Eversheds Sutherland represents clients in disputes in the United States Court of Appeals, state supreme courts, and negotiations. Clients include major players in the media and technology, e-commerce, and utilities sectors, as well as Fortune 500 companies. The team is especially strong representing clients on SALT, energy, and excise tax matters. In Washington DC, Jeffrey Friedman covers state and local tax planning and advocacy to Fortune 100 companies, while Jerome Libin covers tax controversy before the US Supreme Court. Operating out of Chicago, Breen Schiller leads the tax team there and covers state and local tax audit defense and litigation, with particular strengths in e-commerce and cloud computing tax issues. Eric Tresh leads the TMT team in Atlanta and focuses on SALT matters, as does associate Alla Raykin. In New York, Sarah Paul litigates in cryptocurrency and general litigation. Expert in contentious and information reporting work Jonathan Sambur joined from Mayer Brown in April 2021.

Latham & Watkins LLP represents clients on US and cross-border corporate tax disputes, fraud allegations, and US federal and SALT tax controversies. In Washington DC, practice leader Miriam Fisher is a highly regarded tax litigator, representing multinationals and high-net-worth individuals in federal and state tax controversy matters, ranging from high-value tax claims to allegations of fraud. She works alongside Jean Pawlow, noted for representing major American companies in federal trial and appellate courts, as well as alternative dispute resolution involving transfer pricing, foreign tax credits, and research credits. In Boston, Brian C. McManus specializes in cross-border and offshore tax disputes and litigation, as well as criminal tax charges on behalf of multinationals, financial institutions, and Fortune 500 companies. Tax controversy counsel Andrew Strelka rejoined from the Office of the White House in September 2021; tax accounting dispute counsel Joshua Wu rejoined in March 2021 from the US Department of Justice, Tax Division.

Mayer Brown engages in high-profile tax litigation and resolution matters involving bet-the-company tax disputes, with cases before the US Tax Court and federal and state courts. Its expertise includes SALT covering all 50 states, especially in New York, New Jersey, California and Illinois. Co-leads Joel Williamson and Thomas Kittle-Kamp operate out of Chicago while co-lead Brian Kittle is based in New York. The SALT team is lead by Leah Robinson from New York, and supported by New York’s Zal Kumar and Palo Alto-based Larry Langdon and Paul DiSangro. The team also is noted for its work on international advance pricing agreements, lead by John Hildy in Chicago. In a notable move, federal tax controversy specialist Jenny Austin joined from Morgan, Lewis & Bockius LLP in May 2021.

The tax controversy team at McDermott Will & Emery LLP is highly experienced in IRS audits, administrative appeals, and trial and appellate litigation. The team is particularly strong in SALT and transfer pricing disputes and litigation. Clients are primarily multinationals, including a large number of Fortune 100 companies. In Chicago, practice lead Jane Wells May focuses on SALT matters for clients in the healthcare, energy, and manufacturing industries. She works alongside Jenny Johnson, a specialist in negotiated resolutions with the IRS and DoJ; Andrew Roberson, an expert in representing clients before the IRS Appeals Office and Examination Division; federal and SALT litigator Roger Jones; and Catherine Battin, who often represents multinationals in SALT controversies. In Washington DC, Stephen Kranz is a noted expert in state tax reform and digital goods and services tax disputes, and in Boston, Richard Call specializes in SALT litigation, both before administrative and judicial bodies. San Francisco-based Charles Moll focuses on SALT tax controversy resolution, often before California tax authorities.

Morgan, Lewis & Bockius LLP is well-regarded for its tax controversy and litigation support for tax-exempt organizations, high-net-worth individuals, multinationals, and foundations. Covering transfer pricing controversies, administrative appeals, and litigation, the team also has strong IRS and international alternative dispute resolution programs. Based in San Francisco and Silicon Valley respectively, Barton Bassett and Rod Donnelly lead the tax litigation practice on the West Coast. In Philadelphia, Daniel Carmody represents in audits and appeals before the IRS for tax-exempt organizations, while in New York Mary Hevener specializes in payroll tax and employment tax litigation. Washington DC-based William Nelson deals with tax controversies related to partnerships and joint ventures, while Alex Sadler is an expert in R&D tax credit controversy and litigation. Tax litigation expert Tom Linguanti leads the Chicago practice. Sanford Stark, Saul Mezei and Terrell Ussing departed in November 2021. John Magee retired in 2021.

