Davis Polk & Wardwell has long placed great emphasis on its tax litigation practice. The firm’s Tax Controversy Group includes partners, senior counsel, counsel and associates from Davis Polk’s Tax and Litigation Departments. These controversies involve partnership taxation; debt-equity issues; international taxation; intercompany pricing; interest capitalization and allocation; accounting for bad debts; amortization of intangibles; withholding taxes; foreign tax credit issues; and deductibility of takeover and divestiture expenses. Our tax controversy clients include domestic and foreign banks and financial institutions; insurance, pharmaceutical and medical companies; communications and technology companies; food and beverage and consumer product companies; and partnerships and corporations engaged in research, manufacturing and communications. We regularly negotiate settlements with the Internal Revenue Service, involving billions of dollars of disputed taxes.
 |
 |
