Tax: Controversy & Fraud

Tax: Controversy - Nationwide


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THE FIRM This group has a deep and growing bench of experienced tax litigators which, alongside a significant depth of knowledge, positions it as one of the key practices in tax controversy work. Teams in Chicago, Palo Alto and Washington, DC make up this top-tier practice. Its expertise encompasses alternative dispute resolution, litigation, and cross-border controversy matters, and its sector experience incorporates a broad range of arenas, including pharmaceutical and aviation. Notable clients include Boeing, Mattel and Thomson Reuters.

Sources say: "They have a very good group of people." "The service was exceptional."

KEY INDIVIDUALS Chicago-based Mark Oates is a leading trial lawyer with extensive expertise in complex litigation, including tax fraud, criminal defense and international tax matters.

Gregg Lemein has an impressive knowledge of the federal tax system, and is known for his expertise in both domestic and multijurisdictional tax controversy work. He is also considered a go-to lawyer for inter-company pricing matters. "He is a tremendous lawyer; I have a great deal of respect for him," mentioned a peer.

James O'Brien is highly lauded for his experience with international controversy work and his superb corporate litigation skills. He is also highlighted for his expertise with transfer pricing issues.

Duane Webber is regarded as one of the luminaries in tax controversy. Clients speak highly of his practicality in resolving tax disputes, including in alternative dispute resolution techniques, and his innovative approach. He chairs the North America tax group and the firm's Washington, DC office.

Operating out of the firm's Palo Alto office, John Peterson boasts an impressive reputation as one of the strongest experts on the West Coast. He is highly regarded for his tax controversy work on behalf of hi-tech companies and startups. 

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THE FIRM With its impressive stable of leading lawyers, Bingham McCutchen's controversy team remains one of the foremost players in the arena. It remains a go-to group for an enviable client list, including GE, Dow Chemical and Santander as well as major names from both the domestic and foreign financial services markets. Bringing its superb expertise in cross-border controversy and transfer pricing to the table, it also represents leading names in the real estate, energy and technology sectors, among other areas. The firm also receives increased recognition for its burgeoning West Coast-based capabilities.

Sources say: "The quality of work at the firm is unparalleled." "They are highly competent and knowledgeable of the procedures."

KEY INDIVIDUALS John Magee is considered a dean of the tax controversy space, and wins acclaim for his tremendous depth of experience. He has a strong reputation in the field of transfer pricing and is considered a "world-class tax litigator." His major clients include Dow Chemical and Santander.

Raj Madan is praised for his ability to bring "an entrepreneurial, engaged spirit" to his representations. Highlighted as one of the sector's future stars, he is especially well versed in representing major financial institutions in tax controversy and litigation.

William Nelson is co-head of the firm's tax group. He is renowned for being both a versatile lawyer and excellent communicator. One client described him as "steeped in tax law, with extensive deal and litigation experience."

Sanford Stark is one of the team's go-to experts in transfer pricing issues and is actively sought after by several Fortune 100 companies. His practice also includes cross-border tax disputes, structures and accounting matters.

The tremendously experienced David Curtin is renowned for his ability in both civil and criminal trial cases. Within the practice area of tax controversy he is especially sought after for his experience as a former trial attorney in the Department of Justice's tax division.

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THE FIRM Latham & Watkins is highlighted for its high success rate in litigation and for devising innovative approaches to dispute resolution. In its dealings with the IRS, and in disputes involving REITs, the firm is praised as having unparalleled expertise. The group is also increasingly recognized for its expanding capabilities in fraud and Fair and Accurate Credit Transactions Act (FACTA) matters. Its recent highlights include representing Shea Homes before the US Tax Court in relation to long-term contract accounting methods used by home builders, a case with claims exceeding $600 million.

Sources say: "Latham displays good common sense and a working understanding of the law. Their track record has shown good judgment and wise counsel."

KEY INDIVIDUALS Miriam Fisher has in-depth knowledge of both criminal and civil tax actions, and at both a state and federal level. Her ability in highly complicated cases, especially those involving fraud, is often praised. She has an impressive client list from industries including energy and financial services, and has handled matters before the IRS, Department of Justice and state tax authorities.