Baker Botts L.L.P. is a key resource for federal tax controversy and litigation, especially for clients in the energy, technology, and financial service industries. The team is particularly strong in the appellate courts, as well as offering longstanding expertise in estate and gift tax controversies against the IRS. The SALT practice also covers state audits, appeals, and litigation. In Houston, state and local tax chair Renn Neilson specializes in defence on sales tax controversies, while senior partner John Porter covers estate and gift tax controversies and administrative appeals. Located in San Francisco, William Gorrod covers SALT controversy, while Jon Feldhammer is noted for representing clients before the IRS and California Franchise Tax Board on income, estate, gift, and international tax disputes. Richard Husseini departed in August 2021.

Chamberlain Hrdlicka represents Fortune 100 corporations, multinationals, and high-net-worth individuals on federal and state litigation and criminal tax defense. The team also covers IRS litigation, audits, and appeals before Federal Circuit Courts and the Supreme Court. Houston-based co-chair Lawrence Sherlock specializes in negotiating and litigating federal tax disputes. He works alongside tax controversy co-chair Juan F. Vasquez, Jr. and Larry Campagna, a highly regarded tax defense expert. San Antonio-based federal and SALT controversy specialist Jamie Vasquez is also noted. In Atlanta, David Aughtry is noted for both criminal and civil tax controversy and litigation, and Hale Sheppard focuses on conservation easement and captive insure matters, while in Philadelphia tax litigation specialist Philip Karter covers high-profile matters including federal income tax, excise tax, and estate and gift tax. Former Justice of the Supreme Court of Texas Eva Guzman joined in August 2021, practicing out of Houston and San Antonio, and is particularly strong in SALT litigation.

The tax dispute specialists at DLA Piper LLP (US) represent corporates and high-net-worth individuals on a broad range of tax mandates, including complex SALT and federal tax litigation, international transfer pricing disputes, and audit defense. Based in New York, practice co-lead Ellis Reemer is an expert in civil and criminal tax disputes at all court levels. He works alongside co-lead Diana Erbsen, who concentrates her work on federal and SALT tax controversy, as well as criminal tax matters. In Los Angeles, Michael Patton is a key resource regarding transfer pricing disputes and advanced pricing agreements. Boston-based Tamara Shepard specializes in handling appeals, both in the federal appellate courts and IRS appeals. Splitting his time between Silicon Valley and Sacramento, Joseph Myszka covers the intersection of international tax controversy and tax-efficient operation organizational work.

The team at Gibson, Dunn & Crutcher LLP is well-regarded for its tax controversy work, ranging from audit and administrative resolution to trial proceedings and appeals. Its experience covers cross-border transfer pricing, investigations, and tax compliance. Clients include major players in technology, pharmaceuticals, e-commerce, and financial services industries. California-based Michael Desmond and Washington DC’s Sanford Stark   were jointly appointed to lead the team. Stark is an expert in federal tax controversy and litigation and joined from Morgan, Lewis & Bockius LLP in November 2021, while former Chief Counsel of the IRS Desmond joined in May 2021 and and is a highly regarded specialist in tax controversy. Tax controversy experts Saul Mezei and Terrell Ussing also joined the Washington DC office from Morgan, Lewis & Bockius LLP in November 2021.

The tax disputes team at Kirkland & Ellis LLP has a ‘strong deep bench for tax disputes’ in federal and state courts, administrative appeals, and dispute resolution before litigation stage. It is especially experienced in transfer pricing controversy proceedings and representing private equity funds in tax audits and proceedings. Based in Houston, practice co-lead Richard Husseini represents public and private companies and high net worth individuals before the IRS, courts, and regulatory bodies. Operating out of Chicago, co-lead Natalie Keller is experienced in transfer pricing disputes, particularly for clients in automotive, medical product, and pharmaceutical industries. She works alongside Todd Maynes, a tax litigation, debt restructurings, and insolvency specialist, and counsel JoAnne Nagjee, who represents clients in administrative appeals and post-appeal mediation.

The Washington DC-based tax controversy team at Miller & Chevalier Chartered represents Fortune 500 and Fortune 100 clients, as well as clients active in the oil and gas, aviation, and pharmaceutical industries before all courts. It is also experienced in tax dispute resolution short of litigation. Practice co-chair Kevin Kenworthy is a tax litigation expert, advising multinationals on high-value disputes while co-chair George Hani focuses on tax accounting controversies. Alan Horowitz specializes in appellate litigation and Maria O’Toole Jones is noted for her work in tax controversy concerning taxation of insurance companies. Adam Feinberg covers federal excise tax and related tax litigation; Lisandra Ortiz is a specialist in international tax and transfer pricing disputes, as well as tax refund litigation cases; and James Gadwood is particularly strong representing clients on IRS examinations and private letter rulings. Tax controversy expert Joseph Rillotta joined from Faegre Drinker Biddle & Reath in October 2021.

