Practice Areas & Industries: Winston & Strawn LLP

Practice/Industry Group Overview

Winston & Strawn's tax controversy practice is involved in representing our clients interests at all administrative and judicial levels.  Our tax attorneys have presented, negotiated, and resolved hundreds of cases with IRS appeals offices around the country, and the scope of our appeals practice covers virtually every taxpayer-contested issue.  We also regularly represent clients in tax matters before the U.S. Tax Court, the U.S. Court of Federal Claims, and federal district courts.  When necessary we handle cases for clients in the federal circuit courts of appeal and the U.S. Supreme Court.

Our tax controversy attorneys represent public and significant privately held corporations, exempt organizations, and large estates in administrative and judicial proceedings against the IRS with respect to:

• Corporate reorganization and merger issues
• Alleged tax shelter transactions
• Challenges to leasing transactions (including
• LILO and OFSC transactions)
• Debt/Equity classifications
• Capitalization of costs under Section 263A
• Capitalization of environmental expenses
• Conduits and U.S. withholding tax issues
• Section 482 allocations
• Intangible asset valuation and amortization
• Section 269 and 382 issues
• Section 263 Cap A issues
• Employment tax issues
• Challenges to captive insurance premium deductions
• Challenges to COLI insurance programs
• Challenges to securitization transactions
• Challenges to S corporation status
• Challenges to federal estate tax return positions

Representative Matters

Soka University Property Tax Litigation
Soka University
Winston & Strawn tax attorneys represented Soka University in litigation against the county of Los Angeles, California, and the state board of equalization in which the University sought a refund of property taxes assessed to Soka’s campus.      
 
Federal Tax Controversy Matters
Winston & Strawn's tax controversy practice is involved in representing our clients interests at all administrative and judicial levels.      
 
Appellate Cases - Tax
Our attorneys have handled appeals involving a variety of legal issues, including those in the tax law area.