Kirkland’s Tax Disputes Practice Group helps clients resolve complex tax issues and disputes. Combining deep knowledge of substantive tax law with the intricacies of tax practice and procedure, we assist clients in anticipating and planning for potential future tax controversies at the time transactions are structured and completed. When tax controversies arise, we work to resolve them confidentially in examinations by the IRS or state and local taxing authorities, in administrative appeals, and with competent authorities through the Mutual Agreement Procedures (MAP). When a satisfactory administrative resolution is not available, we have substantial experience in trying — and winning — high-stakes tax cases in every tax litigation forum, all the way through appeal and to the Supreme Court.
We advocate on behalf of clients with respect to other sensitive tax issues, including criminal investigations, voluntary disclosures, whistleblower defense, fraud allegations, promoter audits, and congressional and internal investigations involving tax issues.
We also assist clients in arbitration and litigation with contractual counterparties over tax issues such as tax indemnities, tax sharing agreements, and investment tax treaty provisions.
We represent all types of taxpayers — corporations, partnerships (through the specialized TEFRA and BBA partnership audit procedures), individuals (including those subject to the Global High Wealth initiative), estates, trusts, entities in bankruptcy reorganization, exempt organizations, and retirement plans.
We serve our clients on a broad range of domestic and foreign tax issues, including partnership issues for private equity and hedge funds, transfer pricing and Section 367(d), deductibility of settlement payments and charitable contributions, valuation, economic substance, tax credit qualification, tax accounting, withholding tax, employment taxes, excise taxes, state and local tax issues, Administrative Procedure Act (APA) challenges, and issues arising under the Tax Cuts and Jobs Act and the Inflation Reduction Act.