International Tax Controversy & Litigation

Companies operating in global markets have multifaceted legal, tax and operational issues that require an international perspective combined with a thorough knowledge of country-specific tax, legal and regulatory practices. Fox’s international tax controversy and litigation practice focuses on complex tax controversy matters, including tax audits, administrative appeals, claims for refund and voluntary disclosures. Our clients include corporations, partnerships, estates, high net worth individuals and government entities facing every kind of tax liability. We are experienced in cross-border tax controversies, advising clients on competent authority matters, transfer pricing and disputes related to arising from bilateral, regional and global business transactions.

Fox puts a priority on finding efficient and creative ways to resolve tax disputes to our clients’ advantage pre-litigation, whenever possible, but we are fierce, battle-tested advocates when our clients’ interests are best protected by going to trial.

Fox attorneys have represented domestic and international clients before the Criminal Investigation Division of the Internal Revenue Service, U.S. Tax Court, Court of Federal Claims, state and federal courts and international arbiters in connection with audits of nearly every category of taxation, including income taxes, sales and use taxes, estate and wealth taxes and employment taxes.