Davis Polk has long had a leading tax litigation practice. The firm’s Tax Controversy Group includes partners, senior counsel, counsel and associates from Davis Polk’s Tax and Litigation Departments.
The tax controversies we handle involve partnership taxation; debt-equity issues; international taxation; intercompany pricing; interest capitalization and allocation; accounting for bad debts; amortization of intangibles; withholding taxes; foreign tax credit issues; and deductibility of takeover and divestiture expenses. Our tax controversy clients include domestic and foreign banks and financial institutions; insurance, pharmaceutical and medical companies; communications and technology companies; food and beverage and consumer product companies; and partnerships and corporations engaged in research, manufacturing and communications.
We have represented our clients before federal courts (including the U.S. Court of Claims, the U.S. Tax Court and the U.S. Court of Appeals for the Federal Circuit) and state courts (including the New York Court of Appeals), as well as before federal and state agencies. We regularly negotiate settlements with the Internal Revenue Service involving billions of dollars of disputed taxes, and pursue high-stakes administrative appeals in complex tax matters.
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