Tax Controversy and Litigation for Tribal Governments
- Holland & Knight's Tribal Tax Controversy and Litigation Team represents Tribal governments and their enterprises in complex federal and state tax disputes.
- We combine nationally recognized tax controversy experience with deep Tribal law knowledge to help clients navigate IRS audits, tax assessments and penalty notices with confidence.
Overview
Although Tribal governments and their wholly owned businesses are exempt from federal income tax, they remain subject to a range of other tax obligations, including employment and excise taxes, as well as information return reporting and withholding requirements. These rules can be particularly complex when applied to Tribes and their enterprises such as casinos and other Tribally owned businesses.
Our Tribal Tax Controversy and Litigation Team is one of the most active practices in the country. We regularly help Tribal governments and their enterprises in responding to IRS audits, penalty notices and potential liabilities. We advocate for penalty relief and closely monitor ongoing matters to ensure issues are resolved efficiently and cost effectively.
Our attorneys bring experience from the U.S. Department of the Treasury, senior roles at the IRS, clerkships with the U.S. Tax Court and litigation positions at the U.S. Department of Justice's (DOJ) Tax Division and IRS Office of Chief Counsel. Through our consistent success in securing penalty abatements, we have helped Tribes preserve millions of dollars in governmental funds.
Representation
Our Tribal Tax Controversy and Litigation Team works closely with clients to handle matters such as:
- civil penalty disputes and abatement
- employment and excise tax audits and appeals
- information reporting compliance disputes
- IRS disputes and penalty notices involving IRS forms 1099-NEC, 1099-MISC, W-2G, W-2, 940, 941, 945, 1042 and CVL-PEN
- general welfare exclusion matters, including audit readiness and compliance
Our track record reflects our commitment to helping Tribes safeguard financial resources and uphold their sovereign rights.
