Edward L. Froelich represents domestic and foreign public corporations, privately held companies, partnerships, trusts and individuals across the spectrum of federal tax controversies, including audits, trials and appeals. Ed’s clients include businesses, business owners and investors with operations and interests in the financial services, technology, real estate, health care and other industries.
A former trial attorney for the Tax Division of the US Department of Justice, Ed draws on his Justice experience to provide effective advocacy in Internal Revenue Service examination and appeals and in litigation before federal courts. Among other issues, Ed has successfully represented clients in disputes involving transfer pricing, worthless stock deductions, cross-border transactions, tax credits, income tax accounting, insurance, employment tax, accounting method issues and a variety of penalty assessments.
Ed also advises concerning privilege and work product questions and reporting obligations, including the obligation to file information returns such as those relating to the Form 1099 series, Form 1098, FinCEN 114, FATCA and employment taxes.
Ed is the author of the United States chapters of The Tax Disputes and Litigation Review and The Transfer Pricing Review, published by Law Business Research. He is a co-author of BNA’s Privilege in Tax and Accounting Matters (T.M. 635) and The Section 7525 Tax Practitioner-Taxpayer Privilege and Related Issues (Accounting Policy and Practice Series No. 5511).
After earning his law degree, Ed served as a law clerk for the Honorable John P. Wiese of the US Court of Federal Claims.
