Technical expertise and qualified representation 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 any company's life. It is not merely a documentary review, but a technical procedure in which the taxpayer must demonstrate the correctness of its tax and accounting practices.
Reactive, fragmented, or operationally-limited approaches can result in significant assessments, application of penalties, and unnecessary expansion of the audit's scope. The impacts of a poorly managed audit go beyond the financial sphere, reaching legal exposure and the regular continuity of operations.
Fines and penalties that compromise cash flow
Liability of executives and shareholders
Impact on business continuity
Our approach to tax audits is grounded in rigorous legal analysis, technical preparation, and proactive management of the audit process. Our work goes beyond responding to isolated demands from the tax authority — it involves a comprehensive understanding of the business, its tax history, and the applicable legal framework.
Before any formal response, we conduct an internal technical review of the taxpayer's position, assessing risks, documentary consistency, and regulatory compliance. Based on this diagnosis, we structure the response in a legally coherent, precise, and legally compliant manner, ensuring the audit proceeds in an objective, proportionate, and technically grounded way.
Comprehensive diagnosis before any formal response to the tax authority
Legally coherent and technically grounded responses
Technical review of the audit's scope, the fiscal periods involved, and the applicable regulatory framework, focused on accurately understanding the object of the tax examination.
Structured review of the company's tax position, identifying sensitive areas, documentary consistency, and compliance with 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 with the tax authority, ensuring adequate, timely, and legally aligned responses throughout the proceedings.
In audits involving cross-border operations, one of the primary challenges lies in correctly interpreting structures that span different legal and tax systems. Often, the difficulty is not in the irregularity of the operation itself, but in the absence of an integrated reading across the jurisdictions involved.
Our binational practice enables us to legally contextualize U.S. structures before the Brazilian Federal Revenue and explain Brazilian operations in light of applicable IRS rules, based on the legal foundations of each system. This capacity for technical articulation across distinct jurisdictions ensures a more precise, consistent, and defensible conduct of tax proceedings.
Brazilian companies, regardless of their corporate structure or the location of their shareholders, that have been notified by the Brazilian Federal Revenue (Receita Federal) or the IRS in audit, tax examination, or fiscal review proceedings.
Brazilian companies with operations, investments, or structures in the United States — including subsidiaries, holding companies, or U.S. corporate vehicles — subject to tax inquiries from the IRS or the Brazilian Federal Revenue, particularly 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 who are tax residents in Brazil, the United States, or other jurisdictions, holding patrimonial, corporate, or investment structures internationally that are under analysis, audit, or review by Brazilian or U.S. tax authorities.
Companies, economic groups, and international structures that proactively seek to assess their level of tax compliance, documentary consistency, and regulatory risk exposure before the Brazilian Federal Revenue and the IRS.
Properly managing a tax audit requires technical preparation, legal clarity, and qualified interaction with the tax authority. A thorough assessment at the right moment helps preserve operational regularity and minimize unnecessary exposure.
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