Tax Controversy and Litigation
Taft’s Tax Controversy and Litigation practice offers decades of combined experience in resolving civil and criminal tax matters, both at state and federal levels. Our attorneys handle complex tax disputes in income, transactional, estate and gift and excise taxes for businesses, individuals, trusts, estates and exempt organizations. Additionally, our attorneys have significant experience in assisting clients with identifying and resolving Foreign Bank and Financial Account Reporting (“FBAR”) matters via voluntary disclosure or otherwise.
The breadth and depth of dispute resolution knowledge within our Tax practice enables us to understand and apply controversy management early during the audit, to draw upon and partner with a client’s internal resources and outside advisors, and to help shape issue resolution proactively. Our experience includes opinion review, participation in tax administrative review and appeal, guidance on pleadings and discovery and practice before relevant state and federal courts.
Our goal is to resolve tax matters quickly and effectively, at the earliest stage possible and, if appropriate, without litigation. Where litigation is necessary or desired, we have the requisite knowledge and understanding to challenge or defend positions in the appropriate judicial venue. In matters involving institutional taxpayers, we work directly with in-house counsel, in-house auditors and other members of the client’s advisory team, providing a comprehensive approach to resolving the dispute.
- Represented a foreign publicly traded company with respect to its U.S. subsidiaries’ income tax audit and before the IRS Office of Appeals.
- Represented a publicly traded company before the IRS Office of Appeals, achieving favorable settlement.
- Assisted a publicly traded company with foreign tax credit matters stemming from an IRS audit.
- Represented electric utility in annual property tax assessment process.
- Trial victory for gas utility in litigation of centrally-assessed valuation for property tax.
- Represented Fortune 1000 industrial company in protest of sales tax assessment related to Minnesota manufacturing operations.
- Represented Fortune 500 company challenging property tax assessment on R&D facility.