Tax:  Tax Controversies & Litigation

Nixon Peabody represents clients in all aspects of controversies with the Internal Revenue Service and with state and local tax authorities. We handle audits, coordinated exams, administrative appeals, and both civil and criminal tax cases in federal and state courts.

We understand that most clients prefer to resolve tax controversies without litigation. We begin every engagement by clearly understanding the client’s priorities and pursuing these. Our attorneys have the substantive skills to “dig in,” to isolate the necessary facts and issues, to accurately determine the settlement parameters of the tax authorities, and to negotiate a settlement that protects the client’s interests. We are uniquely qualified to achieve these results because many of our attorneys are also CPAs, CFPs or CMAs, and many have experience working in industry, for the IRS, the Justice Department, and the Joint Committee.

Not all tax controversies can or should be settled. In some cases, effective representation of our clients is only achieved when the tax authorities understand that we are prepared to take the dispute to the courtroom. We have demonstrated success in a wide variety of cases involving an array of tax issues.

We have extensive experience in disputes involving:

  • Federal income, estate, gift, and excise taxes
  • State and local income, sales and use, and property taxation
  • Transfer pricing of goods, services, and intangibles
  • Tax treatment of mergers and acquisitions
  • Inbound and outbound transactions involving U.S. and foreign tax issues
  • Tax exempt status, intermediate sanctions, and specialized excise taxes
  • Tax status of employee benefit plans
  • Taxation of transactions among employers, plans, and beneficiaries
  • Eligibility for, and transferability of, tax credits and incentives
  • Taxation of specialized financial products and transactions
  • Tax treatment of listed transactions
  • Voluntary disclosure agreements
  • Assertion of civil penalties
  • Allegations of criminal conduct
  • Defending the tax-exempt status of debt obligations and arbitrage audits.
Boston • Chicago • Los Angeles • London • New York • Paris
Rochester • San Francisco • Shanghai • Silicon Valley • Washington • Albany
Buffalo • Long Island • Manchester • Palm Beach Gardens • Providence

Disclaimer | Nixon Peabody International | © 2010 Nixon Peabody LLP
This website contains attorney advertising. Prior results do not guarantee a similar outcome.