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.