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Covington handles major tax controversies involving virtually every aspect of substantive tax law for large multi-national companies and other clients from audit and administrative appeals to litigation. Covington’s controversy experience includes alternative dispute resolution techniques such as arbitration and mediation. Covington explores every procedural and practical approach to resolve difficult issues in a matter that will meet our clients' goals and expectations while minimizing to the extent possible the utilization of client resources. Covington believes that a close partnership and teamwork with its clients' audit and litigation staffs is important to the most effective and efficient resolution of large case tax controversies.
Covington’s tax controversy experience includes very large case audits, administrative appeals and litigation involving a broad spectrum of subject matter areas, including transfer pricing, foreign tax credits, accounting methods and treatment of corporate reorganizations and restructurings, FSC and ETI benefits, treatment of items under the consolidated return regulations, allocations under Section 861, partnership issues, allowance of losses on subsidiary stock, form over substance, Subpart F inclusions, and summons enforcement actions. Covington understands that resolution of tax controversies requires creativity and a complete understanding of the impact of the controversy and potential resolutions on its clients. A recently negotiated global settlement of tax issues for the major sports leagues illustrates Covington’s in-depth approach to achieving controversy resolutions for its clients.
Representative Matters
- We have served as lead counsel for several companies in the resolution of large case audits and administrative appeals. These cases involved multiple issues including transfer pricing, worthless stock claims, foreign tax credits and various accounting issues.
- Litigated cases include International Business Machines Corp. v. United States, 87 A.F.T.R.2d (RIA) 2001-536 (Fed. Cl. 2001); International Business Machines Corp. v. United States, 39 Fed. Cl. 661 (1997); International Business Machines Corp. v. United States, 116 S. Ct. 1793 (1996); Buffalo Bills, Inc. v. United States, 31 Fed. Cl. 794 (1994); Estate of Catherine Schlumberger Jones v. Commissioner, T.C. Dkt. No. 4911-94; Wymann-Gordon Co. v. Commissioner, T.C. Dkt. No. 10874-91; Tallahassee Memorial Regional Medical Center v. Commissioner, T.C. Dkt. No. 24374-97; Hiram Walker-Gooderham & Worts, Inc. v. Commissioner, T.C. Dkt. No. 25185-90.
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