When tax exposure is material, timing and strategy determine outcomes.

 

Businesses and individuals facing complex IRS issues require more than technical analysis - they require strategic representation that aligns legal position, timing, and risk.

 

Whether you are challenging an IRS adjustment, evaluating a high-value transaction, or managing transfer pricing exposure, the right approach can reduce liability, avoid penalties, and create certainty before positions are tested.

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​​When You Need a Tax Controversy Attorney

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You should consider engaging experienced representation when:

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• The IRS proposes significant audit adjustments or penalties

• A transaction involves uncertain or high-risk tax treatment

• Transfer pricing exposure is recurring or material

• You need certainty before taking a return position

• Strategic decisions will materially affect financial outcomes

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​​In many cases, early strategic decisions determine the outcome before the IRS process fully unfolds.

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Why Clients Engage Us

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Clients engage us when stakes are high and timing matters.  

 

We provide:

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• 30+ years of IRS-facing experience, including matters before Appeals, Chief Counsel, and APMA

• Proven results in high-dollar disputes, rulings, and transfer pricing matters

• Strategic judgment on when to fight, settle, or seek advance IRS certainty

• Alignment of legal strategy with business and financial objectives

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Core Services

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IRS Appeals Representation

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If an audit does not resolve favorably, the IRS Appeals process is often the most effective opportunity to reduce adjustments and resolve disputes without litigation.

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If your matter involves an IRS dispute, timing and positioning are critical.  

 

Learn more about our IRS Appeals attorney services.

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Private Letter Ruling (PLR) Requests

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For transactions involving uncertainty, a Private Letter Ruling request can provide binding IRS guidance before a position is taken.

When tax treatment is uncertain, the cost of being wrong can exceed the cost of getting clarity.

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Explore our Private Letter Ruling services to obtain binding IRS guidance before positions are taken.

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​​​​Advance Pricing Agreement (APA) Strategy

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For ongoing transfer pricing exposure, an Advance Pricing Agreement can provide multi-year certainty and reduce audit risk.

Transfer pricing exposure is rarely a one-year issue - without alignment, it can create recurring audit risk, double taxation, and financial statement uncertainty.

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Learn about our Advance Pricing Agreement representation to negotiate an agreement with the IRS.

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Strategic Cross-Border Tax Controversy

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Multinational tax disputes often require coordinated evaluation of:

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   •  IRS controversy exposure
   •  Transfer pricing risk
   •  Double taxation concerns
   •  Financial reporting implications
   •  Long-term certainty strategies

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We represent businesses in:

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   •  IRS Appeals
   •  Advance Pricing Agreement
   •  IRS Appeals for Transfer Pricing Disputes

 

Effective controversy strategy often requires integrating both proactive certainty planning and reactive dispute resolution.

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Choosing the Right Strategy

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The appropriate approach depends on timing and risk.  

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• Under audit → IRS Appeals representation

• Before a transaction → Private Letter Ruling request 

• Ongoing cross-border exposure → Advance Pricing Agreement

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Each approach involves different timing, risks, and outcomes. 

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To better understand how disputes are resolved in practice, see how the IRS Appeals process works.​

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Who We Represent

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Our clients include:

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• Multinational companies

• Middle-market businesses

• Family offices & high-net-worth individuals

• CFOs, tax directors and in-house counsel

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How We Help Clients Choose the Right Strategy

 

Not every IRS issue should be approached the same way.

 

Some matters require an Appeals strategy focused on litigation risk. Others call for advance IRS certainty before a return position is taken. Recurring transfer pricing exposure may require a longer-term APA strategy.  

 

We help clients determine the right path before positions are finalized and exposure increases.

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What Most Taxpayers Get Wrong​

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• Entering IRS Appeals without a developed record

• Requesting a Private Letter Ruling when the issue does not warrant it

• Avoiding Advance Pricing Agreements despite recurring exposure​

 

* These decisions often determine outcomes before the IRS process even begins.

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Before your position is tested by the IRS, a short strategic discussion can identify risks and opportunities that materially affect the outcome.  

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Frequently Asked Questions (FAQs)

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What does a tax controversy attorney do?  ​

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​A tax controversy attorney represents businesses and individuals in disputes and strategic matters involving the Internal Revenue Service.

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This includes:

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• Resolving audit disputes through IRS Appeals

• Obtaining advance IRS guidance through Private Letter Rulings

• Managing transfer pricing risk through Advance Pricing Agreements​

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When should I contact a tax controversy attorney?  ​

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You should consider engaging counsel when:

 

• The IRS proposes significant adjustments or penalties

• A transaction involves uncertain tax treatment

• Transfer pricing exposure is material

• You need IRS certainty before filing a return

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​​*  Early involvement often materially improves outcomes.

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What is the difference between IRS Appeals, a PLR, and an APA?​

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• IRS Appeals resolves disputes after an audit

• A Private Letter Ruling provides advance IRS guidance

• An Advance Pricing Agreement establishes transfer pricing methodology for future years​

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The appropriate strategy depends on timing, risk, and financial exposure.

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Can IRS disputes be resolved without litigation?​

​Yes. Many disputes are resolved through IRS Appeals, where cases are evaluated based on hazards of litigation rather than rigid audit positions. 

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How early should I seek IRS representation?​

​The earlier, the better. Engaging counsel before positions are taken - or early in an audit - can significantly improve outcomes and may prevent disputes entirely.

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​Schedule a Confidential Consultation

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Whether you are managing an IRS dispute, evaluating a high-value transaction, or addressing recurring transfer pricing exposure, early strategic decisions can materially affect certainty, leverage, financial exposure, and long-term outcome.

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A focused evaluation can help determine:

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• The most effective strategic path forward
• Whether proactive or reactive resolution tools are appropriate
• How to manage risk, timing, and operational impact
• How to position the matter to maximize long-term certainty and flexibility

 

Our practice focuses on strategic tax controversy and tax certainty matters involving:

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• IRS Appeals
• Private Letter Ruling
• Advance Pricing Agreement

 

Tax controversy is not simply about resolving disputes - it is about strategically managing exposure, uncertainty, and long-term business risk.

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