Tax controversies

In this ever changing and challenging environment, our Withers Tax Controversy team will work with you to prevent, efficiently manage, and resolve tax examinations and disputes. We have a highly experienced global team of Partners and Of Counsels, from both our Tax and Litigation practices, who can assist you in virtually every area of dispute. We combine deep technical understanding, local knowledge, strong relationships with government officials, tax litigation experience, and a global perspective to provide our clients timely and thoughtful advice.

With tax investigations, a one size fits all approach simply does not work. Our team will carefully review your issues and develop a strategy of responses and solutions based on years of procedural and substantive tax experience. Our goal is to resolve a client’s case by balancing the value of an early resolution against the costs and potential outcomes of tax litigation. We counsel, negotiate and, when appropriate, aggressively advocate for our clients in tax investigations and prosecutions.

We represent individuals and entities that have been accused of owing tax or being criminally liable for not complying with tax law. We have defended our clients against a broad range of tax crimes, including, but not limited to: tax evasion; evading/obstructing the collection of tax; negligent/fraudulent tax return preparation; failure to report income; fraudulently overstating deductions; failure to withhold and/or pay over employment tax; and failure to charge and/or remit sales tax.


  • Tax Examinations/Audits
  • Tax Collection Defense
  • Defense against Summons Enforcement
  • Civil and Criminal Tax Litigation (in Federal and State Courts)
  • Voluntary Disclosures (offshore, domestic and state/multistate)

Recent work

  • Negotiated with IRS for a decrease in the civil miscellaneous penalty associated with the Offshore Voluntary Disclosure Program as a result of partial compliance.
  • Represented client in examination emanating from IRS Criminal Investigations and through negotiation were able to have case returned to a civil examination and resolution.
  • Represented TEFRA Partnership in IRS examination that was settled at the IRS Office of Appeals and reduced a proposed deficiency from $12 Million to nothing.
  • Successfully negotiated multi-state voluntary disclosure involving over 30 states.
  • Represented corporation in Connecticut Department of Revenue civil tax exam with underlying criminal issues. Negotiated a proposed adjustment from $1,000,000 in tax to $10,000.

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