Jill A. Frisch  

For decades, American multinational corporations have artificially reduced their federal tax liability through abusive transfer pricing, the practice of offloading too much profit to foreign subsidiaries in low-tax countries. 

Today, the tide may be turning thanks to Jill Frisch, a former top litigator at the IRS. 

Over a four-decade career, Frisch doggedly led the agency’s most complex cases to limit or eliminate foreign tax shelters, including manipulative transfer pricing schemes, to ensure America’s largest companies paid their fair share. Her landmark win against the Coca-Cola Company in 2020 was the first time the IRS successfully prosecuted a foreign transfer pricing case, laying the groundwork for future enforcement.  

“Jill Frisch is exactly the kind of public servant that makes the IRS work,” said Danny Werfel, former commissioner of the IRS. “For decades she took on the hardest cases against the best-resourced opponents and won. The billions recovered for American taxpayers are a testament to what a skilled, determined IRS can accomplish.” 

In 1985, Frisch joined the IRS. By 1990 she was handling investigations into large multitiered businesses involving voluminous records, complex transactions and foreign tax law. 

Jill’s “indefatigable drive and unlimited appetite for information,” as well as her ability to coordinate with subject-matter experts like economists and financial experts, made her successful, according to John Magee, a former attorney who opposed Frisch on two cases. 

Her first landmark case came in the late 1990s, when the U.S. Tax Court found that Colgate-Palmolive improperly claimed roughly $100 million in capital gains losses through transactions that lacked “economic substance,” setting a precedent for interrogating new types of tax avoidance schemes. 

In the early 2000s, she successfully prosecuted the Bank of New York for claiming an artificially high number of foreign tax credits through a series of complex transactions. The bank was charged with an $850 million tax bill. 

“Jill’s cases set national precedents affecting large numbers of taxpayers and established important tax administration principles,” said John Altman, division counsel at the IRS Office of Chief Counsel. 

But it was Frisch’s foreign transfer pricing work that perhaps left the biggest mark. 

After years of losses, she scored the agency’s first major victory in 2020, when the tax court found that Coca-Cola’s foreign subsidiaries had severely underpaid for the rights to use parts of the company’s soda-making formula. The result was overinflated profits in low-tax countries and artificially low profits in the U.S., a higher tax jurisdiction. 

The tax court sided with Frisch on a related case against Coca-Cola in Brazil in 2023 and then finalized its ruling against the conglomerate in 2024, finding it liable for roughly $6 billion in back taxes, including interest. The decision has been appealed and remains under litigation. 

In a similar case against Medtronic, a medical device company, Frisch convinced the Justice Department to appeal a 2016 ruling against the IRS. She was instrumental in getting a court to vacate that decision in 2018 and then again 2025. The two parties are currently exploring a negotiated settlement. 

“Jill’s work has resulted in the recovery of tens of billions of dollars in federal income taxes. She has done a tremendous job advancing tax law and was unwavering in her commitment to get the right result,” Altman said. 

However, today, the IRS faces tough challenges. 

Since the start of the Trump administration, over 30,000 employees—about 25% of the workforce—have left the agency through mass layoffs, retirements and deferred resignations. 

Including Frisch. 

She retired in 2025 and is currently exploring pro bono opportunities in different fields of law.  

If any career demonstrates why the public benefits from an effective and well-staffed IRS, it is hers. 

“We always tried to do the right thing and get to justice. It was a tremendous job, and I loved every minute of it,” Frisch said.