We advise and represent our clients in both national and international tax proceedings, in tax audits and in connection with tax criminal proceedings. Our services include:

  • Assistance during tax audits, development of audit strategies and subsequent proceedings (e.g. tax settlement agreements)
  • Representation in administrative appeals and before tax, administrative or constitutional courts including the European Court of Justice, with the Internal Revenue Service and the Department of Justice, as well as with state and local tax jurisdictions throughout the US
  • Managing tax investigations and disputes including those in relation to FATCA and for individuals in relation to tax evasion concerning undeclared assets in bank accounts offshore. Our expertise includes advising on the disclosure of reports, group litigation orders, acting in courts and tribunals, negotiating settlements with tax authorities and interviews under caution
  • Individual and corporate advice in relation to crisis management. We have extensive experience in defending raids by many different regulators and investigating authorities regulatory authorities. Our 'Rapid Response' global crisis management hotline service provides 24-hour, 365-day access to regulatory legal advice and crisis assistance.
  • Individual and corporate defense at all stages of tax criminal proceedings
  • Individual and corporate defense in tax-related liability proceedings
  • Advice on voluntary disclosure of tax evasion and disclosure submissions for individuals and companies including those relating to the Liechtenstein Disclosure facility ("LDF")
  • Negotiations with tax authorities on advance rulings and mutual agreements
  • Assistance in connection with obtaining Advanced Pricing Agreements and participation in Mutual Agreement Procedures
  • Compliance advice – guidelines and concepts for avoiding risks of criminal or other sanctions against companies, executives or staff (e.g. tax control framework)
  • Assistance with FIN 48 issues and assessment of tax audit risks