition of taxpayers who allegedly owed several million dollars in use taxes
- Represented individual taxpayers at the federal and state levels in controversies relating to residency status
- Advised corporations and individuals on the tax consequences and structuring of litigation settlements