Andersen

Andersen

Tax Controversy

Andersen’s tax controversy practice helps clients navigate complex audits and appeals and resolve challenging practice and procedure matters with federal, state, local, and foreign tax authorities. 

Our professionals have years of experience dealing with a wide range of issues for private clients, businesses, and alternative investment funds. Complex regulations coupled with increased enforcement present a substantial need for clients to have support from trusted and experienced tax controversy professionals. Our team adds value over the full lifecycle of taxation, from planning and reporting through examination defense and dispute resolution. Our tax controversy professionals work closely with Andersen subject-matter specialists to ensure that the right combination of tax technical expertise is paired with a thorough understanding of practice and procedure to secure optimal outcomes for our clients. Our tax controversy professionals can assist you with:

Audits & Appeals

  • Managing communication, coordinating timeline, and limiting scope with examiners from early stages through closing in pursuit of a “no change” conclusion.
  • Negotiating and responding to Information Document Requests (IDRs).
  • Conducting technical research and analyses to support tax positions.
  • Defending tax positions in response to Notices of Proposed Adjustment (NOPAs).
  • Preparing protest letters to the IRS Independent Office of Appeals and providing representation.
  • Rendering expert testimony, analyses, and other litigation support in judicial proceedings.

Practice & Procedure

  • Communicating with tax authorities through notice and letter analysis and response, telephone calls via priority service lines, acquisition of transcripts and status updates, and imposition of collection holds.
  • Providing advice and guidance with respect to statute of limitations, BBA partnership procedure, foreign and domestic withholding and reporting, refund claims and Joint Committee on Taxation review, and collection due process for federal tax liens and levies.
  • Assisting with residency certifications, EIN verification, entity classification issues, interest computations, transcript analysis, identity and tax return verification, voluntary disclosure, and penalty abatement.
  • Facilitating requests for Taxpayer Advocate Service assistance and providing representation throughout the resolution process with the assigned advocate. 

Other

  • State and Local Tax Controversy – Navigating complex audits and appeals and resolving challenging practice and procedure matters with state and local tax authorities.
  • R&D Controversy – Defending R&D credit reporting in audit and appeal cases and supporting R&D credit refund claims.
  • International Tax Controversy – Managing challenges to transfer pricing positions in audit and appeal cases and providing support with Advance Pricing Agreements, Mutual Agreement Procedures, and Competent Authority.
  • Global Tax Controversy – Dealing with foreign tax authorities in more than 170 countries worldwide through the Andersen Global association of member firms.

Partners in Creating Value

Andersen knows that the best way to avoid controversy is to plan for it. Our tax controversy professionals interact with local client service teams on a regular basis, inviting local teams to involve the tax controversy practice before tax returns are filed and examination notices are sent. Disputes can often be avoided through appropriate documentation and the development of fact patterns that support favorable tax positions. Andersen tax controversy professionals include former IRS and Treasury attorneys who provide a critical review of return positions and substantiation requirements before disputes arise with tax authorities. Whenever possible, Andersen adds value to clients by resolving potential controversies before they materialize.