Global Tax Controversy and Litigation



Gibson Dunn’s Global Tax Controversy and Litigation Practice Group is highly skilled in navigating and resolving a broad range of complex domestic and cross-border tax disputes.

Gibson Dunn’s Global Tax Controversy and Litigation Practice Group is led by renowned tax controversy and litigation lawyers with decades of experience handling the largest and most complex cases on behalf of a wide range of taxpayers.  Our team members have worked at the highest levels of government as the most recent IRS Chief Counsel and a recent Deputy Associate Chief Counsel (International), and include award-winning former trial attorneys with the U.S. Department of Justice Tax Division.  Our broad and deep experience enables us to craft nuanced strategies for achieving the most effective and efficient resolution of any tax dispute.  We handle contested matters involving a broad range of tax issues, including:

  • Cross-border transfer pricing
  • The tax treatment of in-bound and out-bound transfers and investments
  • Withholding taxes
  • Controversies arising under the Tax Cuts and Jobs Act
  • Partnership tax disputes arising under the procedural rules of the Balanced Budget Act and the Tax Equity and Fiscal Responsibility Act
  • Employment taxes, worker classifications, and employee benefits
  • The tax treatment of financial products
  • Estate and gift taxes
  • Renewable energy credits and other business tax credits
  • Investigations and tax-related compliance for public companies and other regulated entities
  • Excise taxes
  • Franchise taxes
  • Exempt organization matters
  • Information reporting and related withholding provisions
  • The tax treatment of blockchain and other digital asset transactions and structures

In the United States, we represent clients at the federal, state, and local levels.  We work with clients at all stages of tax controversy and litigation, ranging from audit and administrative appeals through trial court proceedings and judicial appeals.  In federal litigation, we represent clients in the U.S. Tax Court, the Court of Federal Claims, the federal district courts and courts of appeal, and the United States Supreme Court.  We also represent clients in international matters, both in unilateral disputes before foreign tax authorities and in bilateral and multilateral disputes involving competent authority.  We have extensive experience in resolving uncertain tax positions through letter rulings, advance pricing agreements, and other processes available to secure advance guidance and direction from relevant tax authorities, helping our clients to avoid or mitigate the risks of tax controversies before they arise.

For additional information, please visit our Tax practice page.


Supreme Court Holds That 2017 Mandatory Repatriation Tax Does Not Violate The Sixteenth Amendment

-June 20, 2024

IRS and Treasury Issue Guidance on Related-Party Basis Adjustments

-June 17, 2024

Supreme Court Holds That A Corporation’s Life Insurance Proceeds Used To Redeem A Decedent’s Shares Must Be Included In Federal Estate Tax Calculation

-June 6, 2024

Chambers and Partners Transfer Pricing 2024

-May 24, 2024

Tax Court Determines That Limited Partners Are Not Necessarily Exempt from Self-Employment Tax – The Limits of the Limited Partner Exception, as Such

-December 19, 2023

Who’s Who Legal Recognizes Four Gibson Dunn Partners in Corporate Tax 2023

-November 7, 2023

Gibson Dunn Recognized in Chambers High Net Worth 2023

-July 20, 2023

New IRS Guidance on Acceptance of Advance Pricing Agreement (APA) Submissions and Increased Pre-Submission Review

-May 25, 2023

Who’s Who Legal Recognizes 39 Gibson Dunn Partners in its Inaugural Thought Leaders USA Guide

-January 9, 2023

IRS and Treasury Issue Interim Guidance Addressing the Corporate Alternative Minimum Tax

-January 6, 2023

IRS and Treasury Issue Proposed Regulations Narrowing Domestically Controlled REIT Qualification Test and Revising Section 892 Exemption, as Well as Final Regulations Relating to Qualified Foreign Pension Funds

-January 4, 2023

Penalty Relief Available: Recent Jurisprudence Offers the Opportunity for Significantly Lower Fines and Other Penalties in White Collar Resolutions with DOJ and Other Agencies

-January 3, 2023

IRS and Treasury Issue Interim Guidance on New Stock Buyback Excise Tax

-January 3, 2023

IRS and Treasury Issue Proposed Regulations on Consolidated Group Ownership of CFC Stock for Certain Purposes

-December 16, 2022

Proposed U.S. Foreign Tax Credit Rules Provide Relief for Certain Taxpayers and Ideas for Others

-December 1, 2022

Gibson Dunn Ranked in World Tax 2023

-September 29, 2022

11 Gibson Dunn Partners Named Lawyers of the Year

-August 18, 2022

Update: Senate Passes Revised Version of Inflation Reduction Act of 2022; Carried Interest Changes Omitted and Tax on Corporate Stock Buybacks Added

-August 10, 2022

Inflation Reduction Act of 2022 Would Modify the Tax Treatment of Carried Interests, Include a Corporate Minimum Tax, and Expand Clean Energy Tax Incentives

-July 29, 2022

Gibson Dunn Recognized in Chambers High Net Worth 2022

-July 14, 2022

Expert Guides Recognizes Four Gibson Dunn Partners in Tax

-July 8, 2022

Supreme Court Holds That Late Petitions For Review Of IRS Collection Due Process Determinations Are Subject To Equitable Tolling

-April 21, 2022

The Biden Administration’s Digital Assets Executive Order and Its Implications

-March 10, 2022

How Justices May Interpret Statutory Time Bar In Tax Context

-January 24, 2022

The Potential for Tax Enforcement Through Subregulatory Guidance

-December 13, 2021

Infrastructure Bill’s New Reporting Requirements May Have Sweeping Implications for Cryptocurrency Ecosystem

-November 18, 2021

Gibson Dunn Adds Tax Controversy Group, Led by Sanford Stark, in Washington, D.C.

-November 15, 2021

U.S. House Ways and Means Committee Proposes Substantial Extension and Expansion of Clean Energy Tax Incentives

-October 13, 2021

Senate Finance Committee Chairman Ron Wyden (D-OR) Introduces the “Ending The Carried Interest Loophole Act” That Would Require Current Ordinary Income Inclusions

-August 10, 2021

Biden Administration Releases Fiscal Year 2022 Budget, Together With a “Greenbook” Providing Detailed Descriptions of Proposed Changes to Federal Tax Law and Accompanying Revenue Estimates

-May 29, 2021

Former IRS Chief Counsel Michael Desmond Joins Gibson Dunn’s Los Angeles and D.C. Offices

-May 3, 2021

World Tax Recognizes Sandy Bhogal and Elaine Chen

-September 24, 2020

UK Supreme Court Decides Suspending UK Parliament Was Unlawful

-September 24, 2019

Supreme Court Holds That Payments For Lost Wages Are Taxable “Compensation” Under The Railroad Retirement Tax Act

-March 4, 2019