Baker McKenzie LLP‘s tax controversy practice represents a diverse array of prominent companies and individuals in the full spectrum of tax disputes, including appeals, audits, and litigation. In addition to a robust federal and SALT offering, the group is noted for its strength in international matters, benefiting from the firm’s global network of offices. George Clarke leads the department from Washington DC and covers the full array of tax disputes at the federal and international levels, including both civil and criminal matters. Also in DC are Duane Webber, a key contact for international disputes and a member of the firm’s Global Executive Committee, and transfer pricing expert Salim Rahim, who is chair of the firm’s broader North America tax practice. Mark Oates, based in Chicago, covers an array of international contentious tax matters, with particular strengths in transfer pricing. Key names in the New York office include Maria Eberle, who chairs the SALT sub-practice, and senior counsel Daniel Rosen, who is experienced in a range of domestic and international disputes.

Eversheds Sutherland takes a leading role in various major civil, criminal, and administrative tax disputes, with experience representing clients in high-stakes matters both domestically and internationally. Team lead Robert Chase is based in Washington DC and advises on audits and appeals in addition to maintaining a strong non-contentious tax practice. Alongside Chase in DC are Jeffrey Friedman, who is noted for his SALT expertise, and Caroline Setliffe, who has significant experience handling international tax matters, including treaty considerations and transfer pricing issues. The DC offering saw significant growth over the course of 2023 with the additions of Dwight Mersereau, David Blair, and David Fischer, all of whom joined the firm from Crowell & Moring LLP early in the year. The Atlanta office includes Eric Tresh, who plays a key role in SALT disputes for some of the firm’s major clients, and Maria Todorova, whose practice includes audits, restructurings, and the negotiation of settlements with tax authorities. Sacramento-based Timothy Gustafson heads the California offering, and has diverse sector expertise. Federal tax expert Sarah Paul and SALT specialist Ted Friedman are core team members in New York. Counsel Alla Raykin, who is based in Atlanta, is a key name.

Latham & Watkins LLP fields a highly regarded contentious tax team with strength in matters relating to transfer pricing, partnerships, and employee benefits. In addition to its robust litigation offering, the department represents clients in audits, appeals, and investigations, with notable expertise in resolving disputes in pre-trial settings. Miriam Fisher, who leads the team from Washington DC, has experience in both federal and state tax matters and represents clients in both civil and criminal cases. Jean Pawlow works between Silicon Valley and DC and maintains close client relations with diverse range of prominent players in the technology, financial, and industrial sectors in addition to working with high net worth individuals. Brian C. McManus, who is chair of the tax department in Boston, additionally maintains a practice in DC and is a key contact for domestic and international tax disputes. Andrew Strelka in DC has experience across the private equity, energy, and financial sectors, having previously worked as senior tax counsel in the Biden White House. Joshua Wu, also of DC, is a further key name within the department, with experience in partnership audits and offshore tax issues.

Mayer Brown fields a team with significant experience in complex national and multinational tax disputes, in addition to displaying strengths in SALT matters across all 50 states. With expertise across the media, hospitality, and technology sectors, the department is in particular noted for its successes in the energy sector, where it works on behalf of numerous prominent multinational groups. The group is jointly led by Brian Kittle, who is based in New York, Gary Wilcox in Washington DC, and Thomas Kittle-Kamp and Joel Williamson, both of whom work from Chicago. Other key names include Larry Langdon in Palo Alto, who is well-known for his acumen in alternate dispute resolution techniques, Leah Robinson, a New York-based SALT expert, and John Hildy of Chicago, whose practice covers transfer pricing in addition to a range of other contentious multinational tax matters. Also in Chicago are Jenny Austin, who has broad disputes expertise and acts in IRS audits, appeals, and litigation, and Anthony Pastore, who has represented clients at all stages of tax controversy.

McDermott Will & Emery LLP fields a large team active nationwide in the full range of contentious tax issues, including audits, appeals, and litigation. Digital tax matters are a key area of expertise for the team, which acts on behalf of numerous prominent companies with interests in this sector. The group is led by Catherine Battin, a Chicago-based SALT expert with a strong record in tax disputes at all levels. Senior partner Jane Wells May, who is a former team lead, is also active in the Chicago office. Other key names include Charles Moll in San Francisco, who is a SALT specialist with experience litigating before the US Supreme Court, Stephen Kranz, who works from Washington DC and is particularly active on behalf of tech companies, and the Boston-based Richard Call. The team saw significant growth over 2023 with the additions of Shawn O’Brien, who joined the Houston office from Mayer Brown, Edward Froelich, new to the DC team from Morrison Foerster, and New York-based lawyer Michael Scarduzio, formerly of Jones Day.

