Adriana Lofaro Wirtz’s practice focuses on tax controversy and litigation. She represents clients at all phases of a tax controversy, from audit through litigation, including representing clients before the Internal Revenue Service Office of Appeals and acting as trial counsel. Adriana's recent matters cover a wide range of substantive tax issues, such as transfer pricing, debtequity classification, charitable contribution deductions, economic substance issues, foreign tax credits, real estate tax matters, aircraft-related issues and state and local tax matters, particularly in connection with the imposition of sales tax on SaaS. She has extensive experience defending taxpayers against the imposition of various types of penalties asserted by the Internal Revenue Service (IRS), including valuation misstatement, fraud and information return penalties. Adriana also advises clients on US reporting obligations with respect to foreign assets and represents clients in making offshore voluntary disclosures and streamlined submissions before the IRS. In addition, she has experience handling IRS collection matters and has successfully obtained relief for late tax elections. Prior to joining Cooley, Adriana served as attorney-advisor to Judge Carolyn P. Chiechi of the US Tax Court from 2007 – 2009. While attending law school, she completed an externship with the Internal Revenue Service Office of Chief Counsel. Adriana has been recognized by Super Lawyers as a "Rising Star" in tax.