Profile
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.
Concentrations
- 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
Capabilities
Experience
- KPMG, LLP, 1993-2022
- Co-National Principal in Charge, Tax Controversy & Dispute Resolution, Washington National Tax
- National Principal in Charge, Tax Controversy & Dispute Resolution
- Northeast Area Principal in Charge, Tax Controversy Services
- Senior Manager, Tax Controversy Services
- KPMG International, 2008-2022
- Global Head, Tax Dispute Resolution and Controversy Network
- Member, Subcommittee – Dispute Avoidance, Resolution and the Mutual Agreement Process, United Nations Committee of International Tax Experts on International Cooperation in Tax Matters, 2017-2021
- Internal Revenue Services, Office of Chief Counsel, 1986-1993
- Special Litigation Attorney
- Trial Attorney/Senior Trial Attorney
- Adjunct Professor of Law, LLM Program, New York University School of Law, 2017-Present
Recognition & Leadership
- Listed, International Tax Review, The Comprehensive Guide to the World’s Leading Tax Controversy Advisors, “Controversy Leaders”
- Listed, International Tax Review
- Women in Tax Leaders Guide
- World Tax Leader
- Listed, Euromoney's Expert Guides: "Women in Business Law"
- Fellow, American College of Tax Counsel
- Board of Overseers, Cardozo School of Law, Yeshiva University, 2023
- Member, Law360 Tax Authority Federal Editorial Advisory Board, 2024
- Member, Law360 Tax Authority International Editorial Advisory Board, 2023
- Member, National Association of Women Lawyers
- Member, American Bar Association
- Member, New York State Bar Association
- Member, Federal Bar Association
Credentials
- LL.M., New York University School of Law
- J.D., cum laude, Benjamin N. Cardozo School of Law
- B.A., cum laude, Columbia University, Barnard College
- New York
- U.S. Tax Court