Morgan, Lewis & Bockius LLP advises a broad array of clients in complex and high stakes tax disputes, many of which potentially involve multibillion-dollar sums. The group is active on behalf of domestic and international clients across the retail, energy, and technology sectors, among others, and provides expertise in audits, appeals, and litigation. The department is led by Barton Basett, an expert in international tax issues based in Silicon Valley. Core team members within the department include Sheri Dillon in Washington DC, who is a federal tax controversy specialist with experience acting on behalf of both businesses and high net worth individuals, Chicago-based Thomas Linguanti, who is particularly active in audits and litigation related to transfer pricing, and Alex Sadler, in DC, whose practice covers international tax credit issues. Also based in DC are R&D credit specialist Doug Norton as well as Michael Kummer, a key name for transfer pricing matters. Rod Donnelly in Silicon Valley assists clients with a broad array of tax concerns, including Subpart F, foreign tax credits, and transfer pricing issues. SALT specialist William Gorrod joined the San Francisco office from Baker Botts L.L.P. in February 2024.

Skadden, Arps, Slate, Meagher & Flom LLP covers a diverse array of tax controversy mandates on behalf of major domestic and international clients, including transfer pricing, tax accounting, and issues relating to employment taxes and worker classification matters. The group provides support in litigation, mediation, and arbitration in addition to fielding comprehensive expertise in audits and appeals. Christopher Bowers in Washington DC is noted for his strength advising domestic and international companies and financial institutions on international tax matters. Also in DC are transfer pricing experts Royce Tidwell and Raj Madan well as Armando Gomez, whose practice covers tax credit disputes, gift tax matters, and criminal tax issues. Emily Lam and Christopher Murphy are leading names in Palo Alto and work on behalf of numerous prominent tech companies and financial groups. Boston partner Kat Gregor has broad sector expertise and is experienced in both litigation and arbitration. Significant upcoming names in the practice include Nathan Wacker, who made partner in 2022 and covers a range of international tax matters, and Melinda Gammello, who was promoted to partner in 2023 and maintains close relationships with a growing roster of blue-chip clients. Both Wacker and Gammello are based in DC. Juliana Hunter is a name to note in the Houston office.

Caplin & Drysdale, Chartered is a Washington DC-based boutique known for its strength in both civil and criminal tax disputes that is hailed by clients as ‘true leaders of the tax litigation bar’. The group acts on behalf of both businesses and private individuals and is noted for its strength in matters involving undisclosed offshore bank accounts and assets, though it also routinely handles other complex international tax mandates. Leading the team are highly experienced criminal tax practitioner Scott Michel and Christopher Rizek, whose practice covers conservation easements, estate and gift taxes, and tax shelter investigations. Michel and Rizek are praised for being ‘knowledgeable, accessible, and very sensitive in dealing with clients’. Niles Elber handles both civil and criminal matters and has recently demonstrated strengths in the conservation easement space, Mark Matthews is primarily active on behalf of high net worth individuals, including those holding assets internationally, and Charles Ruchelman is a key name for captive insurance matters. Other core team members include international tax specialist Victor Jaramillo as well as Benjamin Eisenstat.

Chamberlain Hrdlicka‘s highly experienced team has expertise in audits and appeals and is a leading name in tax litigation. The group is regularly active in both federal and SALT matters in addition to handling international mandates involving South America and Europe. Leading the team is the Houston-based Juan F. Vasquez, Jr., who has experience acting on behalf of both high net worth individuals and prominent multinationals in an array of federal and state and local tax matters. Key team members include David Aughtry in Atlanta, who handles federal criminal and civil tax disputes, Jaime Vasquez of San Antonio, whose practice covers an array of transactional and tax controversy matters, and Larry Campagna, who is based in Houston and is well known in the market. Philadelphia lawyer Jennifer Karpchuk co-heads the firm’s national SALT practice. Recent additions to the team include Erin Hines, who joined from the Tax Division of The Department of Justice in late 2022, and Tom Cullinan, who previously worked within the IRS before moving to the firm in April 2023. Both Hines and Cullinan are based in Atlanta.

