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 these issues.

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.