Tax Controversy

Tax Controversy practice provides thoughtful and experienced advocacy on behalf of clients in local tax disputes nationwide. We represent clients at all stages of the administrative process from first-stage and higher trial courts to the Supreme Court.

Particular focuses of our practice are advising clients during the planning of transactions resolving disputes without litigation, whenever it is possible and in the client’s best interests. By working to resolve disputes at the earliest possible stage, we are often able to reach favorable outcomes for our clients without the additional costs, distraction, and publicity that necessarily accompany any formal tax litigation. At the same time, we understand that some disputes cannot be resolved consensually. In litigated matters, we bring to bear a team of experienced tax litigators who understand both the substantive tax issues and how to present a case effectively.

VIRPO’s Tax Controversy lawyers have an in-depth understanding of tax matters arising in controversies affecting a broad array of industries, including the banking, financial products, manufacturing, food processing, insurance, entertainment, and utility industries. Likewise, we have significant experience with many of the issues on which local taxing authorities currently. On the enterprising side those include debt/equity issues, the determination of ownership of property, the domestic production deduction under Tax regulory, capital versus expense classifications, losses from trading, transactions and consolidated returns, tax credits, transfer pricing, and placed-in-service date disputes. We have also handled legal cases involving tax. For income and business activity taxes, those issues include the composition of a combined group, business and non/business income characterization and expense attribution, fair apportionment, the taxability of proprietary investing, and credit syndication transactions. For transaction taxes, our experience includes such issues as the characterization of transactions, the scope of statutory and case-law exemptions, commercial acquisition and leasing, etc.

 

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