DLA Piper LLP (US) covers the full gamut of tax disputes, acting on behalf of prominent businesses and high net worth individuals in complex domestic and international matters. The group is particularly noted for its strength in criminal tax, with expertise in managing major, high-profile investigations. Co-leading from New York are Ellis Reemer, who has a strong record of acting at the federal, state, and local levels and formerly worked within the IRS Chief Counsel’s office, and criminal tax expert Diana Erbsen, previously a member of the tax division of the US Department of Justice. Also key are Joseph Myszka in Sacramento, who specialises in international tax issues, and San Francisco-based Henry Cheng, who was promoted to partner in 2023 and covers a range of civil tax disputes, including transfer pricing and matters relating to foreign tax credits. Victoria Gu, who works from Palo Alto, is a further name to note.

Gibson, Dunn & Crutcher LLP advises a prestige client base of businesses and individuals on tax disputes at all levels, including audits, administrative resolution, litigation, and appeals. The group acts across a broad range of sectors, including energy, tech, and financial services, and covers an array of tax matters, including transfer pricing, partnership tax issues, and renewable energy credits. Michael Desmond, a Los-Angeles based expert in federal tax matters, co-leads the team alongside the Washington DC-based Sanford Stark, whose specialism lies in international tax disputes. Also based in DC are Saul Mezei, who covers research credits, accounting methods, and employment taxes, and Terrell Ussing, whose focus is transfer pricing. Anne Devereaux is a highly experienced name in Los Angeles who has a background working within the IRS.

Kirkland & Ellis LLP‘s rapidly growing team covers an extensive range of tax disputes at all judicial levels in addition to offering strengths in alternate dispute resolution methods. The department is regularly sought out by high profile clients, including leading names in the energy, private equity and banking sectors. Key names in Houston include Richard Husseini, a highly experienced practitioner who covers both contentious and non-contentious tax mandates, and David Cole, whose expertise encompasses both federal and state tax matters. Natalie Keller in Chicago is well-versed in audits, appeals, and litigation and regularly works with clients in the energy and financial management sectors. Washington DC lawyer David Foster is well known in the market and has a broad practice which includes transfer pricing, estate and gift taxes, and criminal tax.

Highly regarded tax boutique Kostelanetz LLP fields a team of ‘superstar lawyers’ with coverage of both civil and criminal tax matters. The firm acts on behalf of a diverse client base of prominent businesses and individuals facing high-profile administrative and judicial proceedings both domestically and abroad. New York lawyer Bryan Skarlatos co-leads the department with ‘gold standard’ practitioner Caroline Ciraolo, who is based in Washington DC. Skarlatos, who has more than 35 years’ experience in the practice area, covers all aspects of audits, appeals, and litigation and is also noted for his expertise in criminal matters. Ciraolo primarily focuses on civil tax disputes, with experience in both federal and SALT matters. Megan Brackney and Sharon McCarthy, both based in New York, are key names in the practice, with Brackney chiefly handling in audits, while McCarthy is noted for her work in relation to tax investigations. Other names to note in New York include litigator Christopher Ferguson and Michael Sardar, who primarily counsels high net worth individuals on various tax issues. DC lawyer Abigail Burke is a key name.

Miller & Chevalier Chartered is a prominent name for federal tax matters, with a long history of advising prestige clients in the full array of disputes. Active across numerous industries, the group has expertise in transfer pricing, insurance tax, and matters relating to tax incentives, among other issues, and also maintains a strong record of handling complex cases involving multiple jurisdictions. George Hani and Kevin Kenworthy co-head the team; Hani is a specialist in tax accounting issues, with experience in IRS examinations and appeals, while Kenworthy is a seasoned litigator with a practice that covers a range of domestic and international tax issues. Further key names within the team include Maria O’Toole Jones, who is a key contact for insurance tax, Robert Kovacev, who covers international tax matters and is developing a practice focused on the taxation of robotics and artificial intelligence, and James Gadwood, whose client base includes prominent businesses, funds, and high net worth individuals. Transfer pricing specialist Lisandra Ortiz is also a name to note. All lawyers mentioned are based in Washington DC.

