Tax Litigation and Administrative Proceedings
In tax assessments, tax-enforcement actions and tax litigation, the legal debate over whether a given tax applies eventually comes down to accounting evidence: the tax base, credits taken, how revenue was classified, and the amount actually owed.
Context of application
A company's tax and accounting records are voluminous and spread across ancillary filings, ledgers and different systems. Technical analysis organizes these sources so that the discussion over the tax credit rests on verified figures.
When this analysis is needed
- Objections and appeals filed in administrative tax proceedings.
- Tax-enforcement actions and related objections that turn on disputed amounts.
- Claims for the refund of amounts unduly paid and tax offsets.
- Loss of tax immunities and tax benefits.
- Accounting expert examinations conducted in tax proceedings.
Questions typically analyzed
- Review of tax calculations.
- Enforcement and challenge of tax credits.
- Determination of tax contingencies.
- Loss of immunities and of tax and fiscal benefits.
- Reconciliation between the bookkeeping and ancillary tax filings.
How SGEx Approaches This
SGEx reconstructs the tax base under discussion from the company's own records, compares it against the assessment or the calculation presented by the tax authority, and records every difference by nature and by period.
SGEx does not provide legal advice. Its contribution is technical: organizing the economic, financial, accounting and asset-related facts so that lawyers, companies and parties can understand the substantive dimension of the controversy.
Possible Work and Deliverables
The format is defined according to the case, the proceeding and the purpose of the work.
- Tax-accounting expert opinion
- Recalculation of tax credits
- Expert report
- Expert questions
- Contingency report
Other SGEx Solutions
Services, specialties, contexts and industries connected to this topic under SGEx's relationship matrix.
Related Services
- Accounting Expert ExaminationIndependent expert examination of accounting records, financial statements and calculations, prepared for judicial, arbitral and administrative proceedings.
- Economic and Financial Expert AnalysisAnalysis of values, cash flows, economic assumptions and financial models in disputes and decisions that turn on quantification.
- Forensic AccountingReconstruction and examination of accounting records and financial flows for evidentiary purposes, in contexts of suspected wrongdoing, conflict or inquiry.
- Criminal Forensic AccountingAccounting and financial examination of facts under investigation in criminal and administrative sanctioning proceedings, for those who accuse and those who defend.
- Court Calculations and Accounting SupportPreparation, review and challenge of court calculations for law firms, companies and organisations, with validation technology and high-volume production.
- Tax Expert ServicesAccounting and tax examination of assessments, credits, tax bases and amounts in dispute in court and administrative proceedings.
Related Specialties
- Tax MattersLoss of tax immunities and benefits, enforcement and challenge of tax assessments, contingencies and review of calculations.
- Administrative ProceedingsAccounting and financial expert evidence in administrative tax, sanctioning, regulatory and oversight proceedings, from the defence to the appeal stage.
Related Areas of Practice
- Corporate and Shareholder DisputesDisputes among shareholders, partners and officers, corporate dissolutions, buyout claims and disagreements over financial results.
- Civil and Contract DisputesNonperformance, termination, contract revision and civil liability claims in which the controversy turns on monetary values and calculations.
- Wealth, Family and Succession MattersDivorce settlements, probate proceedings and marital disputes that call for the determination, valuation and tracing of assets.
Related Industries
- Public Administration and GovernmentPublic contracts, cooperation agreements, concessions and oversight proceedings involving public funds.
- Associations, Foundations and Nonprofit SectorAssociations, foundations and nonprofit organizations facing accountability duties, tax-immunity requirements and financial reviews.
- Energy and Natural ResourcesPower generation, transmission and distribution, oil, gas and mining, involving long-term contracts and regulatory disputes.
- Pharmaceuticals and Drug DistributionPharmaceutical manufacturers, distributors and retail chains involved in commercial, tax and accountability disputes.
- Industry, Manufacturing and Consumer GoodsManufacturers and consumer-goods producers involved in valuations, and in commercial, tax and corporate disputes.
Request an Analysis
Describe the technical question, the context in which it arose, and the documents available. This information lets SGEx assess the scope of the work before any proposal.