Perkins Coie tax controversy attorneys have collectively litigated hundreds of cases before the U.S. Tax Court, U.S. District Courts, U.S. Federal Court of Claims and state trial courts, efficiently and favorably resolving tax controversies. In addition, we regularly handle audits and appeals with the IRS and state and local taxing authorities. 

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Overview

Perkins Coie tax controversy attorneys have collectively litigated hundreds of cases before the U.S. Tax Court, U.S. District Courts, U.S. Federal Court of Claims and state trial courts, efficiently and favorably resolving tax controversies. In addition, we regularly handle audits and appeals with the IRS and state and local taxing authorities. 

Distinctive for their depth of prior experience in the government, our tax controversy lawyers include veterans of the IRS Office of Chief Counsel, U.S. Department of Justice, and Offices of the United States Attorney. Our insights into the government’s mindset and practices in tax compliance create an advantage for clients and the dispute resolutions we achieve for them. Areas of counsel include:

Offering a full suite of tax controversy services  that spans both civil and criminal investigations, we offer a proactive approach that addresses such issues as offshore reporting, litigation, collections and state and local tax matters. We defend and advise clients, often raising new issues to strike back and strengthen a client’s position. Our team includes a former Assistant United States Attorney and DOJ trial lawyer with an extensive criminal tax background. 

Areas of Counsel

Federal Tax Litigation

Although clients often look to resolve tax issues without litigation, we understand that situations arise that require a more robust response.

Our tax practice lawyers counsel and defend clients engaged in a variety of complex tax disputes. We have significant experience covering all aspects of IRS controversy work, from audits and appeals to litigation before the U.S. Tax Court, U.S. Department of the Treasury, DOJ and Court of Federal Claims. The depth of our administrative and procedural experience gives us unique insight into the perspectives of the U.S. government, regulatory agencies and courts throughout the United States.

State and Local Tax Controversy

Our state and local tax attorneys have substantial experience advising clients on multistate and constitutional tax issues. We provide guidance on all state and local tax matters, including sales, use, income, gross receipts, property, utility tax, real estate property transfer, and leasehold excise taxes. Although we are able to resolve most state and local tax issues at administrative levels, we have substantial litigation experience in state courts and administrative tribunes in Alaska, California, Oregon and Washington.

Federal Tax Collections

Even after a tax liability has been established, taxpayers still have rights and options as to how to pay and even how much they pay. Our tax controversy attorneys’ extensive experience handling collection matters guides clients through administrative processes that can help create a fresh start for them. When necessary, we can further advocate for clients’ rights before the IRS Office of Appeals and Tax Court, as well as in federal, state and bankruptcy courts.

A powerful part of our background is our attorneys’ advice to IRS Revenue Officers and Insolvency Specialists and DOJ attorneys on an array of collection and bankruptcy matters. Armed with experience litigating and even trying cases in U.S. Tax Court dealing with due process rights of taxpayers, we provide a 360-degree perspective on the collections process to achieve favorable client outcomes. 

Estate and Gift Tax Controversy

Our tax controversy lawyers have a sophisticated understanding of estate and gift tax issues, skilled in the many issues that the IRS may raise. We offer thoughtful, informed counsel that adds value to clients in its consideration of estate and gift tax issues underlying the dispute at hand, rather than simply addressing the dispute itself.

In addition, unlike many law firms, our lawyers have litigated willful Report of Foreign Bank and Financial Accounts (FBAR) penalties in the U.S. District Courts as well as before the IRS Office of Appeals. Our experience also includes managing quiet disclosures, streamlined procedures submissions and the offshore voluntary disclosure program.

Criminal Matters

When the specter of criminal tax allegations arises for clients, we are well positioned to mount a vigorous defense. Our attorneys have experience, including at trial, with claims and investigations involving taxpayers alleged to have failed to file returns, been involved in abusive tax schemes, been connected with abusive return preparers and other claims of fraudulent activity.

Offshore Reporting Issues

Our tax controversy attorneys assist clients with unreported foreign bank accounts, companies and other offshore structures. Our prior experience advising the IRS Offshore Voluntary Disclosure Program, from the IRS side, provides us with particularly effective insights when resolving clients’ tax issues.

