Tax Litigation and Controversy
eCom Sellers face different tax challenges from other businesses. Our firm offers solutions when state tax collectors “get it wrong.”
As tax laws shift and evolve, businesses now more than ever require sophisticated tax advice to effectively navigate all types of complex tax matters — formation, operations, sales tax, income tax, VAT, personal property tax, and even ad valorem tax — and their bottom-line impact. We can help. Francissen Rafelson Schick’s Tax Team provides proactive counseling and strategic tax planning solutions to clients based throughout the U.S. and in Europe, Asia, and beyond.
We provide our clients with clear, effective, and innovative tax advice on their transactions and operations so they can efficiently plan and manage their U.S. and foreign tax consequences.
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FRS’s tax practice has handled virtually every type of state and federal tax controversy before state and federal administrative agencies and courts. Our matters include numerous cases in state trial and appellate courts and federal district and appellate courts, the Court of Federal Claims, and the United States Tax Court. We help our clients avoid tax litigation but are prepared to successfully represent them when forced to try a tax case.
Our tax controversy team handles cases for corporate, individual, trust, and partnership taxpayers. These cases involve issues arising across all industries and financial or investment activities. Our tax controversy representation has involved issues related to tax accounting, inventory, R&D, valuation, reasonable compensation, deductibility of captive insurance premiums, and debt versus equity determinations, among others.
We have represented clients and argued cases in numerous major state tax matters related to issues including sales and use tax, intangible personal property taxes, and corporate income tax. We have argued cases at the administrative hearing level through the highest state courts.
Read Our Insights on Tax Law
Amazon’s Notice That They Are Turning Over Your Company Data: Now What?
The New California Sales Tax & What Amazon Sellers Can Do On October 23rd, 2018, Amazon sellers received a notice from Amazon stating that the company would be turning over seller information to the California [...]
Supreme Court Decision South Dakota v. Wayfair: Physical Presence Incorrect
The Supreme Court is hearing the case South Dakota vs Wayfair (W). The case is a challenge to 1992 Quill V North Dakota Supreme Court case reaffirming that a state could not require a business to collect sales tax unless the business is physically located in the state....
Why California Hid Amazon Meta Data in Official State Documents Sent to Taxpayers
So a reporter asked California why hidden Amazon meta data was embedded in an official state document sent to taxpayers. Open the doc in Google Docs...