Tax Controversies and Litigation TRANSACTIONAL
Our cross-disciplinary team has experience in all levels of tax law. We draw on nationally renowned trial lawyers from the firm’s litigation group in order to serve clients involved in tax-related controversies. 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.
Burke, Robert D.

Robert D. Burke

Partner

+1 617 526 6470 (t)

robert.burke@wilmerhale.com

Kilgore, R. Scott

R. Scott Kilgore

Partner

+1 202 663 6116 (t)

scott.kilgore@wilmerhale.com

Null, Amy A.

Amy A. Null

Partner

+1 617 526 6541 (t)

amy.null@wilmerhale.com

Schnall, Matt

Matthew Schnall

Partner

+1 617 526 6892 (t)

matt.schnall@wilmerhale.com

Wethly, Kimberly B.

Kimberly B. Wethly

Partner

+1 617 526 6481 (t)

kim.wethly@wilmerhale.com

Ritt, Roger M.

Roger M. Ritt

Senior Counsel

+1 617 526 6475 (t)

roger.ritt@wilmerhale.com

Kirschten, Barbara

Barbara L. Kirschten

Special Counsel

+1 202 663 6290 (t)

barbara.kirschten@wilmerhale.com

Experience

In recent controversy matters, we have:

  • been engaged to represent a taxpayer in an economic substance matter before the appellate court on an adverse Tax Court decision relying on the economic substance doctrine to disallow foreign tax credits;
  • 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; and
  • achieved a victory for an individual pro bono taxpayer in a precedent-setting Tax Court case resulting in a refund payment to the taxpayer in her claim for entitlement to equitable innocent spouse relief.

Publications & News

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January 3, 2014

11th Circ. Sows Doubt Over Insolvent Bank Tax Refunds

Phillip Anker and Nancy Manzer publish an article in Bankruptcy Law360.

June 7, 2012

Chambers USA 2012 Final Results Announced

June 1, 2012

Massachusetts DOR Issues Final Directive on Restrictions on Pledges of Security Corporation Stock

September 15, 2010

U.S. News Media Group and Best Lawyers Release Inaugural Best Law Firms Rankings

WilmerHale earns first-tier rankings for a dozen national practices.

August 12, 2010

90 WilmerHale Lawyers Named to The Best Lawyers in America® 2011

Best Lawyers is based on an exhaustive peer-review survey in which more than 39,000 leading attorneys cast almost 3.1 million votes on the legal abilities of lawyers in their practice areas.

June 11, 2010

Chambers USA 2010 Reveals Final Results Ranking 101 WilmerHale Lawyers and Dozens of Practices

One-hundred and one WilmerHale lawyers are recognized in the eighth edition of the guide and the firm is listed as among the best in dozens of practice areas throughout its six US locations.

April 5, 2010

Tax Provisions Affecting Life Sciences Companies in New Health Care Reform

March 18, 2010

Chambers USA 2010 Honors WilmerHale, Ranking Over 100 Lawyers and Dozens of Practices

One-hundred and two WilmerHale lawyers will be recognized in the eighth edition of Chambers USA: America's Leading Lawyers for Business.

December 7, 2009

WilmerHale is Among Crain’s “New York City’s Best Places to Work”

The firm, referred to as “progressive and prestigious,” came in at #19 on the list of the 40 companies featured by Crain's in its second annual ranking of the city's top employers.

August 20, 2009

IRS Postpones Deadline for Certain Filers of FBARs until June 30, 2010