Building upon the strengths of our tax, litigation and private client services practices, Proskauer’s tax controversy and litigation group has decades of experience in successfully resolving complex tax matters. We represent private investment funds, closely-held businesses, multi-national enterprises, high-net-worth individuals, family offices, tax-exempt entities, and financial institutions nationally and internationally.
We advise at every stage of a tax controversy matter, from audits and administrative appeals to litigation in federal and state courts, U.S. Tax Court, and appellate courts. Our controversy-related advisory work includes pre-transaction hazard assessments, reserve analysis, international information return reporting issues and defense (FBAR, etc.), internal investigations and whistleblower claims, among other areas. We believe the best defense to a tax dispute occurs before one happens, through careful tax planning and preparation.
When a dispute arises, we understand that our clients prefer to resolve their tax issues cost-effectively, discreetly and (most of all) favorably. Furthering those goals, we work to offer innovative, client-driven solutions that avoid the need for litigation in most cases. We achieve the results our clients want, drawing upon our relationships with and experience in government at the IRS, state revenue authorities, and the U.S. Department of Justice. When litigation is warranted, we remain focused on our clients’ goals, and our involvement sends a strong message to opposing counsel.
- Pre-Audit Advice
- Audit Representation
- Administrative Appeals and ADR
- Summons Enforcement Actions
- Litigation in US Tax Court, Federal and State Courts
- Charitable and Tax-Exempt Organization Controversies and Litigation
- Internal Investigations and Whistleblower Actions
- Criminal Tax Investigations
- Congressional Investigations
- Competent Authority and International Tax Disputes