Sharon Katz-Pearlman focuses her practice on the representation of large multinationals, partnerships, and other taxpayers, before the IRS. She represents clients from the pre-exam phase (voluntary disclosures, pre-filing agreements) through examination, appeals, and into litigation if necessary. In addition, Sharon has represented clients using the full range of IRS Alternative Dispute Resolution techniques which are available to taxpayers, and advises large companies on the IRS’s Compliance Assurance Program (CAP) and other IRS specialty programs.
Sharon has deep experience with the Mutual Agreement Procedure (MAP) and the Advanced Pricing Agreement program (APA) working with Competent Authority to reach resolution on a variety of transfer pricing issues. She also consults with multinationals dealing with enforcement activity around the world, assisting them in developing practices and procedures which ensure consistency and a full understanding of the entity’s global disputes landscape. She consults frequently with clients on application to the OECD’s International Compliance Assurance Programme (ICAP) process.
- Competent Authority matters
- Mutual Agreement Procedure (MAP) cases
- Advanced Pricing Agreements (APA)
- Transfer pricing
- Global tax disputes consulting for multinationals
- ICAP consulting
- IRS examination and appeals representation
- CAP consulting
- Pre-filing agreements
- IRS voluntary disclosures
- Federal penalty relief matters