Akerman LLP represents major players in the financial, automotive, and technology industries on SALT and federal tax disputes. The team also represents clients before the IRS regarding international tax compliance, as well as administrative appeals, trials, mediation, and appellate litigation. Based in Jacksonville, practice chair Peter Larsen specializes in high stakes tax disputes, especially regarding emerging technologies and telecoms. In Chicago, deputy chair David Blum often represents US and multinationals before the IRS and state and local tax agencies, while in Jacksonville chair of the state and local tax practice Michael Bowen is a specialist in SALT controversy and litigation. 2021 saw the practice growing with executive compensation specialist Gabriel Marinaro joining from Katten in May; in November, SALT controversy specialist Lorie Fale and international tax specialist John Buckun joined from PricewaterhouseCoopers LLP and accountant firm Miller, Cooper & Co, respectively. Additionally, special counsel Liz Hughes joined from Greenspoon Marder LLP in November as well.

Holland & Knight LLP has a strong reputation for representing clients in high-stakes tax disputes at IRS administrative, federal, and state levels, as well as appeals. Its clients include oil and energy companies, tax-exempt organizations, high-net-worth individuals, and Native American tribes. August 2021 saw the merger with Texas-based Thompson & Knight, adding practice co-head Mary McNulty, Abbey Garber, and Lee Meyercord to the Dallas team. McNulty frequently represents major oil and gas companies in federal tax disputes, Garber is noted for his work in IRS appeals, and Meyercord is a key resource regarding high stakes SALT litigation. Based in Atlanta, Bill Sharp represents financial institutions in international tax enforcement and compliance. Tax controversy expert Joshua Odintz joined the Washington DC team from Baker McKenzie in March 2021.

The tax controversy team at Norton Rose Fulbright represents clients in SALT litigation, IRS appeals, competent authority disputes, and audits. Its expertise encompasses advance pricing disputes, transfer pricing, and competent authority matters regarding international tax. Operating out of Houston, tax practice co-head Robert Morris focuses on IRS examinations, appeals, and fast track mediations, as well as litigation in the Tax Court and federal district courts. New York’s Mayling Blanco is a white collar defense and commercial litigation specialist, as well as an expert in FCPA and criminal tax matters.

Winston & Strawn LLP represent clients on high-value and sensitive cases, including litigation and dispute resolution before the IRS and DOJ Tax Division. The team is especially strong in SALT, but is noted for its work in international tax dispute resolution with the IRS and foreign tax authorities. Practice leaders Jim Mastracchio and Susan Seabrook joined in January 2021 from Eversheds Sutherland. Splitting his time between Washington DC and New York, Mastracchio represents public and private companies involving complex multi-jurisdictional tax investigations by tax authorities. In Washington DC, Seabrook covers global tax controversy, including transfer pricing disputes. Additionally, DC-based counsel Todd Betor joined from Eversheds Sutherland in March 2021. He specializes in SALT litigation. Lawrence Hill  and Richard Nessler departed in June and July 2021.

BakerHostetler represents domestic and international clients on IRS appeals, tax audits, and litigation. It has particular expertise representing tax exempt organizations and representing in SALT-related litigation. Firm-wide chair of the tax group Jeffrey Paravano is based in Washington DC and focuses on multi-jurisdictional tax disputes and audits, as well as IRS appeals. He works alongside associate Nicholas Mowbray, who covers tax controversy for clients in the oil and gas industry. Based in Ohio, Edward Bernert is an expert in SALT controversy at all levels of court, while chair of the firm Paul M. Schmidt represents clients in IRS audits. In Cleveland, tax controversy co-lead Michelle Hervey represents major players in manufacturing, real estate, and agriculture. New York office leader Elizabeth Smith is a specialist in cross-border tax representation for clients in the financial services sector. In 2021 tax controversy specialists Alexander Reid and Matthew Elkin joined the DC office from Morgan, Lewis & Bockius LLP in July and August, respectively.

Dentons represents multinational clients active in retail, manufacturing, and energy industries in civil and criminal SALT litigation, including pre-trial investigation, pleadings, and trial. In Washington DC, co-head Jeffry Erney specializes in tax litigation and dispute resolution, often acting as lead counsel on major tax disputes and private letter rulings. Based in Louisville, co-lead Mark Lloyd covers areas such as administrative protest and settlement, federal excise tax, tax litigation, and appeals. DC-based managing associate David Mayhall is a key resource regarding civil tax controversies before the IRS as well as advising on tax legislation. Tax controversy expert Linda Pfatteicher joined from Squire Patton Boggs in June 2021. Scott Brian Clark departed in May 2021.

