Search PillsburyLaw.com
  • All
  • Lawyers
  • Capabilities
  • Insights

Service

Federal Tax Controversy & Tax Policy

Contact

William E. Bonano
Senior Counsel, San Francisco
T: +1.415.983.1248
See All Professionals

Pillsbury’s Tax team is renowned for resolving tax controversies and achieving winning results for U.S. and non-U.S. individuals and entities before the IRS, DOJ, administrative tribunals, and in U.S. courts.

Pillsbury’s Federal Tax team has handled some of the most significant, game-changing tax controversies in recent years, establishing important precedent, applying cutting-edge procedural tactics and saving clients millions in potential tax liability. Combining decades of experience representing clients in every administrative and judicial forum with effective working relationships with IRS and DOJ enforcement personnel, we have a proven record of victories for clients in federal tax controversies.

Our team has successfully argued hundreds of tax controversies throughout the U.S. at trial and appellate levels in every U.S. federal venue, in U.S. Tax Court, courts of appeal, and before the U.S. Supreme Court. We have also represented clients in hundreds of tax controversies in administrative proceedings during IRS examinations and before the Appeals Office. In a number of these proceedings, we have negotiated settlements that saved clients well in excess of $100 million. We have also structured unprecedented settlements on behalf of financial institutions and have represented clients in a number of the largest transfer-pricing cases. Our team, which includes former IRS Chief Counsel attorneys, maintains regular communication with IRS examiners, Appeals officers and litigators.

View More

We have extensive experience in all areas of tax domestic and international tax controversy, including tax accounting, tax credits, valuation, corporate transactions, debt vs. equity, stock options, foreign account tax compliance, transfer pricing, FATCA compliance and many other matters. We are also skilled in utilizing alternative dispute resolution options to resolve disputes.

Our Federal Tax team’s services include:

  • Audit and appeals representation
  • Litigation
  • Enforcement proceedings
  • U.S. And international tax planning
  • Transfer pricing
  • Federal tax policy
  • Foreign investment & international tax planning
  • Foreign asset reporting compliance
  • FATCA compliance
  • Offshore voluntary disclosure
  • Tax-exempt organizations
  • Tax accounting
  • Corporate & business transactions
  • Advance pricing agreements
  • Competent authority proceedings
  • Summons enforcement proceedings
  • Offshore voluntary compliance programs
  • IRC section 611& 612
  • Reportable transaction and list maintenance compliance
  • Tax arbitration

Representative Experience

  • Saved a client more than $500 million in federal income taxes in a high-profile transfer-pricing case by showing the lack of merit of IRS proposed adjustments.
  • Achieved through an advanced pricing agreement a favorable transfer-pricing methodology, which was rolled back to resolve more than 10 years of potential issues on a favorable basis.
  • Resolved three cycles of domestic and international issues for a foreign multinational operating in the U.S. through a number of U.S. subsidiaries.

View More

  • Transfer Pricing
    • Successfully resolved the only transfer-pricing dispute brought to arbitration through the Tax Court’s Arbitration.
    • Assisted a large U.S. microchip fabrication company through obtaining a “Fast Track” resolution of profit split computation issues.
    • Represented a large U.S. publishing outsourcing company in connection with a substantial dollar transfer-pricing adjustment proposed by the IRS.
  • IRS
    • Saved a client more than $500 million in federal income taxes in a high-profile court case by showing the lack of merit in nearly every IRS position taken.
    • Represented a large U.S. staffing organization in negotiation of a 95 percent reduction in significant-dollar proposed IRS adjustments.
    • Following more than three years of negotiations, prevailed for large Japanese electronics firm in transfer-pricing dispute with the IRS, convincing IRS to withdraw proposed adjustments of $50 million+ in back taxes and interest.
    • Represented a United Kingdom multinational telecommunications company with a major debt vs. equity issue involving proposed adjustments exceeding $400 million in the first IRS challenge to a multinational standard centralized cash management practice.
  • Swiss Banks
    • Structured unprecedented settlements between Swiss financial institutions and U.S. prosecutors, enabling clients to avoid potentially billions of dollars in exposure under U.S. tax laws and avoid criminal prosecution.
    • Represented several Swiss banks in probes by the DOJ and Internal Revenue Service into offshore U.S. related accounts.
    • Representing one of largest government-owned Swiss banks, a cantonal bank outside Geneva, and its private banking subsidiary, in historic DOJ Program for Non-Prosecution Agreements or Non-Target Letters for Swiss Banks.
    • Assisting Swiss banks in conducting internal investigation, working closely with outside forensic accountants to extract and analyze years of U.S. client account records to meet DOJ Program demands.
    • Engaging in continuing dialogue with DOJ on behalf of Swiss bank clients regarding interpretation of the Non-Prosecution Program provisions and negotiations regarding assessment of substantial fines against participating banks.
  • Wealth Management / Estate Planning
    • Serving as co-trustee of ongoing trusts and charitable foundation with assets in excess of $2 billion and providing strategic advice on matters involving cultural institutions and long-range tax planning.
    • Representing high-net-worth real estate investor widow, contributed essential advice that saved the client hundreds of millions of dollars in tax.
    • Represented high-net-worth investor’s widow in negotiating confidential settlement believed to be among 2014’s largest litigated estate matters. Case presented novel, complex conflicts of law, state taxation and multistate residence issues.

Practice Area Highlights

  • Received American Lawyer’s 2015 “Global Dispute of the Year” Award in the area of Investigations for achievements in guiding multiple Swiss banks through the DOJ’s Swiss Bank Program.
  • Ranked among nation’s top Tax Litigation practices by Chambers USA, clients say Pillsbury is “fantastic at IRS audits and appeals” and “understand[s] where you want to go and [gets] you there.”
  • Received top-tier recognition from U.S. News & World Report nationally for tax litigation and ranked for excellence in handling tax controversies by The Legal 500 U.S.

View More

  • Pillsbury’s tax team is ranked by the International Tax Review—California and New York.

Resources

Brochure

Tax Controversy

Factsheet

Tax Issues for Doing Business in the U.S.

Factsheet

Tax-Advantaged Investment

Video

IRS to Audit 6,000 Companies for Payroll & Employment Tax Compliance Pillsbury Tax Page – keeps you on top of tax law developments

Related Insights

View More
View All