Tax Advice and Planning  
   
  Cross-Border Financial Structures  
   
  Tax Reporting and Withholding  
   
  Qualified Intermediary ("QI") Advice  
   
  Collective Investment Vehicles ("CIVs")  
   
  Transfer Pricing  
   
  Audit and Appellate Controversies  
   
  Tax Litigation  
   
  Rulings and Regulatory Lobbying  
   
  Alternative Dispute Resolution  
   
  Expert Witness/Litigation Support Services  
   
  Advice for Governments  
   

Expert Witness/Litigation Support Services

Laws like the Sarbanes-Oxley Act of 2002 (“Sarbox”) have put an ever-increasing premium on sound financial controls. A department can come under attack when a terminated employee claims to be “blowing the whistle” on purported tax improprieties, such as corporate tax shelters or even active tax fraud.

Litigators generally are not tax attorneys, and a critical part of a company’s defense to a charge of tax improprieties – both in court and in the financial markets – is showing that the corporation took reasonable positions on its tax returns and made reasonable assessments of the risk that those positions might be questioned.

We can help you understand the tax issues in the case and provide support in either a testimonial or support role, including examining and preparing documents and witnesses for trial. Our lawyers former roles as senior IRS and Treasury lawyers lend credibility to our testimony.




 

   
   
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