Shannon Fiedler advises clients on a wide array of complex federal and international tax disputes.
Shannon regularly works with companies across industries on high-stakes matters at all stages of federal tax controversies, including IRS Exam, IRS Appeals, as well as litigation in the US Tax Court and US district courts, and subsequent appeal. In addition to civil tax matters, she has experience navigating sensitive tax matters such as whistleblower claims and allegations of potential criminal tax charges.
She draws on significant experience in transfer pricing matters and regularly counsels clients on the development, administrative, litigation, and appellate stages of multi-billion dollar disputes.
Shannon also has significant experience navigating complex procedural rules affecting US partnerships at all scales. Most notably, she represents investment management companies in disputes with the IRS regarding the application of Section 1402 to limited partner income.
Shannon regularly speaks and writes about current tax controversy issues, including at national conferences hosted by the ABA and the Tax Executives Institute.
Complementing her client-facing work, Shannon serves on the firm’s Associates Committee and previously served on the firm’s Recruiting Committee.
Shannon’s representative matters include: