Department of the Treasury – Internal Revenue Service (IRS)

No interaction with the federal government is more certain than US taxpayers’ dealings with the Internal Revenue Service (IRS), whether through voluntary compliance, examinations, or tax enforcement. Leading companies and global market leaders need to know how to interface productively with this powerful governmental agency, including how to:

• Approach the IRS to confidently plan business transactions, impact policy, and create dialogue around emerging issues in taxation
• Best navigate the policy priorities, procedures, and negotiations inherent in IRS examinations and tax controversies in general, using creative issue resolution strategies and, if necessary, formidable litigation tools
• Respond effectively to tax inquiries and investigations or to the discovery of sensitive tax matters, and how to manage the correction of prior non-compliance

Latham’s Tax Practice maintains consistent contact with IRS officials to help clients achieve their goals vis-à-vis the agency. For instance, Latham lawyers regularly approach the IRS and the Treasury Department on private letter rulings and regulatory comments, while also maintaining close professional relationships with federal tax officials. The team recognizes the value of understanding the government’s views on current tax issues, and is well positioned to advise clients on related matters.

In addition, the firm’s Washington, D.C. Tax Controversy Practice provides critical advice on tax compliance issues, including the astute handling of IRS inquiries, examinations, and administrative appeals, as well as “eggshell” investigations and voluntary correction of non-compliance. When litigation must occur, the team draws on its track record of success in handling complex tax litigation at trial and on appeal.