Morgan Lewis provides companies and partnerships of all sizes, as well as tax-exempt clients, with an integrated approach to tax advice. We focus on four major disciplines: advising on transactions; day-to-day counseling on substantive and tax planning and compliance issues; resolving disputes with taxing authorities and in court; and helping clients obtain private or public guidance from the IRS and the US Department of the Treasury. Our transfer pricing team has represented US and foreign-based multinational enterprises in some of the largest, most complex, and important transfer pricing disputes in recent history. We represent clients from a wide spectrum of industries in all aspects of the transfer pricing planning and controversy processes. Our work spans matters ranging from business restructurings and a wide array of planning issues regarding the identification and valuation of intangible property and services, to audits, IRS and international alternative dispute resolution programs, administrative appeals, advance pricing agreements, the Competent Authority process and other transfer pricing issues under treaties, trial court litigation in the US Tax Court and refund forums, and judicial appeals.