Tax Controversies

Présentation


As tax laws evolve and the focus on enforcement increases, so do the risks and challenges you face. To strategize and stay ahead of potential tax controversies, you need forward-thinking legal counsel.

With one of the largest tax practices in the US, along with first-rate tax practitioners in our offices around the globe, we can provide you with the nuanced resources and experience you need to handle any tax controversy, at any stage, with any type of taxing authority—in or out of the courtroom.

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Results


  • Secured a complete victory on all issues in a major US Tax Court case, Illinois Tool Works Inc. v. Commissioner of Internal Revenue Service. The high-profile case, in which the IRS challenged the repatriation strategy and determined that Illinois Tool Works was liable for more than $84 million in income tax deficiency and penalties, was presented before the United States Tax Court and the court resolved all issues in Illinois Tool Works’ favor. The decision, which had been highly anticipated and garnered extensive press coverage in the tax community, came after an eight-day trial in July 2016 and multiple briefings.
  • Served as lead tax litigation counsel for a $3 billion estate with respect to an alleged $150 million estate and gift tax deficiency involving transfer of interests in a professional sports team, building consensus among tax litigation counsel employed by three sets of beneficiaries adverse to each other in pending probate litigation and advising the court-appointed personal representative regarding his fiduciary duties.
  • Won U.S. Supreme Court case on statute of limitations issue with aggregate tax at issue of more than $1 billion; Home Concrete & Supply.
  • Achieved Fast Track Settlement that resolved multi-billion dollar proposed adjustments for several years under Subpart F and complete abatement of 20% accuracy-related penalty in excess of $1 billion.
  • Obtained 95% IRS concession on Code section 162(f) issue related to claimed deductions of several hundred million dollars.

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Équipes


A diverse, global network of industry-leading talent committed to you and your vision.

Contacts principaux


Jenny L. Johnson Ware

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Webinar / Speaking Engagements / October 27, 2021

Webinar / McDermott Event / May 18, 2021

Webinar / McDermott Event / October 21, 2020

Washington, DC / Speaking Engagements / March 5, 2020

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International Law Office / May 11, 2018

Los Angeles, California / Speaking Engagements / December 6-8, 2017

Chicago, Illinois / McDermott Event / November 16, 2017

New York, New York / Speaking Engagements / November 8-10, 2017

Global Tax Weekly Wolters Kluwer / October 12, 2017

Tax Notes / Worldwide Tax Daily / October 11, 2017

Financial Advisor / Private Wealth / September 29, 2017

Rolling Meadows, Illinois / Speaking Engagements / September 26, 2017

Tax Notes / State Tax Today / September 18, 2017

San Francisco, California / Speaking Engagements / September 18-19, 2017

San Antonio, Texas / Speaking Engagements / September 17-20, 2017

San Antonio, Texas / Speaking Engagements / September 17-20, 2017

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Austin, Texas / Speaking Engagements / September 14-16, 2017

San Antonio, Texas / Speaking Engagements / August 18, 2017

Boston, Massachusetts / Speaking Engagements / August 5, 2017

Louisville, Kentucky / Speaking Engagements / August 2, 2017

Global Tax Weekly (Wolters Kluwer) / July 27, 2017

New York, New York / Speaking Engagements / July 18-19, 2017

Tax Notes / State Tax Today / July 17, 2017

Tax Notes / State Tax Today / July 17, 2017

Tax Notes / State Tax Today / July 17, 2017

Tax Notes / State Tax Today / July 17, 2017

Chicago, Illinois / Speaking Engagements / June 29, 2017

Bloomberg BNA Daily Tax Report / June 28, 2017

New York, New York / McDermott Event / June 8, 2017

Washington, District of Columbia / Speaking Engagements / May 13, 2017

Washington, District of Columbia / Speaking Engagements / May 11-13, 2017

Chicago, Illinois / Speaking Engagements / May 8-10, 2017

Global Tax Weekly (Wolters Kluwer) / August 4, 2016

Tax Notes / Worldwide Tax Daily / March 21, 2016

American Bar Association Section on Real Property, Trust & Estate Law / December 9, 2015

Journal of Multistate Taxation and Incentives (Thomson Reuters/Tax & Accounting), Volume 24, Number 7 / October 2014

Getting the Deal Through / September 2014

Journal of Taxation of Financial Products, Volume 12, Issue 1 / August 2014

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