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International Controversy Work
Caplin & Drysdale
International Controversy Work

Caplin & Drysdale attorneys assist foreign clients with U.S. tax examinations and other interactions with the Internal Revenue Service. 

Representative Engagements

Audit of an International Athlete: Caplin & Drysdale attorneys assisted with the U.S. tax examination of foreign athlete's attributable U.S. source endorsement income, requiring submission of a protest and a competent authority request to avoid double taxation of income previously taxed at the corporate level in the foreign country of the athlete's residence. The client saved nearly $2.0 million in tax as a result of this work.

Income Tax Examination of an Expatriate: Caplin & Drysdale attorneys assisted a former U.S. citizen with a protest of an IRS income tax examination determination that the client exceeded U.S. residence test, requiring complex technical claims relating to use of the "closer connection" exception. Over $75 million in tax and penalties was at issue.

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