Parisa M. Griess

Parisa M. Griess represents taxpayers in complex, high-stakes federal tax controversy matters and tax litigation. She primarily represents US multinational corporations and high-net-worth individuals. She defends clients in Internal Revenue Service (IRS) examinations, IRS Appeals, alternative dispute resolution proceedings, litigation before the US Tax Court and other federal courts, and competent authority matters. She also frequently advises clients on audit risk and readiness.

See more

• Successfully defended a multibillion-dollar Section 482 transfer pricing dispute regarding the arm’s-length value of a platform contribution transaction between cost-sharing participants under Treas. Reg. § 1.482-7 (Facebook, Inc. & Subs. v. Commissioner, 164 T.C. No. 9 (May 22, 2025))* 

• Successfully resolved a Section 482 transfer pricing dispute regarding the arm’s-length amount of various intercompany services (Thomson Reuters America Corporation & Subs. (F.K.A. Livenote, Inc.) & Subs. v. Commissioner, No. 20288-16, US Tax Court)* 

• Defeated a third-party summons issued under a US-India Tax Treaty Exchange of Information Request (IBM India PVT Ltd. v. United States, No. 14-mc-00011, US District Court, Western District of New York)* 

• Successfully resolved a tax refund case involving the Offshore Voluntary Disclosure Program and complex international tax issues (Kundrun et al. v. United States, No. 15-cv-00889, US Court of Federal Claims)* 

• Favorably resolved a multibillion-dollar transfer pricing dispute with IRS Exam for a technology company involving several intercompany services transactions under Section 482

See more