Matt Lerner leads Sidley's Tax Controversy practice. He has 33 years’ experience with tax-related matters, focusing on advising on and litigating federal tax disputes. His work covers all stages of the IRS’s administrative process, including representations in audits and at IRS Appeals and litigation in federal courts. He also advises clients regarding pre-audit planning and audit readiness, document retention strategies, and the establishment and preservation of applicable evidentiary privileges. Matt assists clients with setting up and maintaining efficient global tax controversy functions, to ensure consistency in reporting and dealing with global tax controversies. He has handled controversies on a broad array of subjects, including transfer pricing, complex cross-border transactions, debt/equity, valuation, cost recovery, worthless stock and bad debts, accounting methods, tax-advantaged transactions, research credits, other tax incentives and Section 199. Matt also assists clients with preparing for audits of their reporting positions with respect to the provisions of the Tax Cuts and Jobs Act. He works extensively with expert witnesses, both to assist clients in supporting their positions and in effectively challenging opinions presented by government subject matter specialists.