Steptoe LLP‘s team has expertise in a broad array of domestic and international tax disputes, with a strong record in both litigation and administrative dispute resolution. International tax specialist Philip West, who is located in Washington DC, co-leads the group with the New York-based Beth Tractenberg, whose practice is primarily focused on private clients, including international individuals with complex cross-border assets. Lawrence Hill, who is also based in New York, has significant experience in both civil and criminal tax matters, with a strong record in litigation and IRS administrative processes. DC lawyer Steven Dixon is an expert in transfer pricing matters and works with a broad range of clients across the energy, technology, and insurance sectors, among others. Other core team members in DC include Amanda Pedvin Varma, who handles international tax controversies, and associate Caitlin Tharp, who handles federal matters and is well-versed in handling matters concerning the application of tax law to emerging technologies.

Akerman LLP maintains close relationships with clients from an array of industries, including the retail, technology, and financial sectors. The practice includes five dedicated SALT, federal, international, trusts and estates, and employee benefits tax sub-teams. Peter Larsen, who is based in Jacksonville, co-leads the practice with Chicago lawyer David Blum. Larsen has particular strength in tax challenges relating to emerging technologies, while Blum is a SALT specialist with prior experience as a state tax auditor. SALT sub-practice chair Michael Bowen, who is based in Jacksonville, acts for both national and international clients in relevant disputes. Stefi George, of the New York office, is another SALT expert who acts nationwide advising on tax compliance, controversy, and litigation. Miami lawyer Lorie Fale is also a key contact for clients facing state tax assessments.

Baker Botts L.L.P. maintains longstanding expertise in the energy, technology, and financial services sectors and is highly active in both federal and SALT matters. The group, which demonstrates expertise in audits, appeals, and litigation, is additionally noted for its robust private client practice, which has expertise in estate and gift tax disputes. Houston-based SALT chair Renn Neilson covers disputes relating to sales tax, property tax, and income tax and is particularly sought out by clients in the energy sector. John Porter and Keri Brown work alongside Neilson in the Houston office and are both highly active on behalf of high net worth individuals and families. San Francisco’s Jon Feldhammer has a broad practice covering work for both individuals and public companies, while Ben Geslison, in Houston, is experienced as a trial and appellate litigator. William Gorrod left the firm in February 2024.

Davis Polk & Wardwell LLP fields a team with expertise in all key areas of tax controversy, including partnership taxation, international taxation, and tax credit issues, among others. The group acts before both state and federal courts on behalf of both domestic and international clients, including Microsoft, JPMorgan, Warner Bros. Discovery, and Pfizer. New York-based team lead Mario Verdolini handles a range of contentious tax matters and is particularly adept in administrative proceedings and settlements in addition to handling appeals and risk management matters. Verdolini acts on behalf of a broad client base, including prominent names in the financial, media, and pharmaceutical sectors. Christopher Baratta covers transfer pricing matters and regularly works closely with Verdolini in complex multijurisdictional cases.

Holland & Knight LLP is a trusted choice for major corporations and large family estates, with expertise at the administrative, trial, and appeals court levels. Co-leading the tax controversy group within the firm are Mary McNulty, who is based in Dallas, and William Sharp, who works from Atlanta. McNulty has particular strength in the energy sector, while Sharp is in particular noted for his aptitude in international tax matters. Dallas lawyer Abbey Garber has over 30 years of experience in the practice area, with a record in both civil and criminal issues. Also in Dallas is Lee Meyercord, who focuses on federal tax disputes and acts on behalf of both prominent corporations and high net worth individuals. Amish Shah works from Washington DC and is highly active in the energy sector.

Norton Rose Fulbright US LLP works as part of the firm’s global network to provide comprehensive tax support on an array of complex, multijurisdictional matters. The group covers litigation and administrative proceedings at the federal and SALT level, with expertise in advanced pricing agreements and transfer pricing as well as in criminal tax matters. Robert Morris, who is based in Houston, co-leads the department alongside William Cavanagh in New York. Morris covers disputes at both the federal and state level, while Cavanagh, whose practice is primarily non-contentious, increasingly acts on tax matters that are connected to bankruptcy. Stephen Kuntz, also in Houston, is particularly active in the energy sector, with experience in transfer pricing and energy credits.

