Latham & Watkins has a strong tax controversy practice and is regularly involved in complex corporate tax disputes, including debt-equity characterization, transfer pricing, employee benefits, and fraud-related matters, often with cross-border dimensions. The team represents clients in IRS audits, administrative appeals, and federal and state criminal tax investigations. The Washington DC-based practice is led by Brian McManus, who focuses on disputes with broader national tax policy implications. Jean Pawlow advises on digital taxation and international tax controversy matters. Newly promoted partner Eric Konopka concentrates on statutory and administrative issues, as well as tax aspects of bankruptcy proceedings. Miriam L. Fisher retired from the partnership in 2025.
Legal 500 Editorial commentary
Accolades
Client satisfaction: Sector knowledge
Client satisfaction: NPS ®
Testimonials
Collated independently by Legal 500 research team.
- ‘The Latham tax controversy team is one of the largest in the field, with talent at all levels from partners to junior associates. Unlike many other contentious tax practices, they operate as a coordinated unit, which allows them to staff matters efficiently — whether a large transfer pricing dispute requiring multiple attorneys or a smaller issue handled by one or two lawyers. They cover the full range of disputes, including both criminal and civil tax matters.’
- ‘My experience with the team has been entirely within the civil tax space, including transfer pricing, R&D credits, valuation disputes, and other technical tax issues. They are also highly effective in transaction support, identifying potential contentious tax risks in M&A deals and proposing practical solutions to resolve or mitigate those risks.’
- ‘Latham’s senior attorneys are experienced courtroom litigators who have tried high-profile cases in the US Tax Court and the Court of Federal Claims. Their fluency in economic and accounting issues distinguishes them from many peers, as does their ability to select and manage expert witnesses effectively. Among firms at the top of the contentious tax market, Latham provides particularly comprehensive and scalable solutions.’
- ‘Brian McManus, the Global Leader of the practice, is an exceptional strategist and courtroom litigator. He has a particular strength in assembling the right mix of legal professionals and independent consultants to address complex issues. Although a formidable cross-examiner, he is well regarded by government attorneys, which often facilitates early and cost-effective resolutions.’
Key clients
- Netflix
- Siemens Corporation
- Microsoft Corporation
- Chicago Mercantile Exchange
- Varian Medical Systems, Inc
- Denham Capital Management LP
- Citigroup Inc.
- Occidental Petroleum
- Estate of Stanley Fulton
- Netflix
Work highlights
Representing Netflix in 15 putative class action lawsuits brought by cities in Arkansas, California, Illinois, Indiana, Kansas, Louisiana, Missouri, Texas, Tennessee, Ohio, Nevada, Kentucky, New Jersey, and Georgia, alleging that Netflix and other streaming service providers owe franchise fees when their subscribers access video content over Internet connections located in the public rights-of-way.
Representing Major League Baseball Players Association (MLBPA) on all manner of tax and nonprofit compliance issues including player NIL licensing.
Representing CME Group, Inc. in tax litigation filed in the Court of Federal Claims requesting a refund of tax of $130 million attributable to a tax deduction created to assist American businesses to compete in the global marketplace and codified under former Code Section 199.
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.
Leading partners
The strongest partners in their field, leading on market-leading deals and endorsed by peers and clients alike.
Practice head
Miriam L. Fisher; Brian McManus;
Other key lawyers
Jean Pawlow; Eric Konopka