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Sharon Katz-Pearlman focuses her practice on the representation of large multinationals, partnerships, high-wealth individuals and other taxpayers, before the Internal Revenue Service (IRS), on both domestic and cross-border issues, across all industries. She represents clients from the pre-exam phase (voluntary disclosures, pre-filing agreements) through examination, appeals, and into litigation if necessary. Sharon has wide-ranging experience with resolution of transfer pricing issues at the examination and IRS Appeals level as well as with Competent Authority proceedings, seeking a Mutual Agreement Procedure (MAP) agreement and/or an Advanced Pricing Agreement (APA.)

In addition to traditional representation before the IRS, Sharon represents clients using the full range of IRS Alternative Dispute Resolution tools and advises large companies on the IRS’s Compliance Assurance Program (CAP) and other IRS specialty programs. She also advises clients on application to and participation in the OECD’s International Compliance Assurance Programme (ICAP) process.

Sharon brings over 30 years of experience in federal tax controversy, gained both in previous private and government practice. Immediately prior to joining Greenberg Traurig, Sharon served as the national and global practice leader of the Tax Controversy & Dispute Resolution practice at a Big Four accounting firm; prior to that she was a litigator for the IRS Office of Chief Counsel, where she was a Special Litigation Attorney. While with the IRS Office of Chief Counsel, Sharon earned the National Attorney of the Year Award, given annually to one attorney for outstanding contribution to the Office. She is a Fellow of the American College of Tax Counsel, an Adjunct Professor of Law at the NYU Law School, where she teaches Civil Tax Controversies & Litigation, and a former member (four-year term) on the United Nations Tax Subcommittee on Dispute Avoidance, Resolution and the Mutual Agreement Process, under the direction of the United Nations Committee of International Tax Experts on International Cooperation in Tax Matters.

Concentrations

  • Federal tax dispute resolution: IRS examination, appeals representation (technical issues/federal penalty issues)
  • Alternative Dispute Resolution: mediation, pre-filing agreements, accelerated issue resolution
  • Transfer pricing: Competent Authority matters, Mutual Agreement Procedure (MAP) cases, Advanced Pricing Agreements (APA)
  • IRS Compliance Assurance Process (CAP)consulting
  • International Compliance Assurance Programme (ICAP) consulting
  • Global tax disputes consulting for multinationals
  • IRS collection matters (liens, levies, etc.)
  • Tax Court litigation
  • IRS voluntary disclosures

KLUCZOWE PRAKTYKI

Doświadczenie

  • 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 (Recipient of IRS Chief Counsel’s Office National Attorney of the Year Award, 1989)
    • Trial Attorney/Senior Trial Attorney
  • Adjunct Professor of Law, LLM Program, New York University School of Law, 2017-Present

Wyróżnienia i aktywność zawodowa

  • Shortlisted, The Legal Benchmarking Group, "Women in Business Awards - North America Tax Lawyer of the Year," 2025
  • Listed, The Best Lawyers in America, Tax Law, 2025-2026
  • Listed, Lawdragon, "500 Leading Global Tax Lawyers," 2025
  • 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-Present
  • 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

Wykształcenie i uprawnienia do wykonywania zawodu

Wykształcenie
  • LL.M., New York University School of Law
  • J.D., cum laude, Benjamin N. Cardozo School of Law
  • B.A., cum laude, Barnard College, Columbia University
Uprawnienia
  • New York
  • U.S. Tax Court

Related Capabilities

Tax Tax Controversy and Litigation Manufacturing & Supply Chain Industry Retail