Technical representation and qualified advocacy in tax audits in Brazil and the United States.
An audit notification from the Brazilian Federal Revenue (Receita Federal) or the IRS represents a sensitive moment in the life of any enterprise. It is not merely a document verification, but a technical procedure in which the taxpayer must demonstrate the accuracy of their tax and accounting practices.
Reactive, fragmented approaches restricted to the operational level can result in substantial tax assessments, penalties, and an unnecessary expansion of the audit's scope. The impacts of a poorly managed audit extend beyond the financial sphere, reaching legal exposure and the regular continuity of operations.
Fines and penalties that compromise cash flow
Liability attribution for managers and partners
Impact on business continuity
Our practice in tax audits is grounded in rigorous legal analysis, technical preparation, and the proactive handling of fiscal proceedings. Our work is not limited to reacting pointwise to the demands of the tax authority; rather, it involves a comprehensive understanding of the operation, tax history, and applicable legal foundations.
Prior to any formal statement, we conduct an internal technical analysis of the taxpayer's position, evaluating risks, documentary consistency, and regulatory adherence. Based on this diagnosis, we structure our response in a legally coherent, precise manner aligned with the legal limits of the proceeding, ensuring that the audit unfolds objectively, proportionally, and with sound technical backing.
Comprehensive diagnosis prior to any formal response to the tax authority
Legally coherent and technically backed responses
Technical examination of the audit scope, fiscal periods involved, and applicable normative base, focusing on a precise understanding of the audit object.
Structured review of the company's tax position, identifying sensitive points, documentary consistency, and adherence to current regulations.
Organization of the legal and technical grounds supporting the company's adopted practices, with clarity, coherence, and argumentative precision.
Acting as the central technical liaison channel with the tax authority, ensuring appropriate, timely, and legally aligned responses to the proceeding.
In audits involving cross-border operations, a primary challenge lies in the correct interpretation of structures transitioning across different legal and tax systems. Often, the difficulty stems not from operational irregularity, but from the absence of an integrated reading between the jurisdictions involved.
Our binational practice allows us to legally contextualize American structures before the Brazilian Federal Revenue and explain Brazilian operations in light of rules applicable to the IRS, based on the legal foundations of each system. This capability for technical articulation between distinct jurisdictions ensures a more precise, consistent, and defensible handling of the tax proceeding.
Brazilian companies, regardless of corporate structure or partners' residency, that have been notified by the Brazilian Federal Revenue or the IRS in audit, inspection, or tax review proceedings.
Brazilian companies with operations, investments, or structures in the United States, including subsidiaries, holdings, or American corporate vehicles, subject to tax inquiries by the IRS or the Federal Revenue, especially in cross-border contexts.
American companies, with or without operations in Brazil, facing tax proceedings before the IRS or inquiries related to operations, assets, or structures linked to Brazil.
Individuals, tax residents in Brazil, the United States, or other jurisdictions, holding international asset, business, or investment structures under review, audit, or inspection by Brazilian or American tax authorities.
Companies, economic groups, and international structures seeking to proactively evaluate their level of tax compliance, documentary consistency, and exposure to regulatory risks before the Brazilian Federal Revenue and the IRS.
Properly handling a tax proceeding requires technical preparation, legal clarity, and qualified dialogue with the tax authority. A judicious evaluation at the right time helps preserve operational regularity and mitigate unnecessary exposures.
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