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Tax

The Tax Practice

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We represent publicly held and private corporations, partnerships, individuals and trusts and estates in federal and state tax controversies and transactional tax planning.

TAX CONTROVERSY

The Firm’s experienced tax attorneys represent clients in all aspects of federal, state and local income, estate and gift, employment and other tax disputes. We have managed the successful resolution of literally hundreds of highly complex factual and legal issues involving potential tax deficiencies, penalties and interest in the aggregate of several billion dollars.   We also have provided consulting and expert witness services in a wide range of tax related litigation matters.  Our services include:

  • We assist our clients in formulating audit strategies, and in effectively dealing with the IRS and other taxing authorities to resolve issues at the earliest possible stage.  This includes negotiating the scope of the audit, preparing responses to and where appropriate, contesting IDRs and administrative summonses, controlling statutes of limitations, identifying and protecting privileged documents, requesting field service, technical advice and private letter rulings, drafting protest briefs, advocating and negotiating for our clients before IRS Appeals, and assisting our clients in fast track settlement, mediation and arbitration proceedings.  We are also well versed in the various administrative programs offered by the IRS as possible alternatives to traditional tax practice and procedure, including Industry Issue Resolution (IIR), the Compliance Assurance Process (CAP), the Pre-Filing Agreement Program (PFA), and Advance Pricing Agreements (APA).  We tailor the scope of our services to meet the particular needs of our clients, i.e., although we are typically asked to manage the audit, IRS Appeals and tax litigation process for our clients, we are also experienced in providing support in an advisory capacity, when appropriate, with the client maintaining direct contact with the IRS or other taxing authority.
  • We have noteworthy experience in representing large multi-national corporations (both public and privately-held) subject to the IRS’ Large Business and International (LB&I) coordinated examination program.
  • When administrative settlements cannot be achieved with the desired outcome, our Firm brings a team of seasoned and skillful tax controversy lawyers and litigators with the combined trial experience and technical tax knowledge to achieve outstanding results for our clients.  One of our partners is a former IRS senior trial attorney with the Office of Chief Counsel, and also serves as an adjunct professor of law at Loyola University School of Law where he has taught coursework in the area of Federal Tax Procedure and Litigation for more than 20 years.
  • Our consulting and expert witness experience in a wide range of tax related litigation matters includes representation of clients in case evaluation, risk assessment, case development and trial preparation, and when necessary, expert witness testimony in cases involving tax planning, the issuance of tax opinions, accounting practices, legal and accounting malpractice and related topics.  One of our partners is the co-author of Standards of Tax Practice, a leading treatise on the duties and obligations of federal tax practitioners, serves as an adjunct professor of law at Northwestern University School of Law, where he teaches the course in Tax Ethics, Opinions and Penalties, and has been elected Fellow to the prestigious American College of Tax Counsel.

TAX AND BUSINESS PLANNING

We have extensive experience in structuring, negotiating and implementing practical tax-efficient solutions for our clients’ global and domestic business transactions and general business needs.  We understand that while the tax laws are exceedingly complex, the optimal tax planning for our clients depends not only on a mastery of the technical rules, but also on a keen appreciation of the business context in which our clients’ tax issues arise.  Our clients look to us not merely as “tax specialists,” but as strategic thinkers and business consultants who provide thoughtful and experienced counsel and advice.

The Firm’s tax lawyers have represented clients in a broad range of matters, including:

  • Tax aspects of mergers, acquisitions, joint ventures, spin-offs, split-offs and other business combinations and dispositions.
  • Business formation transactions and internal restructurings.
  • Cross border transactions and international tax planning.
  • Real estate acquisitions and dispositions, including joint venture formation and disposition tax planning.
  • Partnership and S corporation planning.