Tax Controversy Recruiters

The unagreed inventory did not shrink with the workforce. On 30 September 2024 the IRS had 1,879 attorneys in pay status, 10,736 revenue agents and 1,101 appeals officers. On 30 September 2025 those counts were 1,668 attorneys, 8,609 revenue agents and 975 appeals officers (IRS Data Book, 2025, Table 6-3). The National Taxpayer Advocate, in IR-2026-15 on 28 January 2026, reported a separate cut by function: Chief Counsel staff from 2,741 on 25 January 2025 to 2,260 on 18 December 2025, Appeals from 1,775 to 1,263, and Large Business and International from 6,763 to 5,023, inside an IRS workforce that fell from about 102,000 to about 74,000, a 27 percent reduction. The 1,668 figure is attorneys in pay status at fiscal year-end. The 2,260 figure is all Chief Counsel staff in mid-December. They are different series. Both say the government side of the table got smaller while fiscal 2025 still closed 497,621 audits and Chief Counsel received 21,588 Tax Court cases.

That staffing gap is a hiring event on the private side. Firms and companies recruit lawyers who left Chief Counsel, Appeals and large-case exam. The seat they are hired into is not a general tax associate seat. It is the lawyer who already knows the file a revenue agent used to hold. Washington is where that supply concentrates, which is why tax recruiters in Washington and tax recruiters in New York are the two city pages that sit next to this one. The United States Tax Court sits in Washington. The corporate controversy bar that tries those cases is split between Washington and New York.

Public Law 119-21, signed on 4 July 2025, reopened positions that returns had already taken. Congress.gov records the One Big Beautiful Bill Act as Public Law 119-21 on that date. The National Taxpayer Advocate’s 28 January 2026 report said many of its tax provisions apply retroactively and require IRS guidance, forms and programming at the same time the workforce is smaller. Retroactive statutes produce controversy after the return is filed: a position taken in good faith, then a notice, then an exam. That is counsel work in 2026 and 2027, not a planning memo from 2024.

Transfer-pricing disputes still run on a multi-year clock. On 31 October 2025 the OECD reported that transfer-pricing mutual agreement cases closed in 2024 averaged 30.9 months, down from 32 months in 2023, across 141 jurisdictions. The OECD’s 2024 MAP tables show 1,265 transfer-pricing cases started and 1,119 closed (52 cases opened before 2016, plus 1,067 opened later). Inside the United States, the IRS executed 144 advance pricing agreements in fiscal 2025, 79.9 percent of them bilateral, and 501 taxpayers still had a pending APA request on 30 September 2025 (Data Book, Table 3-6). A company that thinks an APA request paused the need for controversy counsel is looking at a queue, not a closed file. How an in-house disputes seat is scoped against that clock, including the Milan and cross-border version of the same hire, is on the tax controversy and transfer-pricing disputes market note.

The dollars sit in a thin set of corporate returns. Fiscal 2025 closed 7,495 corporation income-tax exams, other than Form 1120-S, with $11.99 billion of recommended additional tax. Corporations with $20 billion or more in assets accounted for 281 of those exams and $8.594 billion of that tax (Table 3-2). Partnership returns examined in the same year numbered 3,141. The individual exam rate the Data Book treats as outside the normal statute window, tax year 2021, was 6.6 percent for taxpayers with total positive income of $10 million or more (Table 3-1). High-income individuals, large corporations and partnerships are three different controversy products. A requisition that says “tax controversy” and means all three will not be fillable from one list.

Bloomberg Law reported on 2 June 2026 that firms matching the Milbank scale moved associate base to $235,000 through $455,000. Above the Law, the same day, put the effective date at 1 July 2026. That ladder is what a tax associate earns at a matching firm. It is not a controversy differential, and it is not what a chief legal officer pays a Tax Counsel. The class-year table is on the 2026 BigLaw associate scale. The tax overlay, including why ACC does not print a tax-specialty dollar, is on the tax attorney salary 2026 page.

ACC’s 16 September 2025 Law Department Compensation Survey, of in-house lawyers, puts Attorney median base at $148,000 and Senior Attorney median base at $201,000. Tax appears in that survey as a specialty rank. It does not appear as its own dollar. Quoting those title medians as “tax controversy pay” overstates what the document contains. They are the Legal-department cash a general counsel already uses for counsel titles, and they are the wrong instrument for a Finance-side head of tax.

OPM Salary Table 2026-DCB, effective January 2026, sets GS-15 locality pay for Washington-Baltimore-Arlington at $169,279 (step 1) through $197,200, the Executive Level IV cap. IRS Chief Counsel attorneys in pay status numbered 1,668 on 30 September 2025. A lateral from that office into a firm or a company is leaving that band, not arriving on it. State and local controversy counsel are not on this federal table at all. Their cash follows the firm scale or the in-house title, depending on which of the five buyers is hiring.

Company and firm searches are retained only. The fee is 25–30% of the hire’s total first-year compensation. Thirty percent of that fee is paid as a retainer at engagement and kept if the client cancels. A head of tax controversy is not a general counsel search: the replacement window on other in-house searches is 6 months. General counsel, chief legal officer and chief compliance officer searches carry 12 months. A conversation about a specific seat starts at a confidential briefing or contact.

All tax recruitment · Tax planning and controversy · Transfer pricing · Tax recruiters in Washington · Tax recruiters in New York

Use the planning-and-controversy page when the hire must still write the structure and then defend it. Use this page when the structure is already on a return and the work is the exam, the protest, the petition, or the competent-authority case. Washington covers the Tax Court and Chief Counsel bar. New York covers the corporate controversy practices that try and settle those cases for companies. Compensation detail stays on the salary page. The in-house scoping question, including transfer pricing, stays on the market note.