Schiff Hardin tax lawyers have handled federal, state and local controversies involving income tax, gift and estate taxes, and various other state and local taxes, including sales and use tax and franchise tax matters.
We assist taxpayers, their accountants and local counsel at all stages of tax controversies from initial audit and administrative appeal through contested court proceedings, if necessary. We have an excellent track record of resolving tax controversies administratively (avoiding litigation) and favorably to taxpayers.
Tax controversies with which we have been involved include:
- Challenges to family limited partnerships and LLCs
- A diverse array of tax accounting issues raised in connection with business acquisitions and operations
- Penalty relief or mitigation
- Various sales and use tax matters including those involving e-commerce and economic nexus
- Challenges to sophisticated capital formation structures such as the use of leveraged preferred stock
- Challenges to straddle and other trading strategies
We also have represented a number of individuals and entities at the audit level and beyond in connection with so-called "tax sheltered investments." Working with attorneys in the firm's White Collar Crime and Corporate Compliance Group, we also represent clients in connection with tax fraud investigations and litigation.
Our attorneys represent taxpayers involved in tax collection and related matters. We have counseled corporate officers regarding the attempted imposition of the "100% penalty" for the payment of delinquent payroll taxes. We also have represented "innocent spouses" in connection with divorce-related tax matters and attempts by the IRS to collect taxes owed by their former spouses. We assist taxpayers who have fallen behind in their tax filing responsibilities in qualifying for voluntary disclosure and tax amnesty programs.
Several of our partners are CPAs. We regularly advise accountants in connection with privilege issues and audit defense strategies.