TAX CONTROVERSY 360
TAX CONTROVERSY 360
McDermott’s Real-Time Tax Disputes Insights
TAX CONTROVERSY 360
McDermott’s Real-Time Tax Disputes Insights
tax controversy
Subscribe to tax controversy's Posts

New Resource Center: Navigating Change in the US Administration

by | Mar 19, 2021 | , ,

Pandemic relief, taxes, income inequality, climate change, infrastructure, healthcare and civil rights: the new US administration is moving forward rapidly on President Joe Biden’s stated priorities. So how are these new policies affecting your business? We’re here to keep you informed!

McDermott Will & Emery’s multidisciplinary team of industry-leading lawyers are monitoring key legal areas to help you navigate and gain perspective on the most critical impacts of changing US policies. Access the latest updates in our new resource center.



read more

Tax Planning in a World of Increased Transparency

by | Jan 3, 2018 | , ,

Multinational Enterprises (MNEs) are facing an evolving international tax landscape with long-term implications for tax compliance, planning and controversy. Understanding these changes requires continual effort. Tax Executives Institute recently invited us to explore Country-by-Country (CbC) reporting issues at the 2017 Global Tax Symposium in Houston, Texas. We had a lively discussion and know this will be a hot topic as jurisdictions begin reviewing the CbC reports.

As background, the Organisation for Economic Co-operation and Development’s (OECD) Base Erosion and Profit Shifting (BEPS) project has been a key driver of international tax reform.  BEPS “Action 13” outlined a CbC reporting standard that has been adopted in more than 55 jurisdictions. The CbC report is an annual filing obligation identifying, among other things, the amount of revenue, profit before income tax, and income tax paid and accrued for each tax jurisdiction in which the taxpayer does business. The resulting transparency directly affects global tax strategies since the CbC report is subject to automatic exchange provisions and more than 1,000 such relationships have been established worldwide. Tax authorities will be using this information to perform tax risk assessments so taxpayers need heightened sensitivity to the breadth and depth of information available through the CbC report. If you are involved in the process of preparing a CbC report, discussing the CbC report with a tax authority, or are otherwise interested in how the CbC report could be used by a tax authority, the OECD’s Handbook on Effective Tax Risk Assessment is a valuable resource.

(more…)



read more

McDermott Continues to Receive Top Rankings in Tax in Chambers USA 2017

by | Jun 2, 2017 |

Chambers USA, which releases an annual listing of rankings of law firms and attorneys in various practice areas, has released its 2017 edition. We are honored that Chambers USA has recognized McDermott’s tax practice and several of its attorneys in the latest rankings. A summary of McDermott’s tax rankings is listed below along with a complete list available here to all McDermott rankings.

In the nationwide rankings for Tax Controversy, we maintained our Band 2 ranking. In the state rankings for Tax, we are ranked in Band 1 for Illinois, Band 2 for Washington, DC and Band 3 for Texas.

On the tax controversy side, our team was recognized as known for a “Dominant presence in high-value tax disputes across the USA, fielding particular expertise in transfer pricing litigation and SALT work.” Clients gave us “10 out of 10 for client service,” and added: “They are great at investing in and building a long-term relationship.”  Particularly noted is the value for money we provide.  Clients agreed that they get good value from us: “It’s outstanding client service and worth every penny. Billing has been very detailed and understandable.”

Several of our tax controversy attorneys were recognized by Chambers USA on the nationwide and state levels:

Chair of the firm’s tax controversy practice Todd Welty maintains an excellent reputation in the market for his tax controversy and litigation expertise. One impressed source comments: “His knowledge and trial expertise was phenomenal.” His impressive list of clients includes multinationals and Fortune 100 companies.

“I have the utmost respect for Roger Jones’s litigation and controversy skills,” states one interviewee. His expert litigation practice sees him frequently act for major corporations at all levels of the federal court system.

Jean Pawlow regularly advises financial institutions on complex tax controversy matters. Observers indicate: “Her practice is very deep and diverse, and her clients benefit from that.”

Andrew Roberson comes recommended as an “excellent tax controversy lawyer who has great instincts, is extremely personable and offers really good client skills.” His strong litigation practice is complemented by additional experience in resolving tax disputes in ADR proceedings.

Thomas Borders is a “great and experienced trial lawyer,” according to interviewees. He draws on his experience as a former IRS attorney to act on the full range of federal tax controversy matters, including defending against criminal investigations.



read more

Todd Welty Named ‘MVP of the Year’ for Tax Law

by | Dec 2, 2016 |

McDermott is proud to announce that Todd Welty has been chosen by Law360 as a 2016 “MVP of the Year” in the category of tax law. Mr. Welty’s selection is part of a Law360 series profiling lawyers who have made the most significant contributions in their areas of practice.

This is Mr. Welty’s second time winning this prestigious award, as he was previously selected as an MVP in 2014. Mr. Welty was one of only five lawyers selected in the tax category, and one of only 177 lawyers selected throughout all practice areas nationwide. His outstanding achievements in this area of law were featured in an individual profile published on December 1, 2016.

Mr. Welty was praised by Law360 for his exceptional tax controversy and litigation work.  In his role as co-chair of McDermott’s Tax Controversy practice, he has the ability to tap an extensive pool of talent, enabling him to assemble second-to-none teams of tax controversy and technical tax professionals. Mr. Welty is well known for his track record of winning difficult cases and his strategic resolution of high-stakes tax matters.

Read the full coverage of Todd Welty in Law360.



read more

Tax Controversy Options

by | Oct 11, 2016 | , , , , , , ,

Knowing your options for a US Federal tax controversy is helpful in creating a sound and efficient strategy. The attached chart depicts the typical options involved in a US Federal tax controversy, from the IRS’s examination of the return, through administrative appeals, litigation in Tax Court, Circuit Court appeal, and to ultimate assessment of tax.



read more

BLOG EDITORS

Kevin Spencer

Evan Walters

STAY CONNECTED

Subscribe

TOPICS

ARCHIVES

jd supra readers choice top firm 2023 badge