Deloitte Tax Controversy Services

Broad-based, scalable, tailored for each client

Deloitte Tax Controversy Services provide assistance spanning the various stages of IRS, state, and local examinations, from dispute avoidance to issue resolution and post-exam improvements. Through decades of working with clients on a broad range of tax issues, we have fine-tuned our technology, analytical procedures, and planning methodologies to offer a broad-based, scalable solution that we can tailor to the specific circumstances of each client and each tax controversy.

What to expect from Deloitte Tax Controversy Services

Every tax controversy is unique; almost all are urgent and inconvenient. Precisely for these reasons, Deloitte Tax Controversy Services provides a team and a solution tailored specifically to each client’s controversy, drawing from our network of highly experienced, knowledgeable specialists from diverse backgrounds—former senior IRS and state executives, chief counsel officials, federal and state litigators, auditors, private industry tax executives, and technology specialists. Given the depth and breadth of experienced individuals on our team, we can ramp up and move quickly with the skills, processes, and well-established business relationships to expediently bring about a satisfactory solution.

Our close working relationships, credibility, and familiarity with tax agency teams and decision makers across the country enables us to quickly assess a situation, establish a tailored solution, and work efficiently with the
appropriate agencies. We also understand the importance of key internal communications and can help tax professionals keep executives informed throughout the process, from explaining the controversy to outlining the resolution and protections established to limit future controversies.

Our deep understanding of tax controversy, strong credibility and working relationships with tax agencies, and “in the trenches” knowledge of what it takes to avoid, manage, and learn from the various types of tax disputes translates to value to our clients in the following ways.

Pre-controversy audit readiness

The right experience to help you identify areas that could raise issues and prepare to respond quickly to information requests; the credibility and strong working relationships to communicate effectively with tax agency examiners.


Valuable day-to-day consultation; effective representation at tax agency meetings; analysis of proposed adjustments informed by comparable case experience; guidance resolving issues based on understanding of specific tax agencies and examiners; and reliable verification of final tax, penalty, and interest amounts.

Litigation, appeals, and settlement

The relevant case experience to analyze the strengths and weaknesses of the government’s position and a company’s position. The deep knowledge of administrative and appeals procedures—as well as the information and document management tools—to move the process forward as quickly and smoothly as possible. The technical tax, risk analysis, and finance skills to address IRS and state requests promptly and effectively. The negotiation skills and experience to facilitate favorable outcomes.

Proactive resolution services

Valuable, informed guidance on dispute resolution options and the broad range of decisions and issues that may arise—refund claims, statute of limitations issues, closing agreements, technical advice requests, federal 9100 relief filings, letter rulings, alternative apportionment, and voluntary disclosure initiatives.

Transfer pricing

Help establishing defensible transfer pricing practices, policies, and documentation. Deeply informed strategic and tactical assistance for defending transfer pricing before state and federal tax authorities.

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Meet our experienced team

The Deloitte Tax Controversy Services team advises clients through an extensive network of highly knowledgeable and experienced specialists who bring key skills and working relationships from diverse backgrounds—as lawyers formerly with large law firms, IRS Chief Counsel, state counsel, in-house attorneys, tax authority officials, alternative dispute resolution specialists, and tax litigation specialists for multinational businesses. We welcome the opportunity to talk with you more about how we can help you resolve, defend, and actively manage global, federal, and multistate tax controversies. Contact our leadership team.

Get in touch

Jack Trachtenberg
Principal | Deloitte Tax LLP
+1 212 436 4324

Rosemary Sereti
Managing Director | Deloitte Tax LLP
+1 202 220 2118

Dr. John M. Wells
Principal | Americas Transfer Pricing Leader
+1 214 840 7558

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