Gerald Kafka chairs the firm's tax controversy practice group and its Washington, DC-based tax department. Described as "a very fine tax litigator," his recent highlights include leading in the Shea Homes matter.

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THE FIRM Mayer Brown's preeminent practice group undertakes all manner of tax controversy work, including transfer pricing, audits and local, state and international controversy matters. The team also has extensive trial and appellate experience. The firm's global scope and its strong working knowledge of international tax matters are especially lauded by market sources. Recent highlights include representing Eaton Corporation in US Tax Court litigation challenging IRS-asserted tax deficiencies in the company's transfer pricing of various Latin American manufactured products. Other key clients include Nestlé, Pepco and Tyco International.

KEY INDIVIDUALS Described as "a big gun" of the country's tax controversy arena, Joel Williamson recently led in the Eaton Corporation matter. In addition to his superb controversy and litigation skills, sources also highlight his expertise in international and cross-border matters.

Thomas Durham recently assisted in securing a major victory for Consolidated Edison of New York in a case involving leveraged lease transaction tax issues. He has tremendous expertise in tax-related litigation, including foreign tax, tax-advantaged investments and leasing engagements.

Working alongside him in the Consolidated Edison of New York case was the "very successful lawyer" David Abbott. He has a broad-ranging tax practice undertaking both transactional and litigious work.

Palo Alto-based Larry Langdon is able to combine in-depth experience in the field, having served as an IRS commissioner, with excellent working knowledge of federal tax law.

Thomas Kittle-Kamp is increasingly recognized as a major player in the nation's tax litigation arenas. With Abbott and Durham he recently represented Union Bank of California in a matter concerning leveraged leases of a major sports entertainment complex.

Scott Stewart is highlighted as an excellent name in tax disputes and transfer pricing. He recently played a key role on behalf of Tyco International in an appeal of IRS-proposed income adjustments to certain federal tax returns filed prior to its 2007 separation into Tyco, Covidien and TE Connectivity.

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THE FIRM Skadden continues to lead the pack with its superb capabilities in sophisticated tax litigation and controversy work. Its vast client roster includes major multinationals, financial institutions, governments, estates and individuals, among others. The group tables a tremendous amount of industry experience, with a significant number of its attorneys having been with the IRS or the Treasury. The team has also been increasingly active on inbound lending, particularly from sovereign wealth funds and other foreign investment sources. Recent highlights include representing BNY Mellon in a US Tax Court trial connected with reported foreign tax credits relating to a major cross-border financing.

Sources say: "I use Skadden on tax matters and I find them to be exceedingly competent experts in that area."

KEY INDIVIDUALS Kenneth Gideon is a preeminent figure in the tax litigation space, and remains a leading figure in all types of tax controversy and planning representation. He also maintains a sterling transactional tax practice. He recently represented Transocean in successfully securing a concession before going to trial in significant transfer pricing litigation in the US Tax Court.

Co-head of the firm's tax group, Fred Goldberg wins superb praise from his peers. He has a leading reputation for the most complex of tax controversy issues, and has extensive experience in IRS and administrative dealings.

Another of the firm's sector-leading authorities, John Williams is a renowned expert in tax litigation and controversy work. "A terrific litigator," he undertakes a range of IRS, administrative and federal court engagements. He has continued his high-profile representation of CIGNA in a precedent-setting US Tax Court trial.

Palo Alto-based Julia Kazaks is a key figure in the firm's increasingly recognized West Coast practice. She is considered a very strategic and incisive litigator, and acted in the BNY Mellon case alongside Williams and Alan Swirski. Swirski has an impressive track record in litigation and tax controversy matters, and sees a number of IRS challenges through to success.

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THE FIRM McDermott has drastically increased its national tax controversy capabilities with the arrival of a sizable transfer pricing team in Texas. The additions bolster the firm's sterling controversy practice spanning California, Chicago, New York and Washington, DC. The group's expertise covers a range of litigation, audits and appeals, international controversy, and state and local tax issues, among other matters. It recently secured an impressive success for Home Concrete & Supply in a significant IRS dispute in the Supreme Court.

Commercial Awareness "They provide a lot of good market knowledge."

