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Accountancy firm Price Waterhouse has formed a strategic alliance with Washington-based niche tax practice Miller & Chevalier to become what Millers describes as the "closest thing to a multi-disciplinary practice you can currently have in the States".
Although law firms and accountants have worked together in the area of tax, this link-up is seen as highly unusual because it is not for a specific project or for a limited period of time. In the US the climate is steadfastly against accountants encroaching on the legal market.
The move is described in a statement as "providing seamless US tax controversy services from the pre-examination planning stage through audit and the appeals stage and, if necessary, litigation".
Philip Neal, chair of Millers, which is incorporated for tax purposes, said the arrangement allowed Price Waterhouse to have a closer involvement with tax appeals and litigation without breaking practice rules or losing any work from other law firms.
Neal added that Millers benefited from the fact that it was located in the District of Columbia, which has "the most modern code of conduct of all the states", but made it clear that the firms were not in a joint venture and their relationship was "clearly non-exclusive".
The two firms have signed a "memorandum of understanding", a document setting out the management structure and goals of the alliance and have formed a joint steering committee which meets weekly.
Neal said the practice, which acted successfully in the two largest tax cases heard in the US tax courts, was after the same type of clients as Price Waterhouse: "We both serve the very largest of international companies."
Bernard Shapiro, managing partner of tax policy and strategy at Price Waterhouse in Washington, said the alliance "gives the firms the resources to resolve disputes in the most effective forum, whether it is the Internal Revenue Service, Treasury Department, Department of Justice, Congress or the courts".