Tax controversy services

Resolve tax disputes, manage IRS exams and state audits, reduce risk

Contact our tax controversy team

Our experienced team can help you resolve tax controversies efficiently

Businesses face heavy scrutiny from federal and state taxing authorities. Examinations are expanding, data tools are advancing and agencies are coordinating across jurisdictions. Whether you are preparing for an audit or addressing an active dispute, you need a team that understands the full federal and state landscape.

RSM’s tax controversy professionals guide you through every stage of a dispute. We combine technical depth with practical experience across federal, state and local, international, corporate, partnership, and excise tax areas. Our goal: Help you assess risk, respond confidently and resolve issues efficiently.

Using advanced tax technology—including our IRS controversy tracker—we streamline processes, improve data accuracy and provide analytics that identify risk areas and support strategic decisions. This tech-forward approach helps you achieve timely, effective resolutions and stay focused on your business objectives in an evolving regulatory environment.

Helping you resolve tax disputes at both the federal and state levels

Federal tax controversy can be complex and urgent. We guide you through IRS examinations, appeals and dispute resolution. We help you prepare for audits, address notices and manage communications with the IRS.

Our professionals have backgrounds as IRS attorneys and revenue agents, so we understand the process from all sides.

We support you with:

Audit readiness and risk assessment
Representation before the IRS, including appeals and mediation
Penalty prevention and abatement strategies
Interest review and interest netting opportunities
Prefiling agreements and obtaining prefiling certainty
Assistance with refund claims and appeals
Support for entity classification and filing requirements
Private letter rulings to fix missed elections
Guidance on voluntary disclosure and international information returns

State and local tax controversy brings its own challenges. With thousands of unique tax regimes nationwide, it can be difficult to manage disparate rules, deadlines and documentation expectations. A coordinated and technology enabled approach helps you stay ahead of inquiries and maintain visibility across jurisdictions.

Our state and local tax controversy team works with you to prepare for state and local audits, respond to notices, and pursue resolution efficiently. Our tax controversy tracker centralizes audit activity and helps you monitor deadlines, document requests and risk areas. With that digital support, you gain clearer oversight across state examinations and appeals.

We support you with:

Audit defense and response strategies for state and local authorities
Guidance during multistate examinations and appeals
Guidance on state-specific compliance and reporting
Assistance with penalty abatement and interest review
Help with refund claims and dispute resolution
Proactive planning to minimize risk and exposure

Tax controversy insights

Frequently asked questions (FAQs) about tax controversy

: Tax controversy refers to disputes between taxpayers and taxing authorities—such as the IRS or state agencies—over tax assessments, audits, penalties or compliance issues. These disputes can arise at the federal, state or local level.

: A tax dispute is a disagreement between a taxpayer and a taxing authority about the amount of tax owed or the interpretation of tax law. It often becomes part of a larger tax controversy when formal proceedings or appeals are involved.

: A tax dispute typically involves a disagreement over a specific tax amount or interpretation of law. Tax controversy is broader, encompassing the entire process of examination, appeals and resolution with taxing authorities.

: A common example is an IRS audit challenging a company’s transfer pricing methodology. This type of controversy often involves complex documentation, negotiations with the IRS and potential appeals to resolve the issue.

: Examples include multistate audits, disputes over nexus and apportionment, sales and use tax assessments, and challenges to state-specific compliance requirements. RSM’s state and local tax controversy team helps businesses navigate these complex issues.

: Common triggers include IRS audits, notices of deficiency, penalties, interest assessments and challenges to tax positions. Increased data analytics and enforcement initiatives have made proactive risk management essential.

: OBBBA introduced procedural changes that affect how disputes are handled, including expanded taxpayer rights during examinations, streamlined appeals processes and enhanced digital communication with the IRS. These changes aim to improve transparency and efficiency in resolving controversies.

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RSM US LLP is a limited liability partnership and the U.S. member firm of RSM International, a global network of independent assurance, tax and consulting firms. The member firms of RSM International collaborate to provide services to global clients, but are separate and distinct legal entities that cannot obligate each other. Each member firm is responsible only for its own acts and omissions, and not those of any other party. Visit rsmus.com/about for more information regarding RSM US LLP and RSM International.

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