Tax Controversy and Litigation
Attorneys in Holland & Knight's Tax Controversy and Litigation Practice have more than a half-century of experience representing businesses and individuals in tax disputes at the federal, state and local levels.
Our attorneys have served in significant leadership and field-level positions in the private sector and government, including the U.S. Department of the Treasury, IRS and U.S. Department of Justice.
We help resolve disputes both administratively and in litigation. When litigation is determined to be in our client's best interest, we are forceful advocates and will vigorously defend our client.
We have extensive trial experience litigating tax disputes for major public companies, privately held companies, partnerships, private foundations, tax-exempt organizations, estates and trusts, and Native American tribes.
We have a long history of advising and representing clients in tax audits and disputes before national and local offices of the IRS, before state and local tax agencies and appeal divisions, and in state and federal courts. Our cases often address complex and novel tax issues that set precedent and decide important industry issues. Our cases involve:
major petroleum industry issues
precedent-setting estate tax valuations
partnership taxation
international transfer pricing
foreign tax credits
Report of Foreign Bank and Financial Accounts (FBAR)
Foreign Account Tax Compliance Act (FATCA) and international tax issues
Foreign Investment in Real Property Tax Act (FIRPTA) compliance matters
tax- exempt disputes
collection due process disputes
Employee Retirement Security Income Act of 1974 (ERISA) and other employee benefits/executive compensation matters
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valuation issues
domestic and foreign reorganizations of corporations and financial institutions
penalty and interest issues
Many of our cases have gained national attention due to their significant impact both for our clients and for taxpayers in general. As part of Holland & Knight's preeminent energy industry practice, our team has a long history of successfully representing petroleum, hard minerals and natural resources clients.
Holland & Knight is consistently ranked as one of the top tax law firms in the United States. As evidenced by numerous rankings and awards, media mentions and leadership positions, our tax controversy and litigation attorneys are recognized leaders and authorities in the field. We have been recognized and ranked in U.S. News – Best Lawyers® "Best Law Firms," Chambers USA, The Best Lawyers in America® and The Legal 500 United States, among others.
Our backgrounds include invaluable experience as senior executives in the IRS Office of Chief Counsel, the U.S. Attorney's Office and the U.S. Department of Justice's Tax Division. We regularly team up with our trial attorneys in cases litigated in federal district courts and appellate courts