Tax Controversies

Tax Controversies:
An IRS examination can disrupt your business operations and, if not handled properly and controlled, can materially affect your relationships with third parties and shareholders, and ultimately your bottom line and share price. A taxpayer involved in an international tax controversy can face challenges and opportunities, such as issues relating to foreign-based documents, the IRS’s international summons and collection authority, and invocation of the Competent Authority relief procedures. Recognizing the need for expertise, clients call upon The Ratliff Law Firm for our broad knowledge of the tax controversy process and our superior relationships with the IRS and foreign tax authorities.

Dealing with the IRS at all levels is a mainstream part of The Ratliff Law Firm’s domestic and international tax practice. We routinely handle IRS examinations at the revenue agent level, either directly or behind the scenes as an adjunct to our client’s tax compliance department. We also take charge of an IRS examination at the IRS Appeals Office level, preparing a comprehensive written protest and negotiating with the Appeals Officer. Our attorneys regularly deal with the IRS National Office and Treasury Department, preparing ruling requests for our clients, defending our clients’ positions in Technical Advice proceedings, and seeking creative solutions to client problems through administrative determinations, revenue rulings, and Treasury regulations. We also assist clients in dealing with ancillary issues relating to a tax dispute, such as financial statement disclosure, tax reserve provisions, and tax return treatment of disputed issues going forward. Through it all, we maintain high professional standards and draw upon our excellent reputation at the IRS, all of which inures to the benefit of our clients. When you add The Ratliff Law Firm to your tax controversy team, you maximize your chances for success.

Our Services

If your company or you, individually, are under examination by the IRS, we can add immeasurably to your defense efforts and, where necessary, take full charge of the examination on your behalf. Call us when:

You are apprised of the commencement of an examination so that we can advise you on logistics, day-to-day dealings with IRS agents, and handling of sensitive issues
You need behind-the-scenes assistance with monitoring the examination, providing procedural guidance to your compliance people, and written product responding to legal and sensitive factual questions
You need a skilled representative to deal directly with the agents and to control the examination
You anticipate receiving or receive a Notice of Proposed Deficiency ("30-Day Letter), and wish to take the case to the IRS Appeals Office
You are planning a transaction that requires a ruling from the IRS National Office or are in the midst of an IRS examination that requires Technical Advice from the IRS National Office
You need favorable IRS or Treasury action in the form of an administrative announcement, revenue ruling, or Treasury Regulation
You would like to pursue the IRS mediation procedure
You need Competent Authority assistance