Tax Controversy

Tax Controversy

Hunton & Williams LLP's tax controversy practice includes a diverse team of tax and litigation attorneys. We are regularly engaged by our clients to solve some of the most difficult tax problems. We represent clients in the following areas:

IRS audits and administrative appeals. Extensive experience representing clients in industry, coordinated, tiered, and emerging issues

  • Issue resolution. Obtaining private letter rulings (PLRs), technical advice memoranda (TAMs), and pre-filing agreements (PFAs)
  • Government relations. Regular interaction with Congressional tax-writing committees and staff and high levels of the U.S. Treasury Department and IRS Office of Chief Counsel to obtain critical legislation, major policy changes, regulations, and published guidance
  • Energy tax controversy. Particular experience drawing on our history of representing major energy companies and utilities, advising in transactions involving renewable energy tax credits, and experience in controversies involving new energy programs such as the Section 1603 Treasury Grant program
  • Federal tax litigation. Representation of clients in the U.S. Tax Court, the Court of Federal Claims, and the various District Courts

We represent clients at the IRS audit level and through tax litigation. It is our firm belief that in the current IRS culture every audit and tax issue has the potential to turn into a serious and prolonged audit, administrative appeal, and possibly even litigation. IRS audits cannot be taken lightly. IRS auditors commonly consult with their tax controversy attorneys and formulate a strategy for the audit at the earliest stages. Taxpayers, likewise, should engage experienced tax controversy lawyers and devise a formal strategy at the earliest possible point in the life of the tax controversy. Early attention to tax controversies affords the benefit of strategic consulting to protect evidentiary privileges, develop a strong record, and build a foundation for a favorable outcome. It is our experience that this approach saves our clients much time and money in the long term and protects clients from taking detrimental positions in the early stages of the IRS audit or appeal.

Nonetheless, we often are engaged at the last minute to solve tax problems that most other law firms, accounting firms, and clients are unable to solve. In these circumstances, we have developed unique and aggressive strategies to achieve favorable results for our clients. If the circumstances require it, we are prepared to elevate tax issues to the highest levels of the U.S. Treasury and the IRS Office of Chief Counsel, to seek Chief Counsel guidance or a PLR or TAM, or to seek a political resolution in the U.S. Congress or a judicial resolution in the Tax Court, Court of Federal Claims, or U.S. District Courts. We often develop multi-tracked strategies to resolve tax controversies at the earliest possible moment. We seek out and engage the top experts in the field or approach federal, state, and local agencies and representatives to assist in developing the appropriate facts to assist in the presentation of our client's case. We take great pride in resolving difficult tax problems for our clients.