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Chadbourne tax lawyers have been lead lawyers in many major tax controversy matters. Recent cases have included representation of a multimedia international conglomerate (in which the IRS proposed hundreds of adjustments and deficiencies of hundreds of millions of dollars and in which the taxpayer ultimately received a refund); representation of the New York Clearing House banks (in the settlement of a controversy with New York City concerning offshore bank income); representation of an insurance company before the Court of Federal Claims (in which the company received one of the largest refunds ever paid by the IRS); representation of numerous public and private companies before the IRS in audit and appeals (in which resolutions with the IRS have been termed by our clients as “spectacular”) and in competent authority proceedings under tax treaties; representation of numerous foreign-owned US companies (involving intercompany transfer pricing and other Section 482 issues); representation of a trucking company before the District Court and Court of Appeals (involving an important tax issue for the trucking industry); and even representation of a New York University professor before the US Tax Court and Court of Appeals (involving the taxability of scholarships).

The tax group has obtained from the IRS important, precedent-setting private letter rulings on behalf of our clients. Our reputation has also been instrumental in our efforts to make changes to Treasury regulations and to have a major impact on legislative proposals, both in terms of broad tax policy and in the most focused provisions.

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