Tax Controversy

Latham’s tax controversy lawyers help US and multinational companies, tax-exempt organizations, and global high wealth individuals resolve complex contentious tax matters.

Why Latham

From large-dollar US and cross-border corporate tax disputes to economic substance and promoter cases, to sensitive allegations of fraud, Latham regularly delivers extraordinary results both in and out of the courtroom.

We advise clients on complex tax issues at every stage of a US federal, state, local, or cross-border tax controversy matter, and in every venue where US tax disputes are litigated. In the context of transactions, we identify and manage actual or potential tax controversies before they arise. When issues do arise, we draw on our experience in government at the IRS and US Department of Justice Tax Division and our strong working relationships with US tax authorities to minimize the scope of disputes and work to resolve them quickly and in a cost-effective manner.

For disputes that proceed to litigation, we leverage our sophisticated knowledge of the substantive, procedural, and evidentiary rules to win at summary judgment and at trial. We frequently team with Latham’s highly regarded Supreme Court & Appellate Practice, which has a rich history of notable tax appeal victories.

We regularly represent clients in controversies related to:

  • International and domestic corporate income tax issues, including transfer pricing
  • Partnership tax issues
  • Employment tax and employee benefits issues
  • Excise tax issues
  • State and local tax issues
  • Information gathering by tax authorities
  • Sensitive tax matters, including:
    • Penalty defense
    • Whistleblowing defense
    • Investigations for non-compliance
    • Efforts to self-report and correct errors in compliance

Awards & Rankings

  • Latham Named Tax Group of the Year - January 20, 2022
  • Six Washington, D.C. Partners Recognized as Top Lawyers - December 15, 2020
  • Eight Latham Partners Recognized as Top Lawyers by Washingtonian - December 13, 2018
  • Global Tax Controversy Chair Receives 2018 Jules Ritholz Memorial Merit Award - May 13, 2018
  • "Rising Stars" Honored for Legal Excellence - July 18, 2017

Latham’s “extensive tax controversy practice” is “regularly retained to handle major US Tax Court disputes,” and is “noted for its experience in high-value claims brought before state and federal appeal courts” and multi-jurisdictional fraud investigations.

Chambers USA 2020

Media Coverage

Litigators of the Week Runners-Up and Shout outsSolo Practitioner, Backed by Latham & Watkins, Wins SCOTUS Tax RulingJustices Revive Law Firm's Day-Late IRS Levy Challenge

News

Latham Delivers Unanimous Supreme Court Victory in Significant Tax CaseLatham Named Tax Group of the YearProminent Tax Litigator Rejoins Latham in Washington, D.C.

Thought Leadership

Supreme Court Allows Challenge to IRS Rule Despite Anti-Injunction ActEC Invites Comments on Collective Bargaining for Self-EmployedTEI Roundtable: The Evolving Dynamic in IRS Appeals

Webcasts & Podcasts

Internal Revenue Service: Successfully Navigating the IRS Audit for Large Business and International Taxpayers