DLA Piper Global Law Firm
Tax Controversy and Disputes
Tax Controversy and Disputes
Representation of a large national accounting firm in a federal grand jury investigation and promoter penalty audit relating to the development, marketing and reporting of tax shelter transactions; negotiated a US$50 million Deferred Prosecution Agreement and an IRS Closing Agreement to resolve both and assisted in the creation of a compliance and ethics plan meeting the requirements of the US sentencing guidelines
Advising and representing a German bank and its subsidiaries in connection with an official investigation regarding possible intentional evasion of VAT
Representation of numerous US based multinational clients in connection with federal income tax audits addressing transfer pricing, R&D credits, withholding taxes, Subpart F income, and various other issues.
Advising various clients in connection with IRS audits of losses arising from partially worthless debt claims and wholly worthless stock claims.
Represented wireless phone companies in California tax litigation holding that certain taxes imposed on their customers were illegal and therefore need not be collected by the companies.
Obtained numerous Advance Pricing Agreements for multinational companies doing business in the United States.
Assisted numerous clients (high-net-worth individuals, estates and financial institutions) in becoming compliant with US (and state) tax laws through voluntary disclosure initiatives relating to previously undisclosed foreign financial accounts; also represented clients in civil tax audits and criminal tax investigations relating to undisclosed foreign financial accounts and transactions
Advising and representing members of the management board of an international electronic group in connection with tax proceedings regarding the international taxation of stock options
Represented an internationally known auction house in an IRS audit with respect to the tax treatment of guarantee payments made in connection with obtaining art work for auctions
Represented a multinational corporation in IRS audit and IRS appeal with respect to the tax consequences of a reorganization, liquidation and gain recognition agreement, including the characterization and valuation of intangible assets under IRC Section 936
Advising and representing a Dutch pension fund in proceedings regarding refund of capital gains tax on foreign payments of dividends
Represented a public water utility in reversing a determination by the New York State Department of Taxation and Finance that the purchase of electricity by the utility for use in powering pumps that create water pressure was subject to sales and/or use tax, by establishing that water pressure was utilized in the "production" of a public water supply, as opposed to in its "distribution"
Advising and representing tourism companies in connection with model proceedings regarding energy taxes before the Austrian Constitutional Court
Advising a significant number of financial institutions in relation to one of the most invasive and extraterritorial legislation to be passed by the US in living memory, FATCA