Page 1 Page 2 Page 3 Page 4 Page 5 Page 6 Page 7 Page 8 Page 9 Page 10 Page 11 Page 12 Page 13 Page 14 Page 15 Page 168 TAX CONTROVERSY AND TAX LITIGATION Baker Botts’ tax controversy and litigation practice lawyers for decades have represented clients across the country in all manner of substantial, complex tax controversies before the Internal Revenue Service, at its Examination and Appeals divisions and its National Office, the Department of the Treasury, the Tax Court, Court of Federal Claims and federal district courts and courts of appeals and the Texas Comptroller of Public Accounts, the taxing authorities of Texas localities and the taxing authorities of other states. We thoroughly evaluate the merits of complex tax issues and develop creative arguments in defense of proposed adjustments. Our lawyers prepare detailed responses to the IRS’ proposed adjustments and written protests for those examinations that proceed to IRS Appeals and have represented clients in a number of mediations, including post-appeals and fast-track mediations. Where a resolution of a tax controversy cannot be achieved administratively, our lawyers have substantial experience in tax litigation in all forums. Most cases are settled without the necessity of trial, however, we have tried many large cases involving sophisticated issues and hundreds of millions of dollars in controversy. TRANSFER PRICING Our tax lawyers regularly work with our clients’ economists and valuation advisors to comply with the intricate U.S. transfer pricing rules. We counsel companies on the range of available methods to determine a transfer price and the documentation that must be collected. We have particular experience on issues affecting the development, transfer and exploitation of intangibles, including IP rights. We help our clients negotiate advanced pricing and related agreements and regularly assist in implementing intercompany cost sharing arrangements for the development of intangibles and shared services arrangements with respect to covered services. We participate in competent authorities’ proceedings, and we defend transfer pricing issues before the IRS on examination and before Appeals.