Henry Cheng

I have substantial experience in successfully representing businesses and multinationals in all aspects of complex civil tax disputes at the federal, state and local levels. I also have substantial experience in representing clients in cross-border tax controversy matters. My clients are across industries and sectors, including high tech and emerging growth, real estate development, travel and hospitality, telecommunications, consumer products, international shipping and logistics, financial services, and investment funds. In federal civil tax controversy matters, I represent clients in the private letter ruling process, in IRS audits, in protests to the IRS Appeals Office and in litigation and trials in the United States Tax Court and other federal courts. Many of my engagements involve international tax issues, such as sourcing of income, anti-deferral regimes, foreign tax credits, U.S. Trade or business and permanent establishment, transfer pricing, and treaty issues. In state and local civil tax controversy matters, I represent clients in tax disputes with state and local taxing jurisdictions throughout the United States. Many of my engagements involve sales and use tax, transient occupancy tax, payroll/unemployment tax as well as residency and income sourcing and allocation issues. I also represent clients in tax refund actions in state courts. I am also an adjunct professor at University of California Hastings College of the Law where I teach tax procedures and tax controversy. I frequently speak at conferences on current tax controversy issues and topics.