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We advise businesses and high net-worth individuals in high-stakes tax disputes, helping them navigate audits, appeals, and litigation with practical strategies aligned with their business and personal objectives.
Procopio’s Tax Controversy group advises businesses, investment funds, and high net-worth individuals in complex disputes with the Internal Revenue Service, the California Franchise Tax Board, and other taxing authorities. We represent clients at every stage of a controversy, from the initial contact by a taxing authority through audit, administrative appeals, and litigation.
Our approach is grounded in experience and practical judgment. Led by former Internal Revenue Service counsel, our team understands how tax authorities evaluate issues and pursue enforcement, allowing us to anticipate positions, shape strategy early, and guide matters toward efficient resolution.
We are often brought in at critical moments, including when a client is under audit, facing a residency challenge—in particular, with Puerto Rico—or addressing tax exposure arising from a transaction. Our experience includes disputes involving post-closing tax matters, allocation and indemnification issues, and the defense of tax positions taken in connection with mergers, acquisitions, and other business transactions.
We also have significant experience in California residency audits and cross-border tax disputes. Our team regularly represents clients in matters involving multi-jurisdictional issues, including U.S.–Mexico matters and disputes tied to international reporting obligations and residency determinations.
Throughout each matter, we focus on practical, efficient strategies that align with our clients’ broader business objectives. That includes managing risk early, avoiding unnecessary escalation where possible, and deploying resources in a disciplined manner to achieve the best outcome.
We represent clients in disputes with the Internal Revenue Service at all stages, from audit through litigation.
We handle disputes with state and local taxing authorities, with a particular focus on California matters.
We advise and represent clients in residency challenges, including complex and high-exposure matters.
We represent clients in disputes arising from business transactions, including post-closing matters and tax-related conflicts.
We advise U.S. and foreign clients on disputes involving international tax issues and reporting obligations.
We represent high-net-worth individuals and families in disputes involving transfer taxes.
We advise clients on evolving and highly specialized tax controversy matters.
As early as possible. Many issues can be shaped or resolved during the audit phase. Early involvement allows for better positioning, more strategic communication with taxing authorities, and often a more efficient path to resolution.
It is important to respond promptly and thoughtfully. We work with clients to assess the scope of the inquiry, preserve relevant information, and develop a strategy for engaging with the agency before the matter escalates.
Most matters begin with an audit or examination, followed by administrative appeals if necessary. Some disputes are resolved at those stages, while others proceed to litigation. We advise clients throughout the process and adjust strategy as the matter evolves.
Often, yes. Many matters can be resolved through negotiation or administrative appeals. We focus on identifying opportunities for resolution early, while preparing for litigation where necessary to protect our clients’ positions.
We take a disciplined and strategic approach, focusing on the issues that will have the greatest impact on the outcome. This includes developing a clear position, managing communications with taxing authorities, and aligning the strategy with the client’s broader business objectives.
We focus on efficient resolution strategies, prioritizing key issues and avoiding unnecessary escalation where possible. Our goal is to deploy resources thoughtfully while maintaining a strong and credible position throughout the matter.
Disputes often arise from transactions, including mergers, acquisitions, and restructurings. We represent clients in defending tax positions taken in those transactions, as well as in post-closing disputes involving tax allocations, indemnification, and return preparation.
Tax residency audits determine where a taxpayer is considered to reside for tax purposes, which can have significant financial implications. These matters are often fact-intensive and require careful coordination of legal, tax, and factual positions.
We advise on disputes involving multiple jurisdictions, including treaty-based issues, reporting obligations, and cross-border transactions. We work with our international tax team and foreign advisors to coordinate strategy and ensure consistency across jurisdictions.
We represent businesses, investment funds, and individuals in complex disputes, including matters involving closely held companies, cross-border operations, and high-value transactions.
Companies often reassess counsel when a matter becomes more complex, involves multiple jurisdictions, or requires litigation. This is particularly relevant when strategic coordination is needed across audit, appeals, and court proceedings.
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