Matthew D Lerner

Practice Areas

Matt Lerner leads Sidley's Tax Controversy practice. He has more than 35 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, as well as 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 authorities. He has handled controversies on a broad array of subjects, including the research credit and other tax incentives, transfer pricing, complex cross-border transactions, the international provisions of the TCJA, debt/equity, valuation, cost recovery, worthless stock and bad debts, accounting methods, partnership taxation, tax-advantaged transactions, and old Section 199. 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. Matt also advises ultra-high net worth individuals on matters relating to taxation.

Matt frequently speaks to business and tax groups on tax controversy and ethics topics and is nationally recognized for his practice. He focuses on getting to know clients, their businesses, and the considerations that affect their decision-making. One client notes that he “is a tremendous advocate for the client, has great legal expertise and is persuasive in negotiating disputes.” Matt prides himself and his team on always being available and responsive to clients’ evolving needs and requests. Clients describe him as “an outstanding collaborator. He offers outstanding practical advice and insights which are extremely helpful.”