Tax Controversy & Litigation

We counsel corporations, partnerships and individuals in complex civil and criminal tax controversies, including investigations, audits and litigation. We represent clients before the IRS, the U.S. Department of Justice and U.S. Attorneys’ Offices, and tax authorities in the United Kingdom, Germany, and France, integrating our litigation strength with our deep technical tax knowledge and government experience to help clients resolve tax issues as favorably as possible.

Our team handles matters spanning the full life cycle of tax disputes. For example, in the U.S., we guide clients through IRS civil examinations, administrative appeals and litigation through appeals, and in criminal matters, we represent clients in IRS investigations, grand jury investigations conducted by the DOJ and U.S. Attorneys offices, and trials when necessary.

Our experience includes:

  • Representing U.S. and non-U.S. corporations (publicly traded and privately held), as well as other business enterprises including partnerships, LLCs, and taxpayers, in civil and criminal tax controversy matters that cut across many industries including manufacturing, financial services, energy, communications and retail.
  • Investigation and discovery processes, including with respect to grand jury subpoenas and IRS summonses.
  • Procedural disputes that arise in tax controversies and litigation including attorney-client privilege and the work product doctrine.
  • Tax-related congressional investigations and high-profile hearings

A defining strength of our practice is the federal government experience within our team. Our lawyers include a former IRS Chief Counsel, former federal prosecutors with extensive lead counsel experience in the DOJ Tax Division and multiple U.S. Attorneys’ Offices, and lawyers with similar experience in non-U.S. jurisdictions. This background gives us a sophisticated understanding of how tax authorities investigate, litigate and resolve disputes and how to position clients effectively at every stage.

We are also known for the substantial courtroom experience we bring to tax disputes. We have tried cases in the U.S. Tax Court, the U.S. Court of Federal Claims, and U.S. federal district courts, U.S. federal Courts of Appeals and the Supreme Court of the United States, as well as courts and tribunals in other countries.

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