Tax Controversy Represent taxpayers, particularly Fortune 1000 and leading financial institutions, high net worth individuals and public accounting firms, in disputes and other matters before the Internal Revenue Service. Expertise covers a broad spectrum of substantive areas of tax law and compliance issues, as well as all phases of litigation, including: • IRS examinations, administrative appeals, fast track settlement, and post appeals mediation • FIN 48 and UTP • tax litigation in United States Tax Court and Court of Federal Claims, including preparing executives for and defending depositions, discovery disputes, summons enforcement and privilege issues • tax-advantaged transactions and financial products, application of judicial doctrines, and Section 6707 and 6708 audits • foreign withholding under Section 1442 • TEFRA examinations and related issues • Foreign Bank Account Reporting issues and compliance, and • transfer pricing. Present internal seminars to business leaders at clients on compliance with reportable transaction and material advisor rules. Teach, train and supervise associates. Transactional Counseling Provide advice and counsel to senior management on structuring transactions in a tax efficient manner. Monitor implementation and documentation of tax-sensitive transactions to prepare for future IRS examinations. Relationships Experienced in communicating and negotiating with the national office of the IRS, Issue Champions, DFOs and Industry Directors. Provide advice and counsel to senior executive management and, internally, to practice leaders and other colleagues, across practice disciplines.