U.S. Tax Reporting and Withholding  
   
  FATCA  
   
  Qualified Intermediary ("QI") Advice  
   
  Tax Advice and Planning  
   
  Cross-Border Financial Structures  
   
  Collective Investment Vehicles ("CIVs")  
   
  Audit and Appellate Controversies  
   
  Tax Litigation  
   
  Rulings and Regulatory Lobbying  
   
  Alternative Dispute Resolution  
   
  Expert Witness/Litigation Support Services  
   
  Advice for Governments  
   

Alternative Dispute Resolution

Not all tax disputes end or should end in the courtroom. We use a number of IRS dispute resolution procedures including Technical Advice, APAs, arbitration and national office review procedures when a dispute develops between a taxpayer and the auditing team that cannot be resolved on appeal, and have had very good success with them. We will continue to use them because they can vastly shorten the time needed to resolve a dispute, and produce very good results with a minimum of cost.


 

   
   
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