KEY INDIVIDUALS Thomas Borders is described as "bright, capable and not afraid of a fight." He has a superb reputation for expertise in all manner of tax litigation, including federal tax controversy and criminal investigations.

Peter Faber is highly respected as a state and local tax expert, particularly in controversy and tax planning matters. His key clients include Morgan Stanley and Goldman Sachs.

Roger Jones is a recent addition to the firm's controversy team from Latham & Watkins. Sources highlight his superb ability to remain "three steps ahead" of the competition in a range of major controversy matters on behalf of taxpayers. He was involved in the recent landmark Home Concrete & Supply case in the Supreme Court.

Washington, DC-based Jean Pawlow leads the firm's national tax controversy practice group. She is a go-to expert for a range of issues, and recently represented Discover, a large credit card company, in tax controversy matters relating to income from interchange fees. 

Also based in Washington, DC, Michael Kelleher's solid expertise extends to transfer pricing and particularly complex federal income tax cases. He has continued his role on behalf of Securitas in significant tax court litigation.

Senior counsel William Goldman is an incredibly well-respected figure in the country's legal landscape. A highly experienced lawyer with a well-deserved reputation, he has handled all manner of federal and state controversy engagement.

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THE FIRM This firm has a strong national tax controversy practice group, comprising experts in Atlanta, New York and Washington, DC. While offering a broad-ranging controversy and litigation practice, the team is best known for its excellence in state and local controversy matters. The group has also benefited from the arrival of a number of experts from Dewey & LeBeouf. Its impressive client roster includes Coca-Cola Enterprises, Kraft Foods and GM.

KEY INDIVIDUALS Jerold Cohen wins high praise for his extensive experience in domestic and international tax controversy work. He is also much sought after for his expertise in tax planning.

Practice group chair Jerome Libin is an expert in an array of international and domestic tax controversy issues. He is particularly recognized for his knowledge of tax planning and transfer pricing, as well as general corporate taxation matters.

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THE FIRM This boutique firm has enjoyed an impressive year of expansion, both in its workload and presence, and strengthened its position as a formidable group for a whole host of tax controversy and litigation. Its expertise covers the gamut of international tax controversy, criminal tax and international tax engagements. It also comes highly recommended for its capabilities in fraud.

Sources say: "The quality of work has been outstanding." "A talented and very good firm."

KEY INDIVIDUALS Scott Michel "is simply the best. Truly exceptional." He is a very highly regarded tax controversy and tax fraud lawyer who has received consistent praise from clients. He has also developed an expertise on the voluntary disclosure program offered by the IRS to US citizens with Swiss bank accounts.

Cono Namorato is highly regarded as a criminal tax lawyer specializing in tax fraud. He has a reputation for expertise in issues arising on offshore accounts.

David Rosenbloom is considered the foremost legal mind in complicated international tax planning and tax controversy matters and has "been engaged as an expert witness in at least four or five countries including Canada, Australia and India." His formidable expertise has led to him being labeled "his firm's leading light."

Christopher Rizek is a civil tax dispute expert enjoying a great reputation in tax controversy for both individual and corporate clients. His areas of expertise include tax shelter penalties, debt tax accounting and the auditing of high net worth individuals.

Mark Matthews is described as "one of the leading minds in criminal tax fraud." He has held positions in the IRS, FBI and CIA, and so brings a wealth of experience to clients' issues.

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THE FIRM Operating out of offices in Atlanta, Houston and Philadelphia, this firm has a notable national reputation for tax litigation. Its broad-ranging practice encompasses local, state and federal tax disputes, as well as criminal and civil tax controversy work. The group is also highlighted for occupying a strong niche in tax controversy relating to business-owned aircraft. Its impressive roster of recent clients includes Western Refining, Inamed Corporate and Colorcon.

KEY INDIVIDUALS Houston-based Larry Campagna is a highly respected litigator with in-depth expertise in fraud, state and local tax controversies, as well as general business litigation. He recently led the team acting for Western Refining in a $10 million tax court case relating to credits connected with upgrading facilities to produce ultra-low-sulfur diesel fuel. 

