At Thompson Coburn, we understand that tax controversies can be daunting. From pre-audit planning through final appeals, our seasoned team advocates for you at every stage. We have represented thousands of clients before the IRS and state and local taxing authorities, protecting their interests and achieving favorable outcomes.
Our comprehensive services cover audits and appeals, competent authority matters, and trial and appellate litigation. As your dedicated advocates and trusted advisors, we are committed to providing innovative and pragmatic solutions to tax controversy issues, including franchise, income, sales and use, gross receipts, nexus and apportionment issues, earnings, business license, utility, property, and other local tax matters.
State and Local Tax (SALT) Controversy
We work with a diverse range of clients, from Fortune 500 companies and regional entities to small businesses, individuals, organizations, and startups across multiple industries. Whether you are facing an audit, assessment, agency review, legal action, or class action litigation, we can help develop a sophisticated tax controversy strategy tailored to your business practices and expectations. If settlement is not an option, our accomplished trial advocates leverage extensive experience and cross-practice resources to see your case through to the highest court, agency, or tribunal. When appropriate, we also offer legislative and governmental solutions.
Our team includes former government counsel, court clerks, tax professors, accountants, and even a former Director of the Missouri Department of Revenue. Our members frequently contribute to tax publications, present at local, regional, and national tax symposiums or conferences, and lead professional tax organizations and business-focused groups.
With our deep knowledge, extensive experience, and unwavering commitment to the field, our team has a proven track record of securing favorable outcomes for clients before state government agencies, public offices, and in appeals before various executive, quasi-judicial, and judicial entities.
Federal Tax Controversy
We are well-versed in navigating complex federal tax laws, negotiating with the IRS, and taking cases to trial when necessary. Our proactive approach aims to help clients avoid protracted lawsuits by identifying potential hazards at the pre-audit planning stage.
In the event of an audit or IRS administrative appeal, we rigorously defend your interests at every turn. We bring extensive experience dealing with the IRS to the table and are adept at resolving issues through negotiation — and if necessary, preparing to litigate issues that cannot be resolved.
Our trial attorneys are not just negotiators. Our trial attorneys are skilled negotiators with substantial courtroom experience, including in the United States Tax Court, always prepared to try cases to verdict. We develop tailored litigation strategies drawing on our deep understanding of your business, the IRS, the Internal Revenue Code, and court procedures.
Our tax controversy practice is also intimately familiar with transfer pricing issues, crucial in today’s global economy. At the pre-audit phase, we offer strategic advice on structuring cross-border transactions and documenting intercompany pricing arrangements to minimize future disputes and avoid double taxation. In the courtroom, our team leverages their understanding of your financial position, transfer pricing strategies, and business model to defend against proposed IRS adjustments.
