Acting for multinational companies and HNW individuals, Baker McKenzie LLP is sought after for advice on the full spectrum of tax controversy matters, including appeals, audits, and litigation, with the firm praised as ‘an excellent tax firm, especially for transfer pricing‘. George Clarke in Washington DC leads the firm’s North America tax controversy sub-practice, drawing on his vast experience in both civil and criminal tax litigation matters. Also in DC are IRS litigation expert Duane Webber and transfer pricing specialist Salim Rahim. Scott Frewing in Palo Alto handles complex civil and criminal  matters, as well as financial investigations. In Chicago, Mark Oates is a key adviser on highly technical matters, including tax treaty interpretation, foreign tax credits, and issues arising from M&A. In New York, Maria Eberle chairs the SALT sub-practice group, and senior counsel Daniel Rosen draws on deep experience with the IRS to advise on regulatory issues. Newly promoted partner Cameron Reilly in Chicago and Robert Albaral in Dallas are also key names in team.

DLA Piper LLP (US) sees continued expansion in the breadth of its tax controversy offering, with the team active in all aspects of sophisticated, challenging tax disputes, at the international, federal, state, and local levels. The firm has a strong SALT capability, headed up by Naftali Dembitzer and David Pope in New York, along with Hugh Goodwin in Palo Alto. The broader tax practice is led from New York office by Diana Erbsen and Ellis Reemer, who both have experience in senior leadership positions in the DOJ’s Tax Division and the IRS Advisory Council, as well as in the IRS Office of Chief Counsel. Henry Cheng in San Francisco is a prominent tax litigator, with recent work encompassing a complex bankruptcy dispute for medical technology company UpHealth Holdings, a significant Tax Court win concerning death benefit proceeds from life insurance policies, and a major cross-border transfer pricing dispute. Victoria Gu in Palo Alto is also a key contributor to the practice. In 2024, the firm hired transfer pricing expert Steve Dixon in Washington DC from Steptoe LLP.

Eversheds Sutherland has a broad tax controversy practice that encompasses civil, criminal, and administrative matters, though it is particularly well-regarded for its work on state and local tax matters. The work also has a broad sector focus, spanning the technology, media and entertainment, energy and natural resources, healthcare and life sciences industries, among others. Robert Chase  and Mary Monahan, who both handle complex and technical federal tax issues for multinational corporations, lead the tax practice from Washington DC. Jeffrey Friedman, also based in DC, is a recognised expert in SALT matters. Eric Tresh in Atlanta is a key adviser to both national and global companies on SALT matters, and he is active in administrative and judicial fora throughout the US. DC-based Dwight Mersereau recently acted for pharmacy benefit organization Express Scripts, Inc. in a significant case concerning the application of former Section 199 to domestically produced software. In the same office, David Blair and David Fischer are respected for their work at both federal and state level. In early 2025, the firm hired a group from Chamberlain Hrdlicka, including partners Hale Sheppard, Cassandra Bradford, and Samuel Grier.

The Washington DC office of Latham & Watkins LLP is home to its ‘competent and creative’ tax controversy practice. The firm continues to build on its impressive track record of success in litigation in the Tax Court, the Court of Federal Claims, District Courts, Courts of Appeal, the US Supreme Court, and state courts, and continues to new precedents. In a high-profile case following the Supreme Court’s landmark decision in Loper Bright Enterprises v. Raimondo, which enables courts to challenge regulations, the firm successfully challenged federal rules issued in the wake of 2017 tax reform concerning how US domestic corporations are taxed on income related to controlled foreign corporations, a matter led by Jean Pawlow. Miriam Fisher, who chairs the global tax controversy practice, recently acted for Occidental Petroleum in a Tax Court matter concerning the largest environmental remediation settlement in history. Brian McManus, who is also chair of the Boston tax team, focuses his DC practice on controversy matters with broader national tax policy implications. Joshua Wu and Andrew Strelka are also key practitioners.

Mayer Brown has a dedicated tax controversy and litigation team that consists entirely of tax specialists. This level of in-depth expertise sees the firm involved in cutting-edge cases, ongoing examples of which include achieving the first taxpayer win under New York’s new manufacturer tax incentive for E. & J. Gallo Winery. Leah Robinson in New York, who leads the increasingly active SALT practice, led on that matter. The practice has four outstanding leaders, namely Brian Kittle in New York, Thomas Kittle-Kamp and Joel Williamson in Chicago, and Gary Wilcox in  Washington DC. Kittle-Kamp, whose recent work spans major cases involving transfer pricing, partnership and corporate transactions, is currently acting for Abbott Labs before the US Tax Court in a challenge to regulations implementing the global intangible low-tax income (GILTI) rules. Williamson’s track record includes the trial of seven major transfer pricing cases. Kittle recently won an issue of first impression concerning an IRS substance-over-form and step-transaction challenge. In Chicago, John Hildy is lauded for his work on federal tax disputes for multi-national corporations, and Jenny Austin has a broad practice that encompasses transfer pricing and other international issues.