Virtual Currencies and Voluntary Disclosure

Our group is led by former IRS and U.S. Department of Justice attorneys experienced in criminal and civil tax matters involving virtual currency. This informs our advice to clients seeking practical guidance and increased certainty. We also have extensive experience in voluntary disclosure of tax matters to the IRS. This is highly relevant for virtual currency holders (or others involved with virtual currency) who intend to correct or amend past filings.

Distinctive for their depth of prior experience in the government, our tax controversy lawyers include veterans of the IRS Office of Chief Counsel, U.S. Department of Justice, and Offices of the United States Attorney. Our insights into the government’s mindset and practices in tax compliance create an advantage for clients and the dispute resolutions we achieve for them. Areas of counsel include:

Offering a full suite of tax controversy services  that spans both civil and criminal investigations, we offer a proactive approach that addresses such issues as offshore reporting, litigation, collections and state and local tax matters. We defend and advise clients, often raising new issues to strike back and strengthen a client’s position. Our team includes a former Assistant United States Attorney and DOJ trial lawyer with an extensive criminal tax background. 

Areas of Counsel

Federal Tax Litigation

Although clients often look to resolve tax issues without litigation, we understand that situations arise that require a more robust response.

Our tax practice lawyers counsel and defend clients engaged in a variety of complex tax disputes. We have significant experience covering all aspects of IRS controversy work, from audits and appeals to litigation before the U.S. Tax Court, U.S. Department of the Treasury, DOJ and Court of Federal Claims. The depth of our administrative and procedural experience gives us unique insight into the perspectives of the U.S. government, regulatory agencies and courts throughout the United States.

State and Local Tax Controversy

Our state and local tax attorneys have substantial experience advising clients on multistate and constitutional tax issues. We provide guidance on all state and local tax matters, including sales, use, income, gross receipts, property, utility tax, real estate property transfer, and leasehold excise taxes. Although we are able to resolve most state and local tax issues at administrative levels, we have substantial litigation experience in state courts and administrative tribunes in Alaska, California, Oregon and Washington.

Federal Tax Collections

Even after a tax liability has been established, taxpayers still have rights and options as to how to pay and even how much they pay. Our tax controversy attorneys’ extensive experience handling collection matters guides clients through administrative processes that can help create a fresh start for them. When necessary, we can further advocate for clients’ rights before the IRS Office of Appeals and Tax Court, as well as in federal, state and bankruptcy courts.

A powerful part of our background is our attorneys’ advice to IRS Revenue Officers and Insolvency Specialists and DOJ attorneys on an array of collection and bankruptcy matters. Armed with experience litigating and even trying cases in U.S. Tax Court dealing with due process rights of taxpayers, we provide a 360-degree perspective on the collections process to achieve favorable client outcomes. 

Estate and Gift Tax Controversy

Our tax controversy lawyers have a sophisticated understanding of estate and gift tax issues, skilled in the many issues that the IRS may raise. We offer thoughtful, informed counsel that adds value to clients in its consideration of estate and gift tax issues underlying the dispute at hand, rather than simply addressing the dispute itself.

In addition, unlike many law firms, our lawyers have litigated willful Report of Foreign Bank and Financial Accounts (FBAR) penalties in the U.S. District Courts as well as before the IRS Office of Appeals. Our experience also includes managing quiet disclosures, streamlined procedures submissions and the offshore voluntary disclosure program.

Criminal Matters

When the specter of criminal tax allegations arises for clients, we are well positioned to mount a vigorous defense. Our attorneys have experience, including at trial, with claims and investigations involving taxpayers alleged to have failed to file returns, been involved in abusive tax schemes, been connected with abusive return preparers and other claims of fraudulent activity.

Offshore Reporting Issues

Our tax controversy attorneys assist clients with unreported foreign bank accounts, companies and other offshore structures. Our prior experience advising the IRS Offshore Voluntary Disclosure Program, from the IRS side, provides us with particularly effective insights when resolving clients’ tax issues.

Virtual Currencies and Voluntary Disclosure

Our group is led by former IRS and U.S. Department of Justice attorneys experienced in criminal and civil tax matters involving virtual currency. This informs our advice to clients seeking practical guidance and increased certainty. We also have extensive experience in voluntary disclosure of tax matters to the IRS. This is highly relevant for virtual currency holders (or others involved with virtual currency) who intend to correct or amend past filings.

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