Tax Controversy and Compliance

• Advised in connection with potential U.S. tax exposure arising out of matters disclosed in non-tax commercial litigation for clients with international holdings in various investment and business holdings
• Advised in connection with and successfully handled to conclusion numerous income tax examinations at the U.S. federal, state and local levels relating to high-profile executives of large publicly and privately held companies, as well as individuals involved in various aspects of media, sports and entertainment businesses
• Advised in connection with and successfully handled to conclusion a number of tax controversies relating to issues of residence at the U.S. federal and New York State and City levels for high-profile individuals
• Advised in connection with and successfully handled to conclusion voluntary disclosures of off-shore financial accounts and assets with an aggregate value of several hundred million dollars
• Successfully defended against proposed assessments at the federal, state and local levels in relation to matters of significance, including the resolution of numerous matters at the federal appeals as well as local administrative hearing levels involving issues of executive compensation, transfer pricing, entitlement to treaty benefits, deductibility of interest and U.S. withholding tax matters
• Successfully litigated to conclusion, including the affirmation on appeal, the largest reported New York City residency case, which resulted in the incorporation into the law of our arguments concerning the proper standard of proof
• Successfully handled to conclusion a federal income tax audit of closely-held U.S. commercial real estate corporations involving the potential exposure to tax, interest and penalties in excess of US$100 million
• Successfully handled to conclusion U.S. federal and state income tax examinations involving very substantial amounts relating to source and characterization of income from compensatory arrangements, including a joint examination by the IRS and a foreign country
• Handled successfully a refund claim by a nonresident for improperly withheld taxes on deferred compensation paid by a former U.S. employer
• Successfully handled to conclusion a proposed New York assessment in excess of $100 million relating to the potential disallowance of investment interest expense to a large investment partnership
• Successfully handled to conclusion New York income tax examinations of executives of a large and high-profile publicly traded company relating to source of income from the exercise of options issued to key executives
• Successfully handled to conclusion issues of change of domicile raised in tax examinations
• Successfully handled to conclusion a significant New York City refund claim for a corporation owned by a high-profile recording artist relating to taxes that a careful reading of the underlying agreements indicated were paid erroneously
• Provided advice in connection with and assisted non-U.S. counsel in the planning for, filing and litigation of the ultimately successful claims for refund of very substantial non-U.S. taxes of high profile clients
• Advised a high-net-worth individual with sizable offshore investment interests regarding potential exposure in respect of non-filing of numerous information returns
• Advised a large financial institution concerning its potential exposure for non-payment of required U.S. tax withholding by its borrowers
• Advised a publicly-traded company regarding internal investigation relating to certain tax compliance matters
• Assisted clients in obtaining closing agreements and offers-in-compromise resulting in reduction of and payment terms for significant outstanding tax liabilities
• Advised and consulted in a New York estate tax examination of a high-visibility New York City resident decedent
• Advised regarding a claim for innocent spouse relief in respect of joint tax returns filed by the other spouse under criminal investigation
• Advised fiduciaries and individuals regarding potential exposure for gift and estate taxes under transferee liability provisions, federal priority statute and special lien provisions
• Advised and assisted in the filing of a petition to quash IRS summons issued pursuant to treaty partner assistance request for third-party financial documentation