In Atlanta, David Aughtry is lauded as a "leading practitioner within the tax controversy area." He has a solid practice undertaking federal tax litigation and controversy, and "has more courtroom experience than anyone in Atlanta," say sources. 

Based in the Philadelphia Metro area, the "very capable" Philip Karter has strong expertise in tax controversy work, and excellent courtroom skills. He is considered a solid choice for large corporate issues.

Herbert Odell is a multitalented controversy lawyer highlighted for his ability to combine both tax controversy and tax planning work. 

Juan Vasquez is highlighted for his handling of federal, state and local tax controversies. He is also noted as a practitioner with great energy and excellent client focus.

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THE FIRM New York-based Kostelanetz & Fink has an enviable national reputation for representing a range of major clients in civil and white-collar criminal tax litigation. Market sources continue to highlight the group's expertise with foreign disclosure and offshore disputes, and its excellence in IRS-related litigation. 

Sources say: "They demonstrate a high level of efficiency and expertise."

KEY INDIVIDUALS Clients consider Robert Fink to be one of the most responsive legal minds in the practice area. He has a reputation for being incredibly knowledgeable of the intricacies of tax controversy, as well as for his broad civil and criminal tax, and white-collar defense practice.

Bryan Skarlatos is able to combine an excellent knowledge base, extensive experience, great contacts and an unparalleled reputation for achieving client goals. He undertakes a diverse range of white-collar, civil and criminal tax and voluntary disclosure issues, among other matters. 

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THE FIRM Operating out of the firm's head office in Washington DC, Miller & Chevalier offers a wide range of legal services in the tax controversy practice area. The firm has established itself as one of the foremost for issues relating to transfer pricing, cross-border transactions, and complex partnership-related matters. Its practice also has an impressive record in criminal tax cases.

Sources say: "They're outstanding lawyers, an excellent law firm, and a pleasure to work with. Quality people. They have a long history of exemplary work in tax and tax controversy."

KEY INDIVIDUALS Kevin Kenworthy is noted as "a top litigator" by peers, and has an impressive reputation for particularly complex tax controversy work.

Alan Horowitz is renowned for his successful federal appellate tax work, and for his ability to take on the IRS and win.

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THE FIRM Fulbright & Jaworski enjoys an excellent reputation for all types of tax law engagements, including state, federal and local. The Texas-based firm is renowned for its expertise in real estate and oil and gas, among other sectors. The tax controversy team undertakes litigation, tax shelter, gift tax, criminal investigations and IRS audits. Its clients include AT&T, the Armand Hammer Foundation, and Prospector Offshore Drilling.

KEY INDIVIDUALS Jasper Taylor has a nationally recognized tax litigation and controversy practice, acting on behalf of clients from an array of industries, including energy, real estate and telecom. He has experience before both the IRS and the US Tax Court.

Of counsel Charles Hall is described as "a phenomenal tax lawyer," and is highly regarded for his tax controversy expertise and impressive record of successful dealings with the IRS. 

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THE FIRM Steptoe & Johnson's superb team in Washington, DC continues to gain recognition for providing a strong and cohesive tax controversy and litigation practice. It handles all manner of administrative and tax shelter controversies, as well as IRS appeals and audits, and has seen particular growth in insurance and foreign tax haven-related controversies. Its recent highlights include representing John Hancock Financial Services in a US Tax Court dispute with the IRS relating to the treatment of certain leveraged leases. Key clients also include Liberty Global, and Eastman Kodak.

Sources say: "They are very skilled at negotiation with the IRS, strategy and tax litigation."

KEY INDIVIDUALS Arthur Bailey is considered an excellent tax litigator. His practice extends to disputes relating to cross-border investments and life insurance. He led in the John Hancock Financial Services matter.

Walker Johnson has a strong practice covering tax controversy and litigation, as well as tax planning. Sources also highlight his expertise in financial, life insurance and investment tax matters.

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THE FIRM DLA Piper enjoys an increasing profile for its capabilities in representing clients at federal, state and local levels. The firm is lauded for its ability in all areas of tax controversy, including appeals, litigation, and audits. The firm is also well regarded for its ability to deal with criminal tax investigations and also to mediate with the IRS.

Client Service "Top quality work, experts in their matter and very good with clients."

