Tax litigation support
Complex tax disputes (deduction eligibility, timing differences, transfer-pricing documentation, and civil or criminal fraud investigations) benefit from experts who can translate code and regulations into plain-language opinions tied to the underlying books.
Experts may critique opposing positions, assist with penalty defenses, and help counsel frame discovery targeted at workpapers and reconciliation schedules.
Related topics
| Phase | What We Do | Deliverable |
|---|---|---|
| 1. Issue Framing | Translate legal posture into tax accounting questions | Issue tree |
| 2. Workpaper Review | Trace positions to returns, elections, and supporting files | Reconciliation schedules |
| 3. Authority & Method | Document statutory and guidance basis for conclusions | Legal-technical memo |
| 4. Testimony | Present calculations and rebut opposing tax expert | Tax expert report |
Frequently asked questions
What role does an accounting expert play in tax litigation?
What role does an accounting expert play in tax litigation?
Experts reconcile tax positions to general ledger and sub-ledger detail, evaluate reasonableness of transfer-pricing documentation, and explain whether books support reported positions.
Can the same expert address civil fraud penalties and liability?
Can the same expert address civil fraud penalties and liability?
Scope must be defined carefully. Experts typically opine on accounting facts and reconstruction of income or deductions; legal conclusions on fraud or penalties remain for counsel and the trier of fact.
What records are essential in tax disputes?
What records are essential in tax disputes?
Tax returns, workpapers, trial balances, intercompany agreements, and source invoices for challenged deductions allow experts to test positions against contemporaneous books.
How early should counsel retain a tax litigation expert?
How early should counsel retain a tax litigation expert?
Early retention improves discovery requests for workpapers and helps counsel assess whether opposing schedules are reproducible from underlying data.
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