Baker Botts tax controversy and litigation lawyers are both tax lawyers and litigation lawyers. We have underlying knowledge of tax law, combined with a deep bench of substantive tax professionals, providing the highest caliber of service to clients. Our team is experienced at settlements short of litigation with significant, varied administrative practice before IRS Exam and IRS Appeals. We have negotiated settlements on tax matters for both non-docketed and docketed tax cases. Baker Botts tax lawyers are also well known to IRS exam teams, appeals officers and counsel and to the Department of Justice and are effective in working with them on settlements. We also have a strong record of advocacy in convincing appellate courts on tax positions.
Baker Botts income tax controversy and litigation lawyers represent large companies and high net worth individuals across the country in all manner of complex tax controversies before the IRS, at its Examination and Appeals divisions and its National Office, the Treasury, the Tax Court, Court of Federal Claims, federal district courts, courts of appeals, state courts and state taxing authorities.
We thoroughly evaluate the merits of complex tax issues and develop creative arguments in defense of proposed adjustments.
Our lawyers prepare detailed, persuasive 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. Our practice includes complex negotiations with the IRS relating to pre-filing agreements. When a tax controversy cannot be achieved administratively, our lawyers have substantial experience in tax litigation in all forums. Some cases are settled without the necessity of trial; however, we have tried many large cases involving sophisticated issues and high value controversy.
We also regularly advise energy clients on tax issues related to financial statements, including sensitive disclosure issues, FIN 48 reserves and negotiations with financial auditors.
Our lawyers see their role as your trusted advisor to help you identify and solve past problems and prevent future ones. We work best when we partner with your in-house tax team to jointly analyze problems and develop pragmatic solutions. We also help facilitate effective communication with the legal and business functions.
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News
Thought Leadership
IRS Opens Pre-Filing Registration Tool for Elective Payment or Transfer of Inflation Reduction Act and CHIPS Act Energy Tax Credits
Client UpdatesTax Update
New Reporting Regime under the Corporate Transparency Act Set to Take Effect on January 1, 2024
Client UpdatesCFTC Issues Proposed Guidance Regarding Voluntary Carbon Credit Derivative Contract Listings
Client UpdatesLitigation Update
Proposed Regulations Issued Regarding Section 48 Investment Tax Credit
Client UpdatesTax Update
Proposed Regulations Issued Regarding Direct Pay and Transfers of Clean Energy Tax Credits
Client UpdatesClean Energy Tax Update
Additional Guidance Released Regarding The Low-Income Community Bonus Energy Tax Credit Under Section 48(e) And The Advanced Energy Project Credit Under Section 48C
Client UpdatesClean Energy Tax Update
Inflation Reduction Act Guidance: IRS and Treasury Release Guidance on the Domestic Content Bonus Credit
Client UpdatesTax Update
Maryland Digital Ad Tax Struck Down
Client UpdatesTax Update
Inflation Reduction Act - Tax Controversy Perspective
Client UpdatesTax Update
Unique Tax Questions Posed by Cryptocurrencies and NFTs
Client UpdatesTax Update
Baker Botts Tax Controversy Update: Treasury "Greenbook" for Fiscal Year 2023 Revenue Proposals
Client UpdatesTax Update
Private Equity Industry Tax Increase Proposals Detailed in Treasury Greenbook
Client UpdatesTax Update
Corporate Perspective of Tax Proposals Detailed in Treasury Greenbook
Client UpdatesTax Update
International Tax Proposals Detailed in Treasury's FY 2023 Greenbook
Client UpdatesTax Update
Texas Tax Talk: The Comptroller’s Full Court Press in the Texas Supreme Court
Client UpdatesState and Local Tax Update
Rescinded Proposals for Major California Tax Increases
Client UpdatesTax Update