Skadden, Arps, Slate, Meagher & Flom LLP has a large global tax group, led by Victor Hollender in New York and Emily Lam in Palo Alto, that thrives in high-stakes, complex and tax disputes, whether domestic or cross-border. Its work in audits, administrative appeals, Tax Court and district court litigation, and international matters cuts across the whole spectrum of issues, from transfer pricing matters to SALT cases. Raj Madan, who is regarded by one peer as ‘the country’s lead tax litigator‘, and Christopher Bowers are the key partners in Washington DC, where the hub of the practice resides. Madan, along with up-and-coming partner Royce Tidwell, Nathaniel Carden, and Palo Alto-based Christopher Murphy handled a multibillion-dollar transfer pricing matter for Amgen Inc., which concerned the licensing of complex biopharmaceutical products from to a Puerto Rican subsidiary. New Chicago-based partner Jonathan Welbel, who joined from Baker McKenzie LLP in 2024, has extensive experience in tax controversy, transfer pricing and a range of other international tax issues, and also played a key role in the Amgen case.  Juliana Hunter in Houston is also highly recommended.

Based predominantly in Washington DC, the tax controversies practice at Caplin & Drysdale, Chartered ‘has some of the premier practitioners in criminal tax defense’. Scott Michel, who has great experience in representing high-net-worth and internationally prominent individual and corporate clients in criminal and civil tax controversies, and Charles Ruchelman , who has notable expertise in the taxation of captive insurance arrangements, are the lead partners. In the same DC office, Niles Elber is a standout partner for both civil and criminal tax matters, where his work includes administrative and grand jury tax investigations. Michel and Mark Matthews, who focuses on cases involving undisclosed foreign bank accounts and unreported foreign assets, are ‘top-tier in civil and criminal tax matters’. They recently assisted one of the country’s wealthiest individuals in concluding a criminal tax investigation by the  Mark Allison is the key contact in New York, where he acts for multi-national corporations, financial institutions, sovereign wealth funds, global high-net-worth individuals, family offices and professional athletes and entertainers. Christopher Rizek has left the firm.

Chamberlain Hrdlicka is best known for its work on contentious federal tax matters, whether criminal or civil,  not least because many partners have in-house experience at the IRS, though it is able to handle all kinds of local, regional and national work. Philip Karter in Philadelphia is chair of the practice, which is home to a deep bench of tax controversy specialists. David Aughtry in Atlanta, ‘who would be on the Mount Rushmore of tax litigators’, and Larry Campagna in Houston, who has ‘substantial experience in criminal tax investigations and in tax shelter matters’, are standout practitioners. Also in Atlanta, John Hackney works closely with Aughtry, frequently second-chairing litigation matters, and Tom Cullinan brings experience from his time as counselor to the IRS Commissioner. Jaime Vasquez in San Antonio handles federal, state, and international matters, and Patrick Martin has an active cross-border practice. Charles Rettig, who served as Commissioner of the IRS from 2018 through 2022, is a new hire in LA.

Gibson, Dunn & Crutcher LLP has an impressive roster of multinational corporate clients that includes The Coca-Cola Company and 3M, and also acts for prominent privately held companies, investment funds, partnerships, sovereign wealth funds, and high-net-worth individuals. Washington DC-based Sanford Stark leads the practice. Also in DC, Saul Mezei is a specialist in federal tax controversy matters, notably international transfer pricing and research credits cases, as well as issues concerning accounting methods and employment taxes. Emerging partner talent Terrell Ussing focuses on federal tax matters concerning valuation, transfer pricing, and other complex domestic and international tax issues. Michael Desmond departed the team in February 2025.

The ‘stellar team’ at Kostelanetz LLP is best known for its work in criminal matters, as well as handling the full range of tax controversy issues for high-net-worth clients. Caroline Ciraolo in Washington DC, who ‘leaves no stone unturned in attempting to achieve the best possible results’, and Megan Brackney in New York who is a leading partner. In New York, Bryan Skarlatos has huge experience in tax controversy and exhibits ‘great judgment in civil and criminal matters’. He recently worked with Brackney on a $50m bankruptcy-related audit. Litigators Christopher Ferguson and Michael Sardar, who also handle white-collar criminal defense, are other key names to note in New York. The firm recently joined the Atlanta market, having joined forces with the key partners from Todd Welty. P.C.. Todd Welty, who is ‘among the best in the conservation easement space’, and Andrew Steigleder are the most notable additions.

