Background - Practices (Details)

Tax Accounting

Crowell & Moring offers its clients one of the nation's leading tax accounting practices. In today's environment, the need for tax advice from experienced professionals is more critical than ever. Crowell & Moring's Tax Accounting Practice is recognized by our clients—and by the IRS and Department of the Treasury—for our depth of knowledge, experience, integrity, professionalism, and, most importantly, for our results. Our attorneys have assisted many of the largest and most well-respected companies in the world with the planning and resolution of the most complex tax accounting issues.

Crowell & Moring's tax accounting attorneys, have held senior positions within the IRS, the Department of Justice, and the Department of the Treasury; have provided comments to policymakers on tax accounting issues; and are well-versed in the ruling policies and inner workings of the IRS, which has enabled them to obtain favorable rulings and technical advice memoranda from the IRS national office.

In addition, the Crowell & Moring tax accounting team has resolved tax accounting issues for our clients using a variety of alternative dispute resolution techniques, including Industry Issue Resolution, Fast-Track appeals, post-appeals mediation, and alternative-timing and time-value of money resolutions. Our attorneys have represented clients on significant tax accounting issues during all phases of resolution, including IRS audit, administrative appeals, and, when necessary and advisable, through litigation.

Representative Engagements

  • Represented several large, multinational companies before IRS Appeals with respect to deductions under section 199, the "production deduction."
  • Obtained a private letter ruling for a heavy manufacturer with respect to a LIFO pooling issue.
  • Represented a high-technology company before IRS Appeals with respect to an exclusion under section 118 for a non-shareholder contribution to capital.
  • Advised a leading retailer changing its method of accounting for its inventory.
  • Represented several leading hospitality companies before IRS Appeals with regard to issues arising under their loyalty reward programs.
  • Provided an opinion to a large, multinational manufacturer with respect to its deduction under section 199.
  • Represented a leading manufacturer with respect to its research and development credit.