Proposed Major California Tax Increases
Client UpdatesState and Local Tax Update
Texas Tax Talk Exemption Win Signals Taxpayer Opportunity
Client UpdatesTax Update
Build Back Better Act - Tax Controversy Perspective
Client UpdatesTax Update
U.S. Tax Court Clarifies the Tax Implications of Generic Drug Litigation
Client UpdatesTax Update
Tax Controversy Update: Treasury “Greenbook” for Fiscal Year 2022 Revenue Proposals
Client UpdatesTax Update
Treasury's "Greenbook" - Corporate Tax Perspective
Client UpdatesTax Update
U.S. Treasury Publishes Plan to Close the "Tax Gap" and Raise $700 Billion
Client UpdatesTax Update
Tax Controversy Highlights from President Biden's American Families Plan
Client UpdatesTax Update
Biden Tax Plan May Reinstate Long-Expired Superfund Taxes
Client UpdatesESIR Update
Tax Highlights from Biden's American Jobs Plan
Client UpdatesTax Update
Tax Controversy Highlights from President Biden's Infrastructure Plan
Client UpdatesTax Update
Civil FBAR Penalties: The Possible (Over)Breadth of Willfulness
Client UpdatesTax Update
Following Passage of "Rescue" Legislation, Focus Shifts to Energy Tax Provisions
Client UpdatesTax Update
Stimulus Package Provides Additional Relief to Businesses Including New Paycheck Protection Program (PPP); SBA Alters Original PPP Rules and Adds Rules For New PPP
Client UpdatesSettlement Opportunities for Syndicated Conservation Easements
Client UpdatesTax Update
IRS Releases Final Regulations for TCJAs Changes to Settlement Deductions
Client UpdatesClient Update
DOJ Tax Announces Guilty Pleas in Abusive Syndicated Conservation Easement Cases
Client UpdatesTax Update
Proposed Stimulus Bill Would Extend Renewable and Clean Energy Tax Credits
Client UpdatesTax Update
New Energy Infrastructure Projects: Challenges and Opportunities in 2021 under a Biden Administration and Other Recent Developments
Client UpdatesEnergy Update
Final Regulations Issued Defining "Real Property" for Section 1031 Exchange Purposes
Client UpdatesTax Update
Baker Botts Quarterly Tax Controversy Update
Client UpdatesTax Update
Coronavirus Tax Response
Client UpdatesTax Update
IRS Looks to Third-Party Contractors in Crackdown on Virtual Currency Transactions
Client UpdatesTax Update
IRS Issues Long-Awaited Guidance on Deducting Government Settlement Payments after 2017 TCJA
Client UpdatesTax-White Collar Update
IRS Extends More Key Deadlines in Response to COVID-19
Client UpdatesTax Update
CARES Act: Opportunity to Monetize NOLs From Business Acquisitions Completed in 2018, 2019, or 2020
Client UpdatesCorporate Update
CARES Act Key Tax Relief Provisions
Client UpdatesTax Update
Tax Issues Related to COVID-19
Client UpdatesTax Update
Baker Botts Quarterly Tax Controversy Update
Client UpdatesEvents
Recent
TEI Houston Tax School
Baker Botts Event for Women in Tax, Featuring Myrtle Jones, SVP-Tax, Halliburton
Baker Botts Event for Women in Tax, Featuring Heather Crowder, Phillips 66, VP and General Tax Officer
Please join the women in tax at Baker Botts for the final virtual networking event of 2021 designed for women in-house tax professionals on Monday, December 13 from 11:00 a.m. - 12:30 p.m. CT.
TEI Houston Chapter Tax School
Baker Botts is a sponsor of the 2021 TEI Houston Chapter Tax School taking place the week of October 4, 2021 at the Hyatt Regency Houston.
Baker Botts Event for Women in Tax, Featuring Carla Howard, Vistra Energy, SVP-Tax
Please join the women in tax at Baker Botts for the the second of our networking events designed for women in-house tax professionals on Thursday, August 26 from 12:00 p.m. - 1:30 p.m. CT.
37th Annual Texas Federal Tax Institute Virtual Conference
Baker Botts Special Counsel Leah Davis Patrick will be speaking at the 37th Annual Texas Federal Tax Institute Virtual Conference on June 1, at 1:15 p.m. CT on the TCJA Enforcement Today.
TechGC DeputyGC Virtual Roundtable: Happy Tax Day!
Baker Botts Inaugural Event for Women in Tax
Please join the women in tax at Baker Botts LLP for the first of our networking events designed for women in-house tax professionals on March 4 at 10:30 a.m. CT.