Deloitte Americas profile

The Deloitte network of member firms in the Americas deploys the applicable local and regional teams quickly. Deloitte's Americas tax controversy teams consist of more 280 professionals with offices in 130 locations through a network of member firms.

In Canada, Deloitte Tax Law also has 18 lawyers in tax controversy across three offices: Montreal, Toronto and Vancouver. Deloitte Tax Law is an independent global immigration law firm allied with Deloitte in Canada, with offices across the country.

Professional services teams are present across the globe to provide services locally, while coordinating engagements regionally or globally from a central location.

Deloitte's Americas tax controversy teams also draw on the capabilities and strengths of the group's other businesses – audit and assurance, consulting and risk and financial advisory – to provide broad-scale tax-aligned business insights.

Deloitte has been developing a cross-border, central governance model and network of virtual and physical centres in the Americas region that aligns with our global platforms. This model offers a broad scope of integrated services including tax controversy, compliance, tax provision, statutory accounting, tax advisory services (including international tax, global customs and trade advisory) and transfer pricing.

Tax capabilities include the following services:

• Business tax; tax controversy; tax compliance and reporting; tax implications of business change; business, high net worth and international tax consulting

• Business process insights

• Global employer services

• Global investments and innovation incentives

• Indirect tax

• M&A

• Tax management consulting

• Transfer pricing

• Deloitte Legal (in applicable countries)

The tax controversy professionals of Deloitte member firms in the Americas provide assistance spanning the various stages of federal, state, and local examinations – from dispute mitigation/planning to issue resolution and post-exam improvements. Through decades of working with clients on a broad range of tax issues, Deloitte member firms in the Americas have fine-tuned their technology, analytical procedures and planning methodologies to offer a broad-based, scalable solution that can be tailored to the specific circumstances of each client and each matter.

Deloitte member firms in the Americas offer various cross-border tax controversy capabilities including the following services:

• Pre-controversy audit readiness

• Examinations

• Litigation, appeals and settlement

• Proactive resolution services

• Transfer pricing

• Tax controversy software tools and support

Innovation is a key component of Deloitte's tax controversy offering across the Americas region. Deloitte's network of member firms is investing heavily in tax technology and analytics capabilities and developing solutions to help clients mitigate the potential for, manage, and learn from, the various types of tax disputes, which in turn, translates to value to our clients. Collaboration allows Deloitte member firms to develop tax technology solutions that address specific and complex tax requirements in the Americas region. Deloitte member firms in the Americas can provide innovative tax controversy software tools and support including:

• Tax Controversy Manager: Proprietary web-based tool for managing exam-related data and reporting.

• Interest Analyzer: Service to verify the accuracy of complex federal and state tax agency interest calculations.

• Data Management: Assistance with integrating systems to capture, retain, process and analyze information, and to respond quickly to high-volume information requests. Assistance with planning for tax data retention related to ERP systems implementation.

• Successful appeal to the Tax Court of Canada for a Fortune Global 500 company of an assessment that had increased taxable income by approximately $370 million in relation to the redemption of certain preferred shares.

• Successful resolution of a Canadian transfer pricing dispute for a Fortune 100 company in relation to the disposition of intellectual property operations valued at approximately $5 billion.

• Mexico's tax controversy team was recently appointed as litigator for a leading oil and gas MNG.

• Regional Awards: Americas Tax Innovator Award (second consecutive year), Americas Tax Compliance & Reporting Firm of the Year (third consecutive year) and Americas Transfer Pricing Firm of the Year

• National Tax Firms of the Year: Deloitte Mexico and Deloitte Venezuela

• National Transfer Pricing Firms of the Year: Deloitte Colombia, Deloitte Mexico, and Deloitte Peru

• World Tax: Six countries awarded Tier 1 (Argentina, Brazil, Colombia) or Tier 2 ratings (Chile, Mexico, Uruguay)

• World Transfer Pricing: Seven countries ranked Tier 1 (Argentina, Brazil, Chile, Colombia, Mexico, Peru, Venezuela) and Uruguay ranked Tier 2

Euromoney and International Tax Review-Tax leader/expert guides: 67 leaders across the region were recognized for their individual abilities, as well as for their in-depth capabilities, experience and specialist knowledge:

• 20 in ITR Tax Controversy Leaders Guide 2017

• 19 in 2017 Guide to the World's Leading Transfer Pricing Advisers

• Eight in International Tax Review (ITR) Indirect Tax Leaders Guide 2017

• 20 in ITR Women in Tax Leaders Guide 2017

Deloitte in the Americas region includes 130 offices, with 282 tax controversy professionals.

Phone: +12022202118

Email: rsereti@deloitte.com

Twitter: @DeloitteTax

Website: www2.deloitte.com/us/en/pages/tax/solutions/tax-controversy-services.html

---

This document has been prepared solely for the purpose of publishing in the 2018 Tax Controversy Leaders guide and may not be used for any other purpose. This document and its contents may not be reproduced, redistributed or passed on, directly or indirectly, to any other person in whole or in part without Deloitte's prior written consent.

Deloitte refers to one or more of Deloitte Touche Tohmatsu Limited ("DTTL"), its global network of member firms, and their related entities. DTTL (also referred to as "Deloitte Global") and each of its member firms are legally separate and independent entities. DTTL does not provide services to clients. Please see www.deloitte.com/about to learn more.

Deloitte Legal means the legal practices of Deloitte Touche Tohmatsu Limited member firms or their affiliates that provide legal services outside of the US. For legal, regulatory and other reasons, some member firms, including the US member firm, do not provide legal services. Certain services may not be available to attest clients under the rules and regulations of public accounting.

Deloitte is a leading global provider of audit and assurance, consulting, financial advisory, risk advisory, tax and related services. Our network of member firms in more than 150 countries and territories serves four out of five Fortune Global 500® companies. Learn how Deloitte's approximately 264,000 people make an impact that matters at www.deloitte.com/about.

This communication contains general information only, and none of Deloitte Touche Tohmatsu Limited, its member firms or their related entities (collectively, the "Deloitte network") is, by means of this communication, rendering professional advice or services. Before making any decision or taking any action that may affect your finances or your business, you should consult a qualified professional adviser. No entity in the Deloitte network shall be responsible for any loss whatsoever sustained by any person who relies on this communication.

© 2018. For information, contact Deloitte Touche Tohmatsu Limited.