KEY INDIVIDUALS New York-based Ellis Reemer leads the firm's tax controversy and tax litigation practice group. He is praised by clients for having "very good business sense – not just straight legal considerations. He balances out business needs in a way that is extremely practical." He has a stellar reputation for dealing with the IRS on audit matters and mediation.

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THE FIRM Morrison & Foerster has recently seen substantial growth in tax controversy matters relating to bankruptcy. The firm can call upon impressive knowledge relating to complex financial instruments and has extensive experience in tax litigation. Its capabilities are especially lauded in state and local tax controversy issues, as well as in federal engagements. The team's recent highlights include representing the Official Unsecured Creditors' Committee of Ambac in the US tax aspects of the company's high-profile bankruptcy proceedings.

Client Service "There is always someone available to address any problems or issues that might arise. The firm has always been very responsive."

Commercial Awareness "I would regard their commercial sense as high – they have an excellent understanding of our business and the issues therein."

KEY INDIVIDUALS Edward Froelich is a rising name in the tax controversy arena. He recently played a key role in the firm's representation of the Official Unsecured Creditors' Committee of Ambac. 

Paul Frankel is a nationally renowned practitioner highlighted as a superb attorney in state tax issues. He has an impressive track record in litigation and a very good reputation for both state and local tax controversy.

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THE FIRM Pillsbury Winthrop maintains an excellent reputation for handling federal, state and local tax disputes. It acts on behalf of a broad variety of multinational corporations and individuals, and remains well known for its expertise in real estate tax issues. Its impressive docket of recent work includes its representation of the Archdiocese of San Francisco in a $22 million tax dispute with the City and County of San Francisco. Other key clients include Amazon, AT&T and Apple.  

Client Service "They have excellent timeliness in responding, expertise in the subject matter, relevance to the subject matter, and a professional approach." "We have found Pillsbury’s client service to be very good."

KEY INDIVIDUALS William Bonano "is very intelligent and able to elucidate the argument in an articulate, simple manner that makes sense," say clients. He is also commended for his knowledge of transfer pricing and relating that to the software industry.

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THE FIRM Vinson & Elkins maintains its enviable strength in tax controversy, and has also earned a reputation for excellence in transfer pricing. The firm is frequently a first choice for offshore drillers, and has a wealth of both expertise and experience in dealing with the IRS on behalf of energy and oil and gas companies. Its recent highlights include acting for Transocean on tax disputes with the IRS relating to the company's 2006-2009 federal income tax returns. Clients also include Halliburton, 7-Eleven and the University of Texas.

KEY INDIVIDUALS Based in Houston, George Gerachis leads the firm's tax and employee benefits and executive compensation practice group. Highlighted by peers for his superb tax controversy practice, he enjoys a strong record of success against the IRS and a reputation for navigating particularly complex matters.

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THE FIRM White & Case's tax controversy group has eight tax experts well placed to handle both domestic civil and international tax controversy issues. The firm's global platform makes it an ideal choice for cross-border matters, and it comes highly recommended for transfer pricing.

Sources say: "They are excellent, always very professional, and always keep to their deadlines."

KEY INDIVIDUALS Washington, DC-based Michael Quigley leads the firm's tax controversy and litigation practice group. He has been especially active in transfer pricing matters involving Korean clients and jurisdiction.

Brian Gleicher "stands out for his efforts to know and understand his clients' businesses and always has a thorough understanding of the issues involved, no matter the situation," say sources. He has an excellent international tax practice focusing on transfer pricing and tax treaty work.

Other Ranked Lawyers 其他上榜律师

Houston-based Richard Husseini chairs the tax practice group at Baker Botts LLP. He has both a transactional and controversy practice acting for key clients in the oil and gas industries. He is also highlighted for his expertise with new energy sources, including solar, wind and shale gas.

John Porter at Baker Botts LLP in Houston is a tremendously experienced tax controversy expert. He comes especially recommended for his strong niche in gift and estate litigation.

Leader of the tax controversy practice group at Cooley LLP in New York, Stephen Gardner is renowned among fellow practitioners for his great expertise in the field. He recently successfully led on behalf of Entergy in a Fifth Circuit case relating to the company's claim for nearly $250 million in foreign tax credits related to the UK's windfall tax.

