U.S. Tax Controversy & Litigation

Tax Controversy

Our approach to handling audits and appeals before the IRS is to help clients achieve the desired resolution of their tax issues as efficiently as possible while preserving a constructive relationship with the government. Using our deep knowledge of and experience with applicable procedures, we help our clients navigate the available IRS administrative processes to reach an acceptable resolution. We work with our clients’ professionals and other experts, as appropriate, to present the strongest possible case in order to maximize the opportunity to settle. But significant issues cannot always be settled in the administrative process, so we are mindful of developing a strategy that will be effective if litigation becomes necessary.

Tax Litigation

We have significant experience trying cases in the U.S. Tax Court, the U.S. Court of Federal Claims, and the federal district courts, and in appealing cases to the federal courts of appeal. Our tax controversy lawyers take the lead in both trying and appealing tax cases. Depending on the issue in dispute, however, we believe our clients often are best served when our teams include V&E lawyers from other relevant practice areas, such as Intellectual Property, Complex Commercial Litigation, and Appellate.

Transfer Pricing

We focus on transfer pricing disputes involving intellectual property, including cost-sharing arrangements, buy-in transactions, licenses, and technical services. We regularly work with consulting and testifying economic and financial experts from the major accounting and litigation support firms, as well as from boutique firms. Engaging and effectively working with these professionals, especially at an early stage, helps us develop and implement the most effective strategy for each transfer pricing dispute.

Controversy Planning

Consistent with the adage that an ounce of prevention is worth a pound of cure, careful planning on the front end can be the most effective means of addressing a potential tax controversy. To this end, our team is skilled in assisting clients by identifying and addressing potential tax issues before they become problematic. We believe we can add the most value when we are engaged early to advise on transactions with potential audit exposure.