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While taxes are always front of mind for businesses, recent changes to federal tax law and a significant boost in funding for tax enforcement in the U.S. have reinforced the need for sophisticated guidance in this area. In this new era, businesses need experienced lawyers who can help with their most challenging and complex tax issues.

Crowell’s Tax Group is a full-service team that provides U.S. federal and state tax advice and representation in all types of business transactions as well as tax controversies and litigation. We represent public and private businesses of all types in the insurance, energy, communications, software, high technology, consumer goods, chemicals, hospitality, financial services, automotive leasing, and retail sectors. We also advise tax-exempt organizations, including not-for-profit health care organizations, educational institutions, cultural institutions, foundations, and trade associations in a wide range of matters.

Experienced and Collaborative Team

With decades of experience advising clients on tax issues – and only tax issues – our team has deep knowledge of this area and all aspects of IRS and state administrative proceedings. Our lawyers are also deeply familiar with the inner workings of the government. Clients benefit from the prior government experience many of our lawyers have with the Department of Justice Tax Division, and IRS Office of Chief Counsel. Agency staff know and respect our firm, are willing to work with our team, and have developed highly productive relationships with our attorneys. 

A hallmark of working with Crowell, and an advantage for clients, is the collaboration between attorneys in the tax practice who call on each other as needed and draw on the experience of attorneys and professionals within other practices as well.

How We Can Help You

Tax Audits, Appeals and Litigation

Crowell & Moring’s Tax Group handles more active tax litigation matters than many of its much larger competitors. In recent years, members of the group have handled tax controversies and litigation on behalf of leading insurance, telecommunications, software, defense, and financial services firms.

Clients appreciate our long history of achieving outstanding results in tax controversy and litigation. Our tax group has litigated numerous tax cases before the U.S. Tax Court, U.S. Court of Federal Claims, U.S. district courts, U.S. bankruptcy courts, U.S. courts of appeals, and various state courts.

We recognize that litigation is a last resort and make innovative use of IRS Appeals, Fast Track Settlement, Post‐Appeals Mediation, Industry Issue Resolution, Pre‐Filing Agreements, Compliance Assurance Program (CAP), and other alternative dispute resolution techniques.

Administrative Practice

The Tax Group has a robust administrative practice representing clients before the IRS and state tax authorities. This part of our controversy practice, which is by its nature non-public, involves large-dollar controversies for companies across a number of industries (involving asserted tax liabilities from $50 million to over $700 million).

Clients trust us with large-dollar cases because we have a strong track record in resolving cases administratively with the IRS. Our clients also have confidence that, if necessary, we have the trial experience to bring large, complex tax cases to court and win.

Transfer Pricing Practice

Our transfer pricing practice helps multinational companies resolve international tax disputes through the United States’ tax treaty network, most recently in the furniture, hospitality, and chemical industries.

We regularly appear before the IRS’s Advance Pricing and Mutual Agreement office (APMA), where we have been successful in resolving transfer pricing disputes involving hundreds of millions of dollars as well as penalties in the tens of millions of dollars. 

Our other service areas include:

  • ERISA, Employee Benefits, and Executive Compensation
  • International Tax
  • Non-profit and Tax-Exempt Organizations
  • Partnership Tax
  • State and Local Tax
  • Tax Accounting
  • Transactional Tax

View More

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Press Coverage
Ascension Employee Benefits Atty Joins Crowell & Moring Law360 (October 28, 2022)
Press Coverage
"International Tax Controversy – APAs, Competent Authority, and MAP Proceedings," TEI 77th Annual Conference, Scottsdale, AZ. (October 26, 2022). Speaker: David J. Fischer.
Speech/Presentation
"Recent Developments at IRS Appeals," Managing Tax Audits and Appeals Seminar 2022, Washington, D.C. (October 7, 2022). Speakers: David J. Fischer and Eleanor Moran McWaters.
Speech/Presentation
"Navigating Privilege in the Audit Context," Managing Tax Audits and Appeals Seminar 2022, Washington, D.C. (October 7, 2022). Speakers: S. Starling Marshall and Reid Tomasello.
Speech/Presentation
"A New Wave of Partnership Audits – What to Know Now and How to Prepare," Managing Tax Audits and Appeals Seminar 2022, Washington, D.C. (October 7, 2022). Speakers: Charles C. Hwang and Reid Tomasello.
Speech/Presentation
"Looking Over the Horizon," Managing Tax Audits and Appeals Seminar 2022, Washington, D.C. (October 7, 2022). Speaker: Irina Pisareva and Eric Homsi.
Speech/Presentation
"Recent Developments in the IRS Large Business & International Division (LB&I)," Managing Tax Audits and Appeals Seminar 2022, Washington, D.C. (October 6, 2022). Speaker: David B. Blair and Carina C. Federico.
Speech/Presentation
"Transfer Pricing in Flux," Managing Tax Audits and Appeals Seminar 2022, Washington, D.C. (October 6, 2022). Speaker: David J. Fischer.
Speech/Presentation
"Recent Tax Accounting Cases Answer Important Questions," Managing Tax Audits and Appeals Seminar 2022, Washington, D.C. (October 6, 2022). Speakers: Dwight N. Mersereau and Samantha Skabelund.
Speech/Presentation

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Crowell & Moring LLP is an international law firm with offices in the United States, Europe, MENA, and Asia that represents clients in litigation and arbitration, regulatory and policy, and transactional and corporate matters. The firm is internationally recognized for its representation of Fortune 500 companies in high-stakes litigation and government-facing matters, as well as its ongoing commitment to pro bono service and diversity, equity, and inclusion.

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