When handling controversies, we’re on your team.
We can represent you in the full range of tax controversies, from pre-controversy planning to litigation in the highest courts. We can handle high profile tax issues, while also representing you in more routine controversy matters.
We will work with you to advise on strategic options and priorities for contesting, litigating or settling a tax dispute. With over 150 attorneys in our global Tax group, you will benefit from industry-spanning knowledge in multiple jurisdictions. We have a very strong track record when it comes to resolving and litigating tax disputes.
We have experience advising on civil and criminal and, international and domestic tax disputes, involving income tax; VAT; property tax; sales tax and excise tax. We have also represented clients against national and sub-national tax authorities in all stages of dispute.
If you have a tax controversy or other tax dispute, we can offer assistance at every stage and every level.
Our lawyers are experienced in all aspects of tax controversy and litigation. Our recent experience includes:
- winning a case for a fast moving consumer goods company involving the taxation of foreign sales corporations. The US Court of Appeals for the Sixth Circuit reversed a trial court ruling dismissing the claim and remanded for entry of an appropriate judgment in favor of the taxpayer
- winning a retail client's $150 million tax dispute with the IRS over cross-border financing transactions. The government conceded that there was no tax liability
- achieving a very favorable IRS Appeals Office settlement for a major restaurant chain in a tax controversy related to the federal income tax treatment of gift cards. The settlement resulted in significant change in relevant IRS published guidance
- representing a national transportation company in a research tax credit case involving computer software development. The court ordered a partial summary judgment in our client's favor with respect to the legal standard applicable to internal use software
- representing a Fortune 100 insurance company on appeal in a case involving two questions of first impression—whether compensatory and punitive damages awarded to an insured are part of the company’s losses incurred on insurance contracts that are deductible when booked rather than when paid, and whether a nonlife operating loss is to be taken into account in calculating adjusted current earnings for purposes of the corporate alternative minimum tax
Key contacts
David B. Blair
Partner
Washington, DC, United States
Jeffrey A. Friedman
Partner
Washington, DC, United States
Mary E. Monahan
Partner
Washington, DC, United States
Caroline C. Setliffe
Partner
Washington, DC, United States
Dr. Lars H. Haverkamp, LL.M. (Christchurch)
Partner
Dusseldorf, Germany
Robert Waterson
Partner
United Kingdom