Based in Washington DC, Miller & Chevalier Chartered is involved in the full spectrum of tax controversy matters from transfer pricing and partnership cases to audits and IRS appeals. Acting for major corporates, among them ExxonMobil and United Airlines, the firm is able to handle the most complex domestic and international matters.  The firm’s long heritage is a vital part of its market proposition, as it enables it to call on solid relationships with federal agencies, and to play an active role in industry bodies. Experienced litigator Kevin Kenworthy and tax accounting specialist George Hani are the lead partners. James Gadwood acts as outside tax counsel to corporations in divers sectors, among them automotive, aerospace, energy, and hospitality. Lisandra Ortiz frequently handles audits before the IRS Independent Office of Appeals. New recruit Brian Gleicher, who joined from White & Case LLP, has.a broad practice that encompasses transfer pricing matters and advance pricing agreements.

In Akerman LLP‘s tax practice, the SALT group is the largest component, and it handles complex tax controversy cases nationwide, be they administrative appeals or trials. It frequently handles cases for well-known corporates, among them Skechers and PetMeds, that address novel tax issues  and matters of first impression. Alongside state and local matters – where its network of offices across the US proves to be a key differentiator – the firm is increasingly involved in contentious tax matters at federal level, including recent cases in the aviation and healthcare sectors. Peter Larsen in Jacksonville and David Blum in Chicago are co-chairs of the tax practice. Stefi George in New York leads the SALT practice, which is active nationwide. Michael Bowen in Jacksonville and Lorie Fale in Miami are mainstays of the firm’s tax litigation practice in Florida. Bowen recently acted for Skechers in a case concerning $500m in deductions claimed by the company.

At Baker Botts L.L.P., the SALT team is ‘exceptionally knowledgeable, influential and caters to their clients needs’, praised for the ‘insight, professionalism, flexibility, availability, and thoroughly crafted and well thought-out legal advice’ provided by the tax group led by Stephen Marcus in Dallas. Best known for its work in the energy, techn and financial service industries, the firm is also highly regarded for its estate and gift tax controversy practice, which is sought after by high-net-worth individuals across the US. Keri Brown, Renn Neilson, and John Porter are the key names in Houston. Neilson recently acted for Cheniere Energy, Inc. in matters arising from a sales tax audit of Corpus Christi Liquefaction LLC, which had constructed a large LNG processing plant. Brown and Porter are frequently involved in high-value private client matters, alongside Jon Feldhammer in San Francisco, who also handles high-value real estate tax audits and energy infrastructure matters.

Davis Polk & Wardwell LLP has aclient roster that includes corporate giants across diverse industry sectors, among them Citigroup, Comcast, JPMorgan, and Pfizer. The tax practice handles advisory and contentious work ranging from partnership taxation, and contentious international  matters, to interest capitalization and allocation, withholding taxes, and foreign tax credit issues. It is actively involved in complex transfer pricing cases with values multibillion-dollar sums at stake, and it has an outstanding track record of success before federal and state courts, as well as matters handled at administrative level. Head of the tax group Mario Verdolini handles administrative proceedings and settlements, trials, and appeals, as well as advising on risk management issues. Christopher Baratta frequently assists domestic and foreign clients in the financial services, securities, manufacturing, media, software, and pharmaceutical sectors. Together, they advised multiple clients on potential refund claims based on the Tax Court’s ruling in the Varian case, which invalidated a regulation.

Holland & Knight LLP continues to build its tax controversy and litigation practice, which has a strong focus on the energy sector, but also handles complex in many other industries. Its recent success for Exxon Mobil in a proceedings brought by the IRS in the wake of of the company’s restructuring of its partnership with the state of Qatar is a prime example of its ability to handle complex matters, but so is its work for major airlines, technology companies, high-net-worth individuals, and real estate developers. Mary McNulty in Dallas, who led the Exxon case, and Atlanta-based William Sharp, who is frequently lead counsel in offshore compliance matters,  are the lead partners. Up-and-coming partner Lee Meyercord in Dallas and energy sector specialist Amish Shah in Washington DC also play pivotal roles in the practice. Also in DC, Christopher Rizek joined from Caplin & Drysdale, Chartered, where he co-led the tax controversy practice.

