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International Tax Controversies

Kostelanetz frequently advises U.S. taxpayers with worldwide income and assets, as well foreign clients with activities within the United States, regarding U.S. tax and reporting obligations. Our attorneys also serve as consultants and expert witnesses for other firms and legal, tax, and accounting professionals seeking guidance and opinions with respect to complex international tax issues. Our firm has extensive experience addressing inbound and outbound issues, foreign trusts and foundations, foreign tax credits, foreign reporting obligations, and the impact of the 2017 Tax Cuts and Jobs Act (TCJA) in the areas of transfer pricing, Global Intangible Low-Taxed Income (GILTI), and the Base Erosion Anti-Abuse Tax (BEAT).

Kostelanetz attorneys have exceptional skills with international tax planning, compliance, and controversies. The firm includes a former Special Trial Attorney for the IRS Office of Chief Counsel in New York, a former Acting Assistant Attorney General of the U.S. Department of Justice (DOJ) Tax Division, a former Chief of the IRS Criminal Investigation Division, several attorneys with experience in the IRS Office of Chief Counsel, and four attorneys with criminal and civil DOJ Tax Division experience. Our attorneys frequently speak on and write about international tax issues and serve as adjunct professors in the Georgetown University Law Center’s Tax LL.M. program for a course on International Tax Controversies.

The firm, overall, is ranked nationwide by legal rankings agency Chambers USA in Tax Controversy, and four of the firm’s attorneys are ranked by Chambers USA for Tax: Fraud, nationally. In 2018, Kostelanetz was honored as Tax Team of the Year by Chambers USA. Interviewees remarked to Chambers USA about Kostelanetz:

  • “There’s no better group of people to handle tax controversy matters – they’re very effective and personable.”
  • “They’re tax experts and they have a deep knowledge and thorough understanding of the tax code, but also how the IRS and DOJ are going to approach things.”

The firm has also been recognized as a Tier 1 National “Best Law Firm” in three categories, Tax Law, Litigation – Tax, and Criminal Defense – White-Collar, by U.S. News – Best Lawyers®.

Represented thousands of U.S. taxpayers coming into compliance through voluntary disclosures, Streamlined Filing Procedures, Delinquent FBAR Submission Procedures, and Delinquent International Information Return Submission Procedures.

Advised a client on U.S. reporting obligations with respect to a $600 million foreign trust.

Successfully resolved a double tax issue through Mutual Agreement Procedures with the IRS’s Competent Authority.

Represented a multi-national client during a transfer pricing dispute, navigating tax authorities in the United States and foreign jurisdiction.

Assisted U.S. citizen with hundreds of millions of dollars in assets to expatriate from the U.S.

Represented clients with respect to foreign requests for information transmitted pursuant to treaty exchange of information provisions.

Advised clients with respect to transition tax obligations and exposure involving Internal Revenue Code section 965.

Advised corporate clients on the tax impact of GILTI and options to manage the company’s global effective tax rate.