Tax controversy services

How we support you at the federal level

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

How we support you at the state level

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. ResolutionSight, RSM's AI-enabled tax controversy management platform, provides centralized visibility across notices, audits and controversy matters, helping organizations improve efficiency, accountability and control. Combined with the guidance of RSM professionals, the platform helps monitor deadlines, document requests and risk areas while providing 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

What is 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.

What is a tax dispute?

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.

How does a tax controversy differ from a tax dispute?

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.

What is an example of a tax controversy at the federal level?

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.

What are examples of state and local tax controversies?

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.

What triggers an IRS tax controversy?

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.

How has the One Big Beautiful Bill Act (OBBBA) changed the treatment of tax controversies?

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.