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Covington’s tax group advises multinational clients on their most significant and challenging tax issues. Our members have extensive government experience, including senior positions at the U.S. Department of Treasury, International Revenue Service, and the U.S. Senate. Combined with our talents, focus and creativity, we provide bespoke solutions for sustained tax minimization in an increasingly regulated world. And, in disputes with the tax authorities, we secure favorable results by efficiently resolving matters as early in the administrative process as possible, and, where not possible, we litigate.

Covington’s tax controversy experience includes very large case audits; advance pricing agreements, private letter rulings, and competent authority proceedings; fast track settlements, administrative appeals, and post-IRS appeals mediation; Administrative Procedure Act challenges; and Tax Court and other litigation involving a broad spectrum of subject matter areas. We understand that efficient resolution of tax controversies requires creativity and a complete understanding of the impact of the controversy and potential resolutions on our clients and their operations.