International Tax Controversies

Kostelanetz frequently advises multinational corporations, high-net-worth individuals, and U.S. and foreign entities with U.S. tax obligations on international tax controversies, U.S. and foreign governmental investigations, and cross-border transactions.

Our firm has extensive experience addressing cross-border tax matters, such as inbound and outbound transactions, foreign trusts and foundations, foreign tax credits, foreign reporting obligations, and the impact of the 2017 Tax Cuts and Jobs Act (TCJA) in the areas of transfer pricing, Global Intangible Low-Taxed Income (GILTI), and the Base Erosion Anti-Abuse Tax (BEAT).

Kostelanetz offers tailored strategies for businesses and individuals facing global tax challenges and works diligently to safeguard our clients’ financial interests using our extensive knowledge of compliance regimes under U.S and international tax laws. Our attorneys also serve as consultants and expert witnesses for other firms and legal, tax, and accounting professionals seeking guidance and opinions regarding complex international tax issues.

Approximately half of the firm’s legal team has significant government experience, including a former Acting Assistant Attorney General of the Department of Justice (DOJ) Tax Division, a former Chief of the IRS Criminal Investigation, several attorneys with experience in the IRS Office of Chief Counsel, a former Special Trial Attorney for the IRS Office of Chief Counsel in New York, several attorneys with criminal and civil DOJ Tax Division experience, and several former Assistant United States Attorneys. As a result, Kostelanetz attorneys are fully familiar with the practices of the IRS, the DOJ, and other taxing authorities. 

Our attorneys frequently speak on and write about international tax issues and serve as adjunct professors in the Georgetown University Law Center’s Tax LL.M. program for a course on International Tax Controversies.