We regularly advise clients on ongoing transfer pricing matters and supervise the preparation under attorney-client privilege of supporting documentation by leading independent economists for use as appropriate in audits. We have been successful in achieving out-of-court resolutions of transfer pricing controversies.
We regularly represent clients in the U.S. District Court, U.S. Tax Court and U.S. Court of Federal Claims on tax litigation matters, including corporate, partnership and individual federal income tax issues.
We also represent tax-exempt bond borrowers, issuers and purchasers before the Internal Revenue Service in connection with examinations, closing agreements and before the Department of Justice in responding to IRS summons.