Domestic Controversy Work
Caplin & Drysdale
Domestic Controversy Work

Caplin & Drysdale attorneys are frequently called upon to assist with complex estate and gift tax examinations, as well as income tax issues for individuals, trusts and estates. We also frequently represent clients' interests before the National Office of the IRS on requests for private letter rulings.

Representative Engagements

Defending a trust's income tax position: Caplin & Drysdale attorneys were retained to consider a planned trust division and recommend a tax position designed to maximize the possibility of obtaining a charitable contribution deduction upon the termination of family trusts. The amount at issue is about $250 million in tax.  The family is following Caplin & Drysdale's advice by taking the initial position on a claim for refund, to be followed by a refund suit, if necessary.   

Private Letter Ruling: Caplin & Drysdale attorneys obtained a favorable private letter ruling from the IRS affirming that there are no adverse tax consequences to a settlement agreement entered into by the trust beneficiaries and approved by the state court. The settlement agreement resolved an 80-year old dispute amongst the beneficiaries, who were represented by 15 separate law firms. A committee of those attorneys selected Caplin & Drysdale to represent them before the IRS. 

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