Vinson & Elkins LLP fields a ‘very experienced’ team with broad sector expertise and a strong record in an array of contentious tax matters, including issues relating to partnership rules. Highly experienced litigator George Gerachis, who works from Houston, co-leads the team alongside the New York-based Kathleen Pakenham, whose practice covers partnership tax and transfer pricing. Pakenham joined the team in January 2023 from Cooley LLP alongside Adriana Wirtz, also of New York, who is experienced in a range of audits and litigation and is well-versed in matters relating to tax insurance. Gary Huffman, in Washington DC, acts in both contentious and non-contentious tax matters for clients active in the energy and industrial sectors.

Winston & Strawn LLP acts on behalf of a broad array of clients in both litigation and administrative procedures, with experience in audits, appeals, and internal investigations. Co-leading the team are James Mastracchio, who has a strong track record in both civil and criminal tax controversy, and Susan Seabrook, who is noted for her strength in complex multijurisdictional matters. New York lawyer Karl Kurzatkowski has key expertise in the insurance industry and provides support for numerous prominent clients in this area, while Zachary Weit has experience advising clients in the nonprofit sector. Unless otherwise mentioned, all recommended lawyers are based in Washington DC.

Tax controversy boutique Asbury Law Firm is key port of call for clients in a wide array of sectors, including manufacturing, entertainment, and real estate, who rely on the team’s extensive knowledge of federal tax matters. Conservation easements are a key focus of the group, which is active on behalf of both individuals and businesses facing issues in this space. Founding partner Anson Asbury is highly active as a thought leader in the area and represents an array of clients in investigations, litigation, and appeals. Asbury co-leads the department alongside Brian Gardner, an experienced litigator highly active in the real estate sector. Mark Mesler is a key contact for a number of the firm’s most prominent clients and focuses on tax examinations and appeals. All mentioned practitioners are based in Atlanta.

BakerHostetler acts on behalf of businesses and private individuals in a range of high-profile tax disputes, including Moore V. United States, a highly significant test case. Co-leading the team are Jeffrey Paravano, who is based in Washington DC, Michelle Hervey in Cleveland, and Elizabeth Smith in New York. Paravano has more than 30 years’ experience in the practice area and is well-versed in tax litigation and investigation, Hervey specializes in federal tax controversies, including both litigation and administrative procedures, while Smith covers both contentious and non-contentious tax matters and has experience handling audits. Other key names in DC include Paul Schmidt, who acts for both domestic and international clients, and Nicholas Mowbray, whose practice includes tax issues related to digital asset transactions. Columbus-based tax litigator David Ebersole made partner in January 2024.

Blank Rome LLP fields a leading SALT team that routinely acts in audits, appeals, and litigation, with expertise in all 50 states. The group is active on behalf of prominent multinationals in addition to advising high net worth individuals and SMEs. Craig Fields, who leads the team from New York, advises on both contentious and non-contentious SALT matters and is recognized as a thought leader in the area. Other key names in New York include experienced litigator Mitchell Newmark, as well as Nicole Johnson, whose practice covers the audit, administrative, and judicial levels, and Eugene Gibilaro, who has a growing reputation for advising clients in the manufacturing and healthcare sectors.

Dentons‘ client roster, which ranges from private individuals and families to prominent multi-state and multinational companies, benefits from the team's wide-reaching expertise in all types of tax controversy, including audits and investigations through to trials and appeals. The group offers specific expertise in conservation easements, captive insurance matters, and foreign asset and account disclosure. Louisville lawyers Mark Loyd and Gregory Rhodes jointly head up the practice. Loyd is active at both the federal and SALT levels and has experience at all levels of the courts, including the US Supreme Court, while Rhodes is very active in advising both individuals and businesses on matters relating to conservation easements. Huntsville-based Michelle Levin has experience in contentious and non-contentious tax matters at the federal level, with prior experience in the tax division of the US Department of Justice. Bailey Roese, in Louisville, is a further name to note, as is Huntsville lawyer Logan Abernathy, who is described as ‘sharp‘ and ‘promising’. 

