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
Client Alert | 3 min read | 07.08.25
Trump Administration Announces Clean Energy Tax Credit Enforcement Ramp Up
On July 4th, President Trump signed into law the One Big Beautiful Bill Act (the “Act”), which included a phaseout of incentives for solar and wind generation projects. Projects must either begin construction within one year or be placed in service by 2027 to qualify for the Section 45Y Clean Electricity Production Tax Credit or the Section 48E Clean Electricity Investment Tax Credit. The House’s version of the legislation required a more accelerated phaseout than the Act and only allowed projects that began construction within 60 days of enactment of the bill to be eligible for the tax credits. In discussions last week with House conservatives who favored the faster phaseout of solar and wind tax credits, which was not adopted in the Act, President Trump promised strict enforcement of the rules, including the beginning of construction requirements, for solar and wind projects to qualify for energy tax credits.
Press Coverage | 07.03.25
Speaking Engagement | 06.30.25
"Asserting, Maintaining and Defending Privileges," NYU Tax Controversy Forum
Publication | 06.26.25
A Changed IRS May Finally End Conservation Easement Legal Mess
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
Client Alert | 3 min read | 07.08.25
Trump Administration Announces Clean Energy Tax Credit Enforcement Ramp Up
On July 4th, President Trump signed into law the One Big Beautiful Bill Act (the “Act”), which included a phaseout of incentives for solar and wind generation projects. Projects must either begin construction within one year or be placed in service by 2027 to qualify for the Section 45Y Clean Electricity Production Tax Credit or the Section 48E Clean Electricity Investment Tax Credit. The House’s version of the legislation required a more accelerated phaseout than the Act and only allowed projects that began construction within 60 days of enactment of the bill to be eligible for the tax credits. In discussions last week with House conservatives who favored the faster phaseout of solar and wind tax credits, which was not adopted in the Act, President Trump promised strict enforcement of the rules, including the beginning of construction requirements, for solar and wind projects to qualify for energy tax credits.
Press Coverage | 07.03.25
Speaking Engagement | 06.30.25
"Asserting, Maintaining and Defending Privileges," NYU Tax Controversy Forum
Publication | 06.26.25
A Changed IRS May Finally End Conservation Easement Legal Mess
Insights
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03.29.24
New York Law Journal
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05.24.24
Thomson Reuters Practical Law
TEI Seattle
|12.10.24
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03.04.24
Crowell & Moring’s Crypto Digest
U.S. Tax Court Approves Predictive Coding for Litigation Use
|09.22.14
Crowell & Moring's E-Discovery Law Insights
Professionals
Insights
Client Alert | 3 min read | 07.08.25
Trump Administration Announces Clean Energy Tax Credit Enforcement Ramp Up
On July 4th, President Trump signed into law the One Big Beautiful Bill Act (the “Act”), which included a phaseout of incentives for solar and wind generation projects. Projects must either begin construction within one year or be placed in service by 2027 to qualify for the Section 45Y Clean Electricity Production Tax Credit or the Section 48E Clean Electricity Investment Tax Credit. The House’s version of the legislation required a more accelerated phaseout than the Act and only allowed projects that began construction within 60 days of enactment of the bill to be eligible for the tax credits. In discussions last week with House conservatives who favored the faster phaseout of solar and wind tax credits, which was not adopted in the Act, President Trump promised strict enforcement of the rules, including the beginning of construction requirements, for solar and wind projects to qualify for energy tax credits.
Press Coverage | 07.03.25
Speaking Engagement | 06.30.25
"Asserting, Maintaining and Defending Privileges," NYU Tax Controversy Forum
Publication | 06.26.25
A Changed IRS May Finally End Conservation Easement Legal Mess
Insights
Client Alert | 3 min read | 07.08.25
Trump Administration Announces Clean Energy Tax Credit Enforcement Ramp Up
On July 4th, President Trump signed into law the One Big Beautiful Bill Act (the “Act”), which included a phaseout of incentives for solar and wind generation projects. Projects must either begin construction within one year or be placed in service by 2027 to qualify for the Section 45Y Clean Electricity Production Tax Credit or the Section 48E Clean Electricity Investment Tax Credit. The House’s version of the legislation required a more accelerated phaseout than the Act and only allowed projects that began construction within 60 days of enactment of the bill to be eligible for the tax credits. In discussions last week with House conservatives who favored the faster phaseout of solar and wind tax credits, which was not adopted in the Act, President Trump promised strict enforcement of the rules, including the beginning of construction requirements, for solar and wind projects to qualify for energy tax credits.
Press Coverage | 07.03.25
Speaking Engagement | 06.30.25
"Asserting, Maintaining and Defending Privileges," NYU Tax Controversy Forum
Publication | 06.26.25
A Changed IRS May Finally End Conservation Easement Legal Mess