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.
Our lawyers are widely recognized for their experience, innovative planning and understanding of business needs and objectives, particularly with respect to tax litigation involving:
- Partnership taxation
- Debt-equity issues
- Intercompany pricing
- Interest capitalization and allocation
- Accounting for bad debts
- Amortization of intangibles
- Deductibility of takeover expenses
- Foreign tax credit issues
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.