Fenwick & West LLP has key expertise in the technology and life sciences sectors, with experience covering issues relating to the taxation of cryptocurrency and online software. The group is additionally well-versed in transfer pricing matters and acts on behalf of numerous prominent clients in this area. Larissa Neumann leads the team from Silicon Valley and specialises in transfer pricing, in addition to standing out for her aptitude in international tax matters. Also in Silicon Valley are William Skinner, who shares Neumann’s international focus and covers both contentious and non-contentious matters, as well as David Forst, a key name for tax issues relating to NFTs and cryptocurrencies. Adam Gahtan in New York has a broad litigation practice, supplementing his tax expertise with coverage of IP disputes and antitrust matters.

Jones Day is particularly noted for its strength in criminal tax matters, with experience handling complex multijurisdictional investigations and disputes. The group also advises on civil tax disputes and works within the firm’s global network to aid clients in audits and litigation of any scale. The contentious tax group is led by New York lawyer Kathryn Keneally, who previously worked within the Department of Justice Tax Division and has more than 35 years’ experience in the practice area, with a strong record of representing individuals, corporations, and financial institutions in civil and criminal tax controversy. Charles Hodges is based in Atlanta and specializes in federal tax disputes, including matters relating to transfer pricing. New York lawyer Michael Scarduzio left the firm in November 2023.

The rapidly growing team at Moore Tax Law Group is cultivating a reputation as ‘one of the premier tax controversy boutiques in the country’, with demonstrable expertise in criminal tax matters. In addition to representing clients in litigation, the group handles administrative procedures and out of court negotiations with tax authorities. Founding partner Guinevere M. Moore, who is based in Chicago, co-leads the team with Zhanna A. Ziering in New York. Moore is ‘an outstanding tax litigator’ with experience in high stakes civil and criminal tax disputes. Ziering is active in both federal and SALT matters and is additionally well-versed in international tax issues and matters relating to the taxation of cryptocurrency. Also working from Chicago are Ajay Gupta, an expert in tax litigation and white collar crime, and Shay-Ann Heiser Singh, whose tax practice is supplemented with a background in bankruptcy and immigration matters. New York lawyer Aaron Esman is a further name to note.

Pillsbury Winthrop Shaw Pittman LLP routinely acts for major multinational clients, including Apple, Microsoft, and Pfizer, in business-critical SALT matters. The department is particularly strong in California, where it regularly handles appeals, audits, and administrative procedures. SALT expert Carley Roberts leads the team from Sacramento and acts in litigation and administrative matters in addition to maintaining a robust non-contentious practice. San Francisco lawyer Jeffrey Vesley, who previously co-led the group alongside Roberts, remains active in a range of SALT matters. Zachary Atkins, who is based in Nashville, made partner in January 2024 and is described by clients as ‘a future leader in the space.’

Sullivan & Worcester LLP is particularly adept at handling SALT matters and chiefly represents high-profile clients facing tax controversy within Massachusetts. Jointly leading the team are Richard Jones, David Nagle and Daniel Ryan, all of whom are based in Boston. Jones is a SALT expert who has extensive experience working with clients in the technology, retail, and media industries. Nagle, who is a co-managing partner of the firm, additionally covers federal disputes, as does Ryan, who also maintains a non-contentious practice which covers transactional planning. Caroline Kupiec, who also works from Boston, provides key support to clients facing audits and litigation.

Todd Welty. P.C., established in 2019, is a tax controversy boutique that has a particular penchant for handling disputes relating to conservation easements. Atlanta-based founding partner and team lead Todd Welty, previously of McDermott Will & Emery LLP, is an expert in civil tax disputes, with particular aptitude in resolving cases outside of court. Daniel Rosen, who divides his time between New York, Salt Lake City, and Atlanta, has a practice which covers transfer pricing, civil fraud, and corporate and individual tax shelters, among other issues. Andrew Steigleder works between Chicago and Atlanta, and covers audits, appeals, and litigation, while Lyle Press, of New York and Atlanta, is a federal tax expert with a history of working within the IRS.

White & Case LLP caters to high net worth individuals and prominent corporations facing complex tax disputes, including those involving multiple jurisdictions. The group offers particular expertise in transfer pricing matters, with further strengths in advising on audits. The department is co-led from Washington DC by Kim Marie Boylan, who has significant experience in international tax matters. Sean Lyons, also of Washington DC, is highly active in the practice and represents clients in proceedings at all levels. Brian Gleicher  has left the firm.