Tax Controversies

Covington’s Tax Practice 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. In disputes with the tax authorities, we secure favorable results by efficiently resolving matters as early in the administrative process as possible and litigating when that is not possible.

Capabilities

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
• 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.