Baker McKenzie has a comprehensive tax controversy offering, handling all phases of dispute resolution, from large-scale IRS audits through to high-profile federal court litigation. The team advises on complex domestic and cross-border tax disputes, drawing on deep experience across contentious and investigatory matters. The practice is led from Washington DC by George Clarke, whose work focuses on governmental litigation, including civil and criminal tax proceedings. In Chicago, Mark Oates is noted for his experience in transfer pricing disputes, valuations, research credit matters, inventory accounting, and civil fraud cases. New York-based Maria Eberle is a key advisor to multinational corporations on complex federal and international tax controversies. In Palo Alto, Duane Webber handles procedural disputes involving insurance tax, consolidated returns, inventory, and tax accounting, while Scott Frewing focuses on offshore account investigations and allegations of tax fraud.
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Key clients
- Amgen
- Meta Platforms, Inc.
- Airbnb, Inc.
- AbbVie Inc.
- Abbott
- Douglas Edelman
- Gap, Inc.
- Western Union
- FedEx
- Best Buy
- CVS Health Corporation
- Bayer
Work highlights
Completed an eight week trial in the United States Tax Court for Amgen. The primary transfer pricing dispute involves a proposed IRS income adjustment exceeding USD 23 billion for the period 2010-2015 and associated penalties.
Represented Meta in a recent prominent tax case challenging an IRS proposed income adjustment of over USD 13 billion. After a multi-year trial, we defeated approximately 90% of the IRS adjustment.
Supporting Airbnb in its Tax Court litigation with the IRS disputing the IRS’s USD 4.2 billion adjustment to Airbnb’s cost-sharing PCT and assertion of 6662 penalties.
Lawyers
Hall of Fame
The lawyers at the very top of the profession, widely known and respected by peers and clients for their longstanding involvement in market-leading work.
Scott Frewing
Leading partners
The strongest partners in their field, leading on market-leading deals and endorsed by peers and clients alike.
Practice head
George Clarke
Other key lawyers
Mark Oates; Maria Eberle; Duane Webber; Scott Frewing
