Susan E. Ryba focuses her practice on federal tax controversy matters and tax litigation, particularly advising clients in the technology, healthcare and pharmaceutical sectors, as well as high-net-worth individuals.
Susan has substantial experience in all stages of federal tax controversies, including audits, administrative appeals, alternative dispute resolution proceedings and litigation. She has resolved most of her matters through the Internal Revenue Service’s Independent Office of Appeals (IRS Appeals) and other dispute resolution forums. Susan advises clients on a broad range of domestic and international tax issues, including transfer pricing, effectively connected income, Subpart F, Section 965, the IRS’s economic substance and other related doctrines, worthless stock and debt deductions, withholding tax, foreign tax credits, summons enforcement and penalties.
She is a frequent speaker at seminars sponsored by the Tax Executives Institute and also teaches trial skills for the National Institute for Trial Advocacy.