Tax Controversy and Litigation

Holland & Knight's Tax Controversy and Litigation attorneys represent businesses, individuals and organizations in IRS audits, tax disputes and litigation at all levels, including U.S. Tax Court, federal courts, and state and local tax agencies.

We understand how stressful and complex tax issues can be. Whether you're facing an IRS examination, DOJ tax investigation or tax penalties, our team delivers strategic, results-driven representation to protect your interests and resolve disputes efficiently.

Our attorneys:

• provide early legal counsel on IRS audits that can prevent escalation and protect your rights during the audit process
• have extensive experience guiding clients in U.S. Tax Court litigation that allows taxpayers to challenge IRS determinations without first paying the disputed amount
• deliver insightful, agile defenses of clients facing criminal investigations – including allegations of tax fraud or evasion

In each instance, our lawyers stand alongside our clients to provide tailored guidance designed to solve your toughest problems, with the ultimate goal of providing peace of mind and achieving the best possible outcome.

What We Do

Our Tax Controversy and Litigation Practice helps clients navigate:

• IRS audit defense and IRS appeals, including
  • complex large business and international (LB&I) audits and appeals
  • partnership (Bipartisan Budget Act) audits and appeals
  • employee retention credit audits and appeals
  • transfer pricing and competent authority proceedings
  • collection due process hearings
• federal tax disputes, including
  • Tax Court litigation
  • tax refund suits and other civil tax litigation
  • civil and criminal tax penalties defense.
• state and local tax (SALT) controversy disputes before state agencies and state courts
• international tax issues, including
  • report of Foreign Bank and Financial Accounts (FBAR)
  • Foreign Account Tax Compliance Act (FATCA)
  • Foreign Investment in Real Property Tax Act (FIRPTA) compliance matters
• energy tax controversies
• executive compensation and employee benefits disputes

Who We Represent

Many of our cases have gained national attention due to their significant impact for our clients and taxpayers in general. Our team has a long history of successfully advocating for:

• public and private companies
• partnerships and joint ventures
• tax-exempt organizations, nonprofits and foundations
• estates and trusts
• Native American Tribes
• financial institutions
• energy and minerals sectors, including petroleum, hard minerals and natural resources companies

Leading Lawyers in Tax Controversy and Litigation

Holland & Knight is consistently ranked among the top tax controversy law firms in the U.S. Our tax controversy and litigation attorneys are recognized leaders in resolving complex tax disputes, defending clients in IRS audits and appeals, as well as representing them in Tax Court and federal litigation.

We have earned national recognition from leading legal publications, reflecting our deep experience, strategic insight and successful outcomes across civil and criminal tax matters.