Tax: Controversy Department

What the team is known for Highlighted for its comprehensive civil and criminal tax practice. Advises corporate entities and individual clients on investigations and enforcement proceedings involving matters such as cross-border tax compliance. Offers an outstanding track record in litigation before the US Tax Court and is also noted for its handling of appeals. Diverse industry expertise spans the energy, financial services, insurance and technology sectors, among others.

Strengths An interviewee notes: "The team is very cohesive and thoughtful, and is very talented at thinking through issues," also highlighting their ability to "simplify very complex tax concepts into concise arguments."

"They go out of their way in anything they do to make sure the client is fully satisfied," one impressed client comments, adding: "The team is astute, well connected and technically superb."

A further source comments: "They are absolutely stellar - extremely skilled and extremely competent."

Work highlights Represented Coca-Cola before the US Tax Court in a transfer pricing dispute relating to an IRS determination that the company owed $3 billion in US income taxes.

Notable practitioners

Alan Horowitz is a respected tax controversy litigator with particular expertise in handling tax appeals before the US Supreme Court and federal appellate courts. Interviewees consider him a "very strong lawyer in this space, and a very good writer and thinker."

George Hani frequently acts on tax refund litigation for major energy organizations as part of a broader tax controversy practice. An interviewee says: "He is very skilled at thinking strategically about the issue and considering the broader picture."