Tax Controversy
Foley’s tax controversy practice is comprised of seasoned practitioners, including former tax enforcement and other government officials, who use their experience and insight to craft efficient and innovative strategies to obtain favorable results for their clients. Our tax controversy attorneys have represented clients in all phases of tax disputes and have collectively handled thousands of audits, appeals, administrative proceedings, alternative dispute resolution proceedings, and cases involving local, state, federal, and international tax issues and disputes, both civil and criminal, including:Ìý
- Civil and criminal tax litigation before state and federal trial and appellate courts and administrative bodies, including the U.S. Tax Court, U.S. District Courts, U.S. Court of Federal Claims, and the U.S. Supreme CourtÌý
- IRS audits, protests, and appealsÌý
- State and local tax audits, protests, and appealsÌý
- Alternative dispute resolution, including fast track settlement, post appeals mediation, and the rapid appeals processÌý
- Transfer pricing disputes for state and federal taxesÌý
- Requests for competent authority assistance, unilateral, bilateral, and multi-lateral advance pricing agreements and private letter rulingsÌý
- Tax shelter cases, including injunction and penalty casesÌý
- International and offshore tax compliance and reporting, including international information returns and Report of Foreign Bank and Financial Accounts filing requirements and penaltiesÌý
- Collection proceedingsÌý
- State and local tax liensÌý
- Property tax appealsÌý
- Excise and employment taxes
- Estate and gift taxesÌý
- Tax return preparer regulations and penaltiesÌý
- White collar crime and government investigationsÌý
- Unclaimed property audits, disputes, and voluntary disclosuresÌý
Our Approach
Clients are best served when disputes and litigation are avoided in the first place. Our attorneys use their deep, across-the-board understanding of complicated tax procedures and substantive issues to counsel clients on their business operations and structures and assist them with planning matters and formulation of creative, business-oriented strategies geared toward dispute avoidance.Ìý