Led by Kathryn Keneally and Frank Jackson, the New York-based tax controversy team at Jones Day focuses on representing multinational corporations and high-net-worth individuals in US federal tax controversies before the IRS, US Tax Court and other federal courts. Connected to a global network of offices to provide full coverage regarding tax disputes, the team is also experienced in administrative investigations and grand juries, as well as civil tax disputes. Michael Scarduzio is a specialist in SALT controversy and criminal tax litigation, while Charles Hodges is an expert in federal tax litigation, especially cross-border tax disputes.

With multidisciplinary experience in areas such as transfer pricing disputes, tax accounting methods, and tax treatment of financial products, Shearman & Sterling LLP represents US and foreign clients before the IRS, US Tax Court, and federal courts. The team is noted for representing clients in front of congressional committees on sensitive criminal tax investigations and tax matters. In Washington DC, Kristen Garry covers tax controversies involving IRS audits and administrative appeals, as well as tax litigation, while counsel Robert Rudnick focuses on tax controversy at the administrative and litigation levels, often acting for clients in the telecoms and hospitality sectors. Richard Gagnon represents both international and US clients before the IRS and DOJ, as well as in federal courts.

Vinson & Elkins LLP represents clients in financial services, health care, real estate, and energy industries on both domestic and international tax disputes before tax authorities, as well as tax disputes between private parties. The firm has seen an increase in representing partnerships often owned by high-net-worth individuals or major corporations, as well as filing amicus briefs. Based in Houston, tax controversy team lead George Gerachis represents clients in Tax and Federal District Courts. He works alongside David Cole, who specializes in tax controversy, ranging from audits to IRS appeals and litigation. In Washington DC, Gary Huffman focuses on high-profile financial institutions and oil and gas corporations, and is a key resource regarding tax dispute resolution matters.

Based in Atlanta, the boutique tax controversy team at Asbury Law Firm represents corporations and high-net-worth individuals in federal tax litigation, especially the defense of syndicated conservation easements and IRS penalty assessments. Anson Asbury is a tax litigation specialist, with expertise ranging from criminal tax prosecutions to constitutional implications of tax statutes. Tax litigator Brian Gardner  has appeared before the US Tax Court and Court of Federal Claims.

The tax controversy team at Morrison Foerster handles audits, appeals, and dispute resolution proceedings before federal and state authorities and the IRS. Additionally, the team has represented corporations relating to tax shelter transactions and criminal enforcement proceedings. In New York team chair Anthony Carbone and counsel Rebecca Ulich-Balinskas focus on SALT controversy. In Washington DC, tax controversy leader and counsel Edward Froelich specializes in tax litigation, particularly involving complex corporate refund matters. San Francisco-based Bernie Pistillo takes the lead on international tax controversy work.

Pillsbury Winthrop Shaw Pittman LLP specializes in SALT litigation, with particular strength in representing Fortune 100 clients on both coasts. The Northern California team includes practice head Jeffrey Vesely and Carley Roberts, both highly regarded experts in SALT litigation. Annie Huang and Robert Merten are also noted in the San Francisco and Sacramento offices, respectively, for their impressive SALT controversy expertise. Merten was promoted to partner in December 2021. Additionally, Marc Simonetti is highly regarded for his SALT litigation expertise in New York. Peter Elias departed in February 2021, while Dana Newman has retired.

Ropes & Gray LLP represent asset management firms and clients in life sciences and fintech industries on complex federal and SALT litigation and appeals. The team provides mock audits, drafts formal and informal guidance on reporting and withholding of taxable income, and regularly represent clients in bankruptcy courts and before grand juries. Based in Boston, practice group leader Loretta Richard represents both corporations and high-net-worth individuals in general tax litigation matters, both in District Courts and Federal Court of Claims.

Connected to a global network of experts and regularly appearing before the IRS and foreign tax authorities, White & Case LLP is highly experienced in US and cross-border tax controversy resolution, particularly regarding transfer pricing disputes on behalf of Fortune 100 companies. The team is experienced in appeals and alternative dispute resolution procedures involving international tax treaties. Based in Washington DC, practice head Kim Marie Boylan is an expert in transfer pricing disputes, often appearing before IRS with alternative dispute resolution and administrative appeals expertise; Brian Gleicher leads the transfer pricing practice and regulatory represents multinationals in transfer pricing disputes through mutual agreement processes and advance pricing agreements.