Tax Controversy
US Tax Controversy
The lawyers in our tax controversy practice
represent clients in all types of civil and criminal tax
proceedings and litigation. Our lawyers have handled tax
controversies at all levels, including before the IRS, state and
local administrative tribunals, foreign taxing authorities, the
United States Department of Justice, federal and state district and
appellate courts, and the US Tax Court. We are experienced in
representing clients from the pre-audit planning level through
appeals of litigated decisions, and at all stages in between.
We are skilled in representing clients accused
of criminal activity arising from complex financial transactions
and have represented numerous tax advisors in some of the most
significant criminal and civil proceedings to be brought in recent
years. Furthermore, our lawyers are well-connected with
private and governmental lawyers, which enables us to provide our
clients with a distinct advantage when circumstances are changing
rapidly and present significant risks to our clients.
Our lawyers are experienced with handling tax
controversies in a variety of jurisdictions. Our tax lawyers
have extensive experience representing clients in civil tax
examinations and criminal tax proceedings concerning foreign bank
accounts, in which we are well-versed and experienced in all
aspects of civil and criminal enforcement mechanisms. Our
experience also includes handling parallel civil and criminal
proceedings, an increasingly common occurrence in tax
enforcement.
UK Tax Litigation
We have broad experience of advising clients on disputes with HM
Revenue and Customs and have acted on some very high profile cases
including the landmark House of Lords case Barclays Mercantile
Business Finance Limited v Mawson.
Areas of Focus:
- Trial litigation
- Appellate litigation
- Resolution of tax disputes with the IRS, HMRC and other
national tax authorities
- Criminal tax investigations
- US state and local tax authorities and administrative
tribunals
- Tax treaty disputes