Tax Controversy

Foley’s tax controversy practice is comprised of seasoned practitioners, including former tax enforcement and other government officials, who use their experience and insight to craft efficient and innovative strategies to obtain favorable results for their clients. Our tax controversy attorneys have represented clients in all phases of tax disputes and have collectively handled thousands of audits, appeals, administrative proceedings, alternative dispute resolution proceedings, and cases involving local, state, federal, and international tax issues and disputes, both civil and criminal, including:

Civil and criminal tax litigation before state and federal trial and appellate courts and administrative bodies, including the U.S. Tax Court, U.S. District Courts, U.S. Court of Federal Claims, and the U.S. Supreme Court
IRS audits, protests, and appeals
State and local tax audits, protests, and appeals
Alternative dispute resolution, including fast track settlement, post appeals mediation, and the rapid appeals process
Transfer pricing disputes for state and federal taxes
Requests for competent authority assistance, unilateral, bilateral, and multi-lateral advance pricing agreements and private letter rulings
Tax shelter cases, including injunction and penalty cases
International and offshore tax compliance and reporting, including international information returns and Report of Foreign Bank and Financial Accounts filing requirements and penalties
Collection proceedings
State and local tax liens
Property tax appeals
Excise and employment taxes
Estate and gift taxes
Tax return preparer regulations and penalties
White collar crime and government investigations
Unclaimed property audits, disputes, and voluntary disclosures

Our Approach

Clients are best served when disputes and litigation are avoided in the first place. Our attorneys use their deep, across-the-board understanding of complicated tax procedures and substantive issues to counsel clients on their business operations and structures and assist them with planning matters and formulation of creative, business-oriented strategies geared toward dispute avoidance.