Kathleen Pakenham in New York chairs Cooley LLP's tax litigation practice. She has in-depth knowledge of tax shelters and a solid reputation for undertaking issues revolving around valuation disputes and foreign taxes.

Harold Heltzer leads the tax practice group at Crowell & Moring LLP in Washington, DC. He is described as "very knowledgeable and thorough – a go-to person when you are dealing in the audit and appeals process." He has extensive experience acting before the IRS.

Dallas-based Todd Welty leads the tax controversy and litigation practice at Dentons. He comes highly recommended for his civil and criminal tax controversy expertise.

Barbara Kaplan leads the tax practice at Greenberg Traurig, LLP. She is described as "an expert attorney in international as well as domestic tax fields," say sources. Her practice encompasses a range of federal, state and local tax and tax controversy matters, litigation and examinations.

Charles Rettig of California-based Hochman Salkin Rettig Toscher & Perez is highlighted as "hands-down, the best for litigation" in the tax space. His practice encompasses a range of general tax litigation, controversies, investigations and audits, among other matters.

Natalie Keller of Kirkland & Ellis LLP is applauded for her knowledge of tax controversy and understanding of the litigation process. She has gained a reputation in transfer pricing, IRS audits, and in overcoming issues related to tax compliance.

Chicago-based Todd Maynes of Kirkland & Ellis LLP is described as "one of those standout individuals in whom you have total faith that he is giving great advice." His practice is especially active in tax litigation, debt restructuring and bankruptcy matters.

Michael Desmond of The Law Offices of Michael J. Desmond is a sole practitioner who brings near-unparalleled experience in the field, having worked in the Treasury Department and the IRS. He is a distinguished name in tax controversy work.

William Colgin of Morgan, Lewis & Bockius LLP has an impressive reputation for tax controversy work and IRS audits. He has extensive experience of appeal work arising out of both litigation and audits and has acted for several Fortune 500 clients.

The up-and-coming Caroline Ciraolo of Rosenberg Martin Greenberg, LLP is a well-known name in the tax fraud arena. Her expertise in both civil and criminal tax litigation is matched by her breadth of experience at both a federal and state level.

Washington, DC-based Thomas Johnston of Shearman & Sterling LLP has expertise in tax controversy and the interrelation of foreign tax credits with domestic tax legislation. He remains a key attorney for an impressive list of clients, including Ford.

Lawrence Hill joined the New York office of Shearman & Sterling LLP from Dewey & LeBeouf in 2012. He specializes in IRS controversies and litigation work across the board. His practice also includes white-collar investigations.

Matthew Lerner recently joined Sidley Austin LLP from Steptoe & Johnson LLP. Lerner has an excellent practice encompassing complex tax controversy and fraud matters.

Donald Korb splits his time between the Washington, DC and New York offices of Sullivan & Cromwell LLP. He brings a unique level of experience to his representations as a former Chief Counsel for the IRS. He now leads the firm's tax controversy practice group.

Jack Townsend operates out of the Houston office of the tax boutique Townsend & Jones. He is highly skilled in litigation and negotiations with the IRS, and is lauded by sources as "a professor as much as a partner" in the tax controversy space. 

The "outstanding" James Bruton of Williams & Connolly LLP is lauded as one of the country's leading experts in tax fraud. He operates out of the firm's Washington, DC office and has tremendous experience in acting on cases at every stage of the tax litigation process.

Seth Farber of Winston & Strawn LLP is a versatile litigator with an impressive success record in litigation for tax fraud. He leads the firm's New York-based litigation practice group, and also maintains a strong reputation for white-collar and appellate matters.

The highly experienced trial lawyer Paula Junghans of Zuckerman Spaeder LLP is commended by sources for her superb knowledge of tax litigation and white-collar crime matters, and for her excellent judgment. She is a "top-notch" player in the sector.

Foreign Experts

Foreign Experts are individuals with expertise in a different jurisdiction to the one they are based in. These individuals are particularly highly regarded for international and cross-border work. Usually, they will be identified in the jurisdiction in which they are based and in their country of expertise.