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.

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.

 

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.

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.

 

Mark R. Martin

Mark R. Martin

Co-Principal in Charge, Tax Controversy & Dispute Resolution, KPMG US

Sharon Katz-Pearlman

Sharon Katz-Pearlman

Co-Principal in Charge, Tax Controversy & Dispute Resolution, KPMG US

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; and
  • Advance Pricing Agreements (APAs), including APAs with rollback, unilateral APAs, bilateral APAs and synthetic bilateral APAs