Information Reporting and Compliance

Our lawyers have decades of combined experience with the information reporting and withholding requirements of the Internal Revenue Code. The team is nationally recognized for advising on all aspects of domestic and cross-border information reporting, including Chapter 3, FATCA, and the Corporate Transparency Act. In addition to advising clients on ongoing compliance issues, our lawyers have represented clients in some of the largest voluntary disclosures and most contentious IRS audits related to withholding failures. Their skill and reputation for finding practical solutions to difficult problems have led to amicable resolutions to these disputes while often avoiding costly litigation.

In addition to our federal practice, Covington has a thorough understanding of state reporting and withholding requirements. Our lawyers have advised companies on how to comply with these requirements, as well as how to correct prior mistakes, providing clarity in an environment marked by confusion and a lack of formal guidance from state authorities.

Capabilities

• Advising multinational companies on the development of a comprehensive Chapter 3 and Chapter 4 (FATCA) compliance programs including the registration of foreign financial institutions within their expanded affiliated group
• Representing clients seeking abatement of information reporting and withholding penalties imposed by federal and state tax authorities
• Representing companies in a multifaceted disputes before the IRS Independent Office of Appeals regarding numerous alleged information reporting and withholding failures, including the imposition of intentional disregard penalties
• Representing companies in federal voluntary disclosures with the IRS Foreign Payments Practice
• Representing companies in state voluntary disclosures with respect to state information reporting and withholding failures
• Advising employers on information reporting and shared responsibility penalties related to the Affordable Care Act