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