Adriana’s practice focuses on tax controversy and litigation. She has extensive experience representing clients at all phases of a tax controversy from audit through litigation, including representing clients before the IRS Office of Appeals, US Tax Court, US district courts, and federal courts of appeal, as well as state taxing authorities and state courts. Her recent matters cover a wide range of substantive tax issues, such as transfer pricing, debt-equity classification, charitable contribution deductions, economic substance issues, foreign tax credits, real estate tax matters, aircraft-related issues and state and local tax matters, particularly in connection with the imposition of sales tax on SaaS. She has extensive experience defending taxpayers against the imposition of various types of penalties asserted by the IRS, including valuation misstatement, fraud and information return penalties.
Adriana also advises clients on US reporting obligations with respect to foreign assets and represents clients in making offshore voluntary disclosures and streamlined submissions before the IRS. In addition, she has experience handling IRS collection matters and has successfully obtained relief for late tax elections.
Moreover, Adriana is recognized by Super Lawyers as a "Rising Star" in tax.