Global Tax Controversy and Litigation

LEADERS

Overview

Gibson, Dunn & Crutcher’s Global Tax Controversy and Litigation Practice Group represents multinational corporations, privately held companies, investment funds, partnerships, sovereign wealth funds and individuals in resolving a broad range of complex domestic and cross-border tax disputes.  We work with clients at all stages of tax controversy, ranging from audit and administrative resolution through trial court proceedings and judicial appeal.  We also have extensive experience in resolving uncertain tax positions through letter rulings and other procedures available to secure advance guidance and direction from relevant tax authorities, helping our clients to avoid or mitigate the risk of tax controversies before they arise.  Our tax controversy and litigation lawyers work closely with the firm’s market-leading corporate, commercial litigation, intellectual property, appellate and other practices in a variety of contexts, including disputes with national, regional and local tax authorities and in contentious tax matters involving private parties.

The Global Tax Controversy and Litigation team is led by renowned tax litigators with decades of experience handling the largest and most complex cases and working at the highest levels of government, including the former Chief Counsel of the U.S. Internal Revenue Service.  Our clients come from a range of industries, including technology, pharmaceutical and medical device, consumer goods, electronic commerce, oil & gas, and financial services, among others.  The issues we handle reflect the broad scope of the tax law and include cross-border transfer pricing with a focus on valuing intangible property, the tax treatment of various in-bound and out-bound transfers and investments, partnership tax issues, tax accounting matters, employment taxes and employee benefits, renewable energy credits and other business tax incentives, investigations, and other tax-related compliance matters for public companies and other regulated entities.

In an increasingly interconnected global economy, our experience extends to high-stakes tax controversy matters across Asia, Europe and the Americas.  In the United States, the team handles federal, state and local tax audits, administrative appeals in the IRS’s Independent Office of Appeals, and litigation before various federal and state trial and appellate courts, including the United States Supreme Court, the federal courts of appeal, the U.S. Tax Court and the Court of Federal Claims.  Collaborating with other firm practice groups has proven valuable in securing favorable outcomes and court victories in forums ranging from administrative examinations through the U.S. Supreme Court.

For additional information, please visit our Tax practice page.

RECENT PUBLICATIONS

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