Norton Rose Fulbright frequently handles cross-border contentious tax matters, as well as a range of high-value domestic work, not least because of its strong ties with global players in the energy sector. As well as handling, multi-jurisdictional competent authority disputes, audits, IRS appeals, summons enforcement, and SALT disputes, the firm is also involved in transfer pricing matters, and cases involving foreign tax credits. Robert Morris in Houston and William Cavanagh in New York lead the firm’s US tax practice. The main locus of the tax controversy team is in Houston, where the firm’s most senior tax practitioner Charles Hall and controversy specialist Jasper Taylor both have extensive experience in complex court cases, and Stephen Kuntz focuses on matters transactions involving corporations, partnerships and limited liability companies.

Steptoe LLP continues to be involved in precedent-setting matters, the most notable recent example being its work for American Tax Policy Institute in filing an amicus brief in support of the government in Moore v. United States. Lawrence Hill, in New York who has a long track record of success in both civil and criminal tax matters, was the key lawyer involved. New York is also home to head of tax and private client Beth Tractenberg. Former practice co-head Phil West continues to assist multinationals and high-net-worth individuals on international tax issues from the Washinton DC office. Also in DC, Amanda Pedvin Varma and associate Caitlin Tharp are active in international and federal matters respectively. Transfer pricing specialist Steve Dixonand Elinor Ramey have left the firm.

At Vinson & Elkins LLP, ‘the team’s professionalism, knowledge in the subject matter, and experience in litigation is what sets them apart’. Adept in trials and appeals, the firm is frequently involved in high-value matters both domestically and internationally. George Gerachis  in Houston and Kathy Pakenham in Dallas co-lead the tax controversy practice, which sits within the broader tax practice group led by Houston-based Ryan Carney. Pakenham and New York-based standout partner Adriana Wirtz are ‘the most capable, most ethical tax controversy lawyers in the country’, and one client believes that Wirtz is ‘the gold standard for resolving high-stakes tax controversies quickly and effectively’. Gerachis and Pakenham recently assisted Halliburton with a $32m federal income tax refund case against the IRS involving the deductibility of a payment made to a foreign government. As as its core focus on energy, the practice also handles matters in the financial services, technology, health care, and real estate industries.

Based in Atlanta, Asbury Gardner has a group of tax litigation specialists who are frequently called upon by other law firms and big accounting firms when complex cases cannot be resolved at the administrative level. ‘Highly organized, very responsive, and fierce’, the practice led by Anson Asbury and Brian Gardner is ‘the best in the business’, according to one client. The firm handles a broad scope of work, though niche areas such as conservation easements are strong areas of expertise. Mark Mesler focuses on corporate tax examinations and appeals. Ethan Vernon frequently acts for taxpayers in IRS examinations and appeals.

The tax controversy practice at BakerHostetler has substantial capacity and experience, which leads it to be involved in some groundbreaking matters. A prime example is its work in Moore v. United States, which challenges the Mandatory Repatriation Tax imposed by the 2017 Tax Cuts and Jobs Act. Tax group chair Jeffrey Paravano in Washington DC led that matter. He co-leads the tax controversy and litigation group with Michelle Hervey in Cleveland, and Elizabeth Smith in New York, who has notable experience in the hedge fund industry and in New York state residency and domicile audits and cases. Other key names include DC-based veteran tax expert Paul Schmidt, and Nicholas Mowbray, who handles matters involving international tax, and the taxation of financial products. Tax litigator David Ebersole in Columbus is an emerging talent.

Whether acting for private individuals or multinational companies, Dentons is adept in all phases of tax controversy against the IRS, as well as state and local tax authorities. Indeed, it handles SALT disputes for some of the largest companies in the US. A recent example is a complex matter in Salt Lake County for Delta Airlines. The practice is led by Mark Loyd in Louisville, who has extensive experience at both state and federal level, and Gregory Rhodes in Birmingham, who has an extensive track record of acting as first-chair trial attorney in high-stakes federal and local tax litigation. Michelle Levin in Huntsville is sought after for advice on IRS audits, administrative appeals, and court proceedings. Ronald Levitt in Birmingham leads the firm’s conservation easement team.

Clients note that Jones Day has ‘decades of experience in state and local tax controversy’, though it is also highly active at federal level in criminal and civil matters. Kathryn Keneally in New York takes point on tax controversy matters. A former Assistant Attorney General for the Department of Justice Tax Division, she is currently handling a case described by the government as the largest tax case ever brought against an individual. Keneally was recently joined in the New York office by Justin Campolieta, who brings great experience as an IRS trial attorney. Charles Hodges, a prominent adviser on federal tax controversy at all administrative and judicial levels, and John Allan, who has ‘unsurpassed knowledge of issues and state policymaker players’, are the key contacts in Atlanta.

