Edward L. Froelich

A former trial attorney for the Tax Division of the US Department of Justice, Ed draws on his Justice experience to provide effective advocacy in Internal Revenue Service examination and appeals and in litigation before federal courts. Among other issues, Ed has successfully represented clients in disputes involving transfer pricing, worthless stock deductions, cross-border transactions, tax credits, income tax accounting, insurance, employment tax, accounting method issues and a variety of penalty assessments.

Ed also advises concerning privilege and work product questions and reporting obligations, including the obligation to file information returns such as those relating to the Form 1099 series, Form 1098, FinCEN 114, FATCA and employment taxes.

Ed is the author of the United States chapters of The Tax Disputes and Litigation Review and The Transfer Pricing Review, published by Law Business Research. He is a co-author of BNA’s Privilege in Tax and Accounting Matters (T.M. 635) and The Section 7525 Tax Practitioner-Taxpayer Privilege and Related Issues (Accounting Policy and Practice Series No. 5511).

After earning his law degree, Ed served as a law clerk for the Honorable John P. Wiese of the US Court of Federal Claims.

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• Won key discovery motion in $150M US Court of Federal Claims tax refund action which led to a mediated settlement and substantial refund*
• Persuaded the IRS Appeals Office to concede a $300M proposed 482 adjustment against a major media company*
• Persuaded IRS Exam management to drop novel assessment of the section 6672 trust fund penalty against individuals who managed an entity which invested in the delinquent taxpayer*
• Persuaded IRS Collections to drop a $10M penalty for delinquent Form 3520 foreign trust filings*

*Matter handled prior to joining the firm.

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