Tax
Overview
While taxes are always front of mind for businesses, recent changes to federal tax law and a significant boost in funding for tax enforcement in the U.S. have reinforced the need for sophisticated guidance in this area. In this new era, businesses need experienced lawyers who can help with their most challenging and complex tax issues.
Crowell’s Tax Group is a full-service team that provides U.S. federal and state tax advice and representation in all types of business transactions as well as tax controversies and litigation. We represent public and private businesses of all types in the insurance, energy, communications, software, high technology, consumer goods, chemicals, hospitality, financial services, automotive leasing, and retail sectors. We also advise tax-exempt organizations, including not-for-profit health care organizations, educational institutions, cultural institutions, foundations, and trade associations in a wide range of matters.
Insights
Event | 05.23.24
International Tax Series: International Tax Controversy Update
This panel will provide a comprehensive update on U.S. international tax controversies, with an emphasis on disputes that have reached the trial court or proceeded to judicial appeal. The panel will analyze ongoing challenges to the validity of Treasury regulations (particularly regulations implementing the Tax Cuts & Jobs Act), as well as the rising tide of cases involving the codified economic substance doctrine.
Event | 05.20.24
Event | 05.16.24
Novogradac 2024 Spring Renewable Energy Tax Credits Conference
Client Alert | 2 min read | 05.07.24
Department of Labor Finalizes Changes to Its Fiduciary Rules
Representative Matters
- Representing a foreign-based multinational retail company in a competent authority matter involving a Swiss affiliate’s sale of tangible goods to U.S. subsidiary.
- Representing a U.S.-based hospitality company in bilateral U.S.-Swiss and unilateral advance pricing agreements related to high-value services.
- Advised a multinational software company on transfer pricing options to restructure its Luxembourg intellectual property management company in light of changes in local and European Union law and under the BEPS initiative (129 subsidiaries in 38 countries).
- Represented technology companies in IRS Exam, IRS Appeals, and competent authority proceedings concerning buy-in royalty and cost-share payments; when the IRS proposed designating one company’s cost-sharing case for litigation, we succeeded in resolving the matter without litigation.
Litigation
- AT&T Advertising, L.P. v. United States, No. 1:16-cv-00272- RTH (Fed. Cl. filed Feb. 26, 2016) (section 199 deduction).
- BrokerTec Holdings Inc. v. Commissioner, 117 T.C.M. (CCH) 1146, rev’d, 967 F.3d 317 (3d Cir. 2020).
- Vesta Corporation v. Commissioner, Nos. 26847-16, 26503-17 (T.C. Nov. 13, 2018) (section 199 deduction for software).
- Trusted Media Brands, Inc. v. United States, 2017-2 U.S.T.C. ¶ 50,359 (S.D.N.Y. 2017), aff’d, 899 F.3d 175 (2d Cir. 2018) (statute of limitations applicable to claim for refund based on change to deduction of foreign taxes paid).
- District of Columbia Office of Tax & Revenue v. BAE Systems Enterprise Systems, Inc., 56 A.3d 477 (D.C. 2012) (tax credits and incentives for qualified high technology companies).
Insights
Event | 05.23.24
International Tax Series: International Tax Controversy Update
This panel will provide a comprehensive update on U.S. international tax controversies, with an emphasis on disputes that have reached the trial court or proceeded to judicial appeal. The panel will analyze ongoing challenges to the validity of Treasury regulations (particularly regulations implementing the Tax Cuts & Jobs Act), as well as the rising tide of cases involving the codified economic substance doctrine.
Event | 05.20.24
Event | 05.16.24
Novogradac 2024 Spring Renewable Energy Tax Credits Conference
Client Alert | 2 min read | 05.07.24
Department of Labor Finalizes Changes to Its Fiduciary Rules
Professionals
Insights
Event | 05.23.24
International Tax Series: International Tax Controversy Update
This panel will provide a comprehensive update on U.S. international tax controversies, with an emphasis on disputes that have reached the trial court or proceeded to judicial appeal. The panel will analyze ongoing challenges to the validity of Treasury regulations (particularly regulations implementing the Tax Cuts & Jobs Act), as well as the rising tide of cases involving the codified economic substance doctrine.
Event | 05.20.24
Event | 05.16.24
Novogradac 2024 Spring Renewable Energy Tax Credits Conference
Client Alert | 2 min read | 05.07.24
Department of Labor Finalizes Changes to Its Fiduciary Rules
Insights
Event | 05.23.24
International Tax Series: International Tax Controversy Update
This panel will provide a comprehensive update on U.S. international tax controversies, with an emphasis on disputes that have reached the trial court or proceeded to judicial appeal. The panel will analyze ongoing challenges to the validity of Treasury regulations (particularly regulations implementing the Tax Cuts & Jobs Act), as well as the rising tide of cases involving the codified economic substance doctrine.
Event | 05.20.24
Event | 05.16.24
Novogradac 2024 Spring Renewable Energy Tax Credits Conference
Client Alert | 2 min read | 05.07.24
Department of Labor Finalizes Changes to Its Fiduciary Rules