Federal Tax Controversy

Overview


Federal Tax Controversy

We can help you resolve complex tax disputes with the Internal Revenue Service (IRS), approaching each engagement with a strategic plan that will benefit you for the tax year in dispute—and in future tax years. We partner closely with you to understand your business goals and help you efficiently achieve your objectives.

To position you for success at any stage of a dispute, we draw on decades of experience representing people and businesses in IRS audits (including in the IRS’s Compliance Assurance Process), IRS administrative appeals, and litigation in federal trial and appellate courts. While we resolve most tax disputes at the IRS audit and IRS administrative appeals level, when settlement is not possible, we have a successful track record of litigating tax disputes in federal court.

We have resolved numerous matters through the IRS’s alternative dispute resolution procedures, including Industry Issue Resolution, Fast Track Settlement, Early Referral to Appeals, Rapid Appeals Process and Post-Appeals Mediation. We also have substantial experience with international tax disputes and transfer pricing issues, including navigating complex domestic and foreign-initiated competent authority cases (Mutual Agreement Procedure), and seeking and negotiating Advance Pricing Agreements.

IRS Audits

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Results


  • IRS Audit: 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.
  • IRS Audit: Obtained “no-change” letter after extensive audit regarding inversion, spin-off, and decontrol issues.
  • IRS Audit: Obtained 100% concession on $250 million adjustment involving dispute over application of Code section 367.
  • IRS Audit: Successful Fast Track Settlements for multiple corporate taxpayers related to complex financial product issues involving multi-billion dollar proposed adjustments in successive CAP audits.
  • IRS Audit: Successfully settled disputes over clean coal transactions.

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People


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

Key Contacts


Andrew R. Roberson

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Kevin Spencer

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Federal Tax Controversy

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