Tax Controversy & Dispute Resolution Services

A coordinated approach to tax controversy for multinationals

The market is quickly transforming, and tax disputes are on the rise domestically and globally. Every day, companies face inquiries and audits by a variety of revenue authorities, upending their business operations and taking a toll on their resources and financials.

This heightened activity is due to a flurry of recent events, including the ongoing implementation of the OECD’s base erosion and profit shifting project, the proliferation of unilateral digital services taxes due to a lack of global consensus on how to tax the digital economy, new IRS initiatives, emboldened IRS enforcement activities as a result of recent high profile court victories and jurisdictions around the world dealing with mounting debt.

And, with this rise in the volume of tax disputes, data-driven, tech-enabled approaches to manage and mitigate controversy have become a business mandate.

What we do

We’re here to help clients prevent disputes before they arise, manage controversies which may arise, and resolve challenges by tax authorities in an efficient and effective manner. We combine technology with human capabilities, leverage data analytics and cloud-based technology, for clients who are inundated by tax audits.


Mark R. Martin

Mark R. Martin

Principal, Head of Tax Controversy & Dispute Resolution, Washington National Tax, KPMG US

What sets us apart

The Tax Controversy & Dispute Resolution Services group is a national practice within the firm's Washington National Tax office, made up of cross-disciplinary professionals with extensive controversy and dispute resolution experience in federal tax, transfer pricing, and state and local tax as well as tax authority practice, procedure, and administration.

Our strategic guidance and counsel come from a broad network of experienced practitioners and former tax authority officials, several of whom have prior experience working for the IRS and Multistate Tax Commission in key roles. Our highly skilled tax professionals are then paired with enabling technologies. Through the use of predictive technology tools, data mining & analytics, and the knowledge and experience of our professionals, we offer a holistic approach to anticipating, managing and resolving controversies and disputes.

By working closely with our extensive global network of KPMG International firm dispute professionals, we can provide a consistent approach to disputes based on extensive local knowledge and help you manage your global controversy portfolio effectively.

Our team’s diverse advisory experience is fortified by a suite of KPMG tax technology tools that can help model the impact of resolution paradigms and settlement offers, while tracking and managing process flows. These capabilities are increasingly important as the complexity and frequency of disputes continue to rise.


How we can help

Our approach is designed to provide you with a single, centralized team of specialists who can represent you in complex disputes across disciplines, no matter where controversies arise. Coupled with our outstanding understanding of tax authority practices, our team works to help you achieve positive outcomes and obtain strong results throughout the tax dispute continuum.

Our Tax Controversy & Dispute Resolution professionals can help your organization in a variety of areas. Among them are:

  • Audit readiness, including the use of proprietary risk assessment tools
  • Pre-filing assistance including pre-filing agreements and rulings
  • Examination assistance, including assistance with the IRS Compliance Assurance Process (CAP) and the International Compliance Assurance Program (ICAP)
  • Alternative dispute resolution programs, including IRS Fast Track Mediation/Settlement
  • IRS Appeals and Post Appeals Mediation
  • Competent Authority cases addressing permanent establishment, transfer pricing and other treaty issues, as well as accelerated competent authority assistance where available
  • Advance pricing agreements (APAs), including APAs with rollback, unilateral APAs, bilateral APAs and synthetic bilateral APAs.


Global Dispute Resolution & Controversy Services

Washington National Tax