Miller & Chevalier represents the world's largest multinational corporations in their most significant controversies. Our lawyers just litigated a multi-billion-dollar transfer-pricing case for a Fortune 100 company in a Tax Court trial that lasted two months. And we have been successfully resolving major tax controversies for our clients since 1920. Our tax lawyers combine deep technical tax knowledge with rich experience in all facets of controversy and litigation.

We advise clients on all procedural and strategic aspects of controversies, including responding to information document requests, complying with formal document requests, quashing summonses, managing statutes of limitation, establishing document retention procedures, protecting privileged documents, and dealing with audit adjustments.

Some clients seek to resolve disputes short of litigation. When it comes to those disputes, we are experienced in all forms of administrative dispute resolution, from Fast Track Settlement to Early Referral to Appeals, traditional Appeals, Post-Appeals Mediation, the Compliance Agreement Program (CAP), the Pre-Filing Agreement program, and Advance Pricing Agreements.

And some controversies call for litigation. Over the last two decades, Miller & Chevalier lawyers have litigated more than one hundred tax cases in the federal courts. In recent years, we have taken cases to trial in the Tax Court, the Court of Federal Claims, and in district court. Recent cases have involved the gamut of tax issues, including tax accounting, cost basis and valuation, treaty benefits, tax credits, interest netting, and transfer pricing. We have significant experience and a successful track record in appeals to the circuit courts and the Supreme Court.

  • Commissioner, Internal Revenue Service
  • General Counsel, U.S. Nuclear Regulatory Commission
  • Assistant Commissioner (Technical), Internal Revenue Service
  • Tax Assistant to the Solicitor General, U.S. Department of Justice
  • Assistant to the Solicitor General, U.S. Department of Justice
  • Acting Chief Counsel, Internal Revenue Service
  • Deputy Chief Counsel, Internal Revenue Service
  • Counselor to the IRS Commissioner, Internal Revenue Service
  • Assistant Chief of Staff, Joint Committee on Taxation, U.S. Congress
  • Majority Tax Counsel, U.S. House of Representatives Committee on Ways and Means
  • Assistant Legislative Counsel, Joint Committee on Taxation, U.S. Congress
  • Senior Counsel and Lead Economic Policy Advisor, Senator John D. Rockefeller IV, Chairman of the Senate Commerce, Science and Transportation Committee and Senior Member of the Senate Finance Committee
  • Tax and Trade Counsel, Congresswoman Stephanie Tubbs Jones, Senior Member of the House Ways and Means Committee
  • Advisor to the Assistant Secretary for Tax Policy, U.S. Department of the Treasury
  • Counsel, Subcommittee on the Environment of the U.S. Senate Committee on Commerce
  • Attorney Advisor, U.S. Department of the Treasury
  • Attorney Advisor, Legislation and Regulations Division, Office of Chief Counsel, Internal Revenue Service
  • Honors Attorney, Office of the Associate Chief Counsel (International), Internal Revenue Service
  • Honors Attorney, U.S. Department of the Treasury
  • Legislation Attorney, Joint Committee on Taxation, U.S. Congress
  • Legislative Director, U.S. Senator
  • Member, President Barack Obama's Transition Team, Economic and International Agency Review Working Group
  • Chambers USA: Tax Team of the Year, 2016
  • Chambers USA: Tax: Controversy (Nationwide), 2007 - 2019
  • Chambers USA: Government Relations: Specialist Tax Firms (Nationwide), 2019
  • Chambers USA: Tax (District of Columbia), 2003 - 2019
  • Legal 500: Tax: Contentious (U.S.), 2007 - 2019
  • Legal 500: Tax: International Tax (U.S.), 2013 - 2019
  • Legal 500: Tax: Non-Contentious (U.S.), 2013 - 2019
  • U.S. News - Best Lawyers® "Best Law Firms": Litigation - Tax (National), 2011 - 2019
  • U.S. News - Best Lawyers® "Best Law Firms": Tax Law (National), 2010 - 2019
  • U.S. News - Best Lawyers® "Best Law Firms": Employee Benefits (ERISA) Law (National), 2014 - 2019
  • U.S. News - Best Lawyers® "Best Law Firms": Litigation - Tax (District of Columbia), 2011 - 2019
  • U.S. News - Best Lawyers® "Best Law Firms": Tax Law (District of Columbia), 2010 - 2019
  • U.S. News - Best Lawyers® "Best Law Firms": Employee Benefits (ERISA) Law (District of Columbia), 2010 - 2019
  • International Tax Review "Americas Tax Awards": Americas Tax Policy Firm of the Year, 2012 - 2013, 2015 - 2016 
  • International Tax Review "Americas Tax Awards": Washington, DC Tax Firm of the Year, 2013
  • International Tax Review "Americas Tax Awards": Washington, DC Transfer Pricing Firm of the Year, 2012
  • International Tax Review: World Tax (Washington, DC), 2012, 2014 - 2018
  • International Tax Review: World Transfer Pricing (National), 2014 - 2018
  • International Tax Review: Tier 1 U.S. Firm, Tax Planning Survey, 2018
11.05.2019
Speaking Engagement

Steven Dixon and Loren Ponds will speak at the TP Minds West Coast Conference on November 5-7, 2019, in San Francisco, California.

San Francisco, CA

04.30.2019

Almost 18 months after the passage of the Tax Cuts and Jobs Act of 2017 (TCJA), tax executives remain undecided about the law's impact on U.S.

02.28.2019

The U.S. Department of Justice (DOJ) continues to focus on cross-border white collar investigations and charge individuals located abroad.

White Collar Alert
12.20.2018

On December 13, 2018, the Department of Treasury (Treasury) and the Internal Revenue Service (IRS) issued proposed regulations (Proposed Regulations) under section 59A, the base erosion and anti-ab

Tax Alert