Audit and Appellate Controversies
From its founding, the Firm has represented clients at every stage
of the U.S. federal and state audit process, from the audit through
Appeals. We represent taxpayers (including those in the Coordinated
Examination Program) beginning with advising company tax executives
on how to handle audit inquiries, to presenting individual issues to
the Examination and Appeals Divisions, to supervising entire audits.
Now that the IRS’s Section 1441 Voluntary Compliance Program is
finished, we are representing financial institutions in audit
matters relating to
tax reporting and withholding. We also represent clients before
state taxing authorities.
Since our clients are multinational companies we naturally deal with
transfer pricing issues, including
Advance Pricing Agreements. On occasion we seek the assistance of
the Competent Authorities to avoid double taxation.
We help clients resolve issues relating to corporate tax shelters
sold to them by accounting and investment firms. We typically advise
on whether and how to disclose and defend the transaction. We also
assist in preparing for and conducting appeals or litigation of
Our core philosophy is to resolve issues and close taxable years as
soon as we can. Therefore we urge clients to close tax years and
audits as quickly as possible and to avoid routinely granting the
I.R.S. additional time to audit. In our experience, closing audits
quickly allows issues to be presented while the facts are still
available and avoids surprises when the I.R.S. discovers “new”
issues and makes adjustments for all open years. In recent years, we
have been pleased to see the IRS itself recognize the wisdom of this
approach. As a result, audits are completed faster and cheaper, with
less exposure to adjustments.