Pillsbury Winthrop Shaw Pittman LLP‘s SALT practice is ‘very knowledgable, commercial and easy to work with, and always delivers top-tier value’. The global tax practice led by Nora Burke in New York has an outstanding SALT controversy expert in Sacramento-based Carley Roberts, who is ‘at the absolute top of her field’. Craig Becker in Palo Alto is ‘one of the premier experts in his specialty’. In New York, the firm hired Larry Sannicandro from McCarter & English, LLP, who ‘brings significant strength, where previously the firm has flown under the radar’. His expertise in tax controversy and private wealth, and his role as a member of the IRS Advisory Counsel, add significant depth to the team. San Francisco-based Jeffrey Vesely also plays a key role in SALT matters.

Sidley Austin LLP is a go-to adviser for contentious matters concerning research credits, for example, and also handles transfer pricing issues, litigation, administrative appeals before the IRS, and a range of federal, state and local tax matters for a select group of blue-chip clients. In Washington DC, tax controversy practice head Matthew Lerner and key partner Nathan Clukey are the main contacts. Richard Leavy is the key partner in New York  handles all aspects of state and local taxation, with a notable emphasis on tax controversies. Lerner recently assisted a major US rail company on complex matters concerning its entitlement to interest netting.

White & Case LLP draws on its extensive international network to handle high-value cross-border matter, as well as maintaining a prominent presence in the domestic tax controversy arena. Acting for multinational corporations, financial institutions, investment funds, ultra-high net worth individuals, governments, and sovereign wealth funds, the firm is noted for its expertise in transfer pricing matters, as well as a host of civil and criminal tax investigations. Kim Marie Boylan leads tax controversy practice from Washington DC, where Sean Lyons plays a key role. Brian Gleicher has left the firm.

Based in New York, the tax controversy practice at Blank Rome LLP has a highly experienced partner group focused on SALT matters. Its work spans everything from corporate franchise and income tax, to sales and use tax, personal income tax, and excise tax. The team led by Craig Fields is frequently called upon to advise on the tax implications of complex corporate transactions and reorganizations for a client roster that ranges from Fortune 50 companies to small family-owned businesses and individuals. Up-and coming partner Nicole Johnson, who recently handled an $11m case for DuPont, is among the firm’s ‘very knowledgeable attorneys with expertise in multiple jurisdictions’.

Fenwick & West LLP is a key adviser on tax controversy matters in the life sciences and techn sectors, drawing on the firm’s broader expertise in this industries, as well as its highly regarded tax planning practice. Larissa Neumann leads the team from Silicon Valley, where Will Skinner and David Forst are among the standout practitioners. Neumann frequently acts for leading cosmetics company Estée Lauder in complex matters, including transfer pricing cases. Adam Gahtan in New York has a background in high-stakes patent litigation in the pharma industry, which informs his tax controversy work with experience in complex regulations and valuation issues.

Greenberg Traurig has a large global tax practice that has significant expertise in contentious matters, not least through New York-bsed chair of the tax controversy and litigation group Barbara Kaplan. Bradley Marsh, who leads the SALT practice, and Michelle Ferreira, a former tax litigator for the IRS, are the key contacts in San Francisco. Ferreira counsels individuals, partnerships, estates and corporations in disputes with the Internal Revenue Service and state and local agencies. Marsh handles the full range of state and local tax matters, including payroll, property, business license, employment, franchise, and estate taxes. Scott Fink in New York and Jared Dwyer in Miami handle civil and criminal tax controversies.

Moore Tax Law Group is particularly adept in criminal matters, and also handles a range of civil matters, its work for companies and individual clients encompassing technical corporate and partnership issues, foreign tax compliance, and high-net-worth audit and penalty matters. The ‘hardworking and smart, but also kind and empathetic’ Guinevere Moore in Chicago is the key partner. The Chicago office is also home to tax litigation and white-collar crime specialist Ajay Gupta and Shay-Ann Heiser Singh, who is frequently involved in civil and criminal tax controversies before the IRS. Zhanna Ziering has left the firm.

The Boston office of Sullivan & Worcester LLP is best known for its work in contentious matters at local state level, with work for premier clients such as Lumen Technologies and Medtronic encompasses a growing stream matters at federal level. Richard Jones is the standout partner and a key adviser on SALT litigation and transactional planning. Vastly experienced tax specialist David Nagle handles disputes with the Massachusetts Department of Revenue and the IRS, while Daniel Ryan handles federal and state tax litigation as part of a broader tax advisory practice. Caroline Kupiec is active at all levels of the audit, controversy, and litigation process.