Capabilities
Tax

Tax Controversy, Litigation, and Settlements

Our attorneys represent individuals, estates, trusts, corporations, financial institutions, nonprofits, and non-corporate investment vehicles (including partnerships) in virtually all types of tax controversy and litigation matters in a wide range of substantive areas. Recent litigation matters have involved tax accounting issues, employment taxes, executive compensation, penalties, trusts and estates, matters involving tax reporting obligations related to offshore holdings, and the use of net operating losses and other tax attributes following reorganization.

Our team has significant advocacy experience in administrative proceedings before the Internal Revenue Service (IRS), including district offices, appeals offices, the national office, and the US competent authority, as well as in litigation against the IRS in the federal courts, including the US Tax Court, the US Court of Federal Claims, district courts, and courts of appeals. Members of our practice also represent clients in administrative proceedings and litigation involving state and local tax agencies and appearances before international tax agencies.

We regularly assist taxpayers to become FBAR and FATCA compliant, including in making voluntary disclosures to the IRS of tax compliance oversights, and also have experience in representing sovereign governments and their instrumentalities in their dealings with the US.

Our team also has extensive experience in tax issues related to the settlement of complex litigation, including maximizing the tax advantages of settlements through the establishment and operation of qualified settlement funds and structured settlements.

Experience

Medical device manufacturer Complex product liability settlement

Representing client in structuring and implementing national complex product liability settlement in a tax efficient manner, including establishment of qualified settlement funds and structured settlements.

Energy company Major environmental and mass tort settlements

Representing client in major environmental and mass tort settlements, including structuring and implementation of complex funding mechanisms and qualified settlement funds to maximize tax benefits.

Centex Corporation Centex Corp. v. United States

Obtained a $28.1-million judgment on claims stemming from Congress' retroactive revocation of tax benefits critical to client's acquisition of four insolvent financial institutions.

Cencast Partners and affiliated companies Cencast v. United States

Litigation in the Court of Federal Claims with more than $100 million in tax and interest at issue involving the calculation of the FICA and FUTA wage base for production worker employees.

High-net worth individual Tax refund actions

Represent a high-net worth individual in five inter-related tax refund actions related to the imposition of tax penalties and other items following the settlement of a Tax Equity and Fiscal Responsibility (TEFRA) partnership action by the Internal Revenue Service.

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