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TAX CONTROVERSY

Our tax controversy attorneys are true tax litigators who combine substantive knowledge and experience in tax law with a keen understanding of your business. Whether we work with you from the outset of a controversy or after initial attempts at resolution have failed, our objective is to resolve your tax dispute efficiently and in a manner aligned with your objectives.

  • On behalf of one of the largest banks in the United States, obtained an abatement of IRS penalties arising from the late filing of a foreign national's federal estate tax return.
  • Helped structure the worldwide operations of a group that specialized in the development, manufacturing and licensing of food supplements to minimize U.S. and worldwide tax.
  • Defended a foreign trust administered in Guernsey, Channel Islands, against a proposed 35 percent IRS penalty for the late filing of a form.
  • Structured the U.S. operations of a European-based fabric manufacturer and distributor to minimize U.S., Swiss and French taxes.
  • Assisted a U.S. franchisor of business systems to obtain, through the mutual assistance provision of the U.S.-Japanese income tax treaty, a refund of Japanese withholding taxes imposed on franchise payments.
  • Obtained a favorable private letter ruling from the IRS that reversed long-standing policy, allowing a spin-off of assets from a U.S. pension plan to a Puerto Rican plan with favorable tax consequences.