In the News
IBM, Goodyear, DirecTV Still Owe 'Retroactive' State Taxes
May 23, 2017 — Bloomberg BNA
Law360 Tax Editorial Advisory Board
March 3, 2017 — Law360
Tax Authorities Seen Favoring Profit Split Method
February 16, 2017 — Bloomberg BNA Daily Tax Report
The 24 Firms GCs Love the Most
June 28, 2016 — Law360
Law360 Tax Editorial Advisory Board
February 24, 2016 — Law360
Washingtonian Top Lawyers: Tax Lawyers
December 30, 2015 — Washingtonian
Tax Regulation and Legislation to Watch in 2016
December 24, 2015 — Law360
Federal Tax Cases to Watch in 2016
December 24, 2015 — Law360
Biggest Federal Tax Cases of 2015
December 24, 2015 — Law360
5 Biggest Tax Policy Changes Of 2015
December 21, 2015 — Law360
U.S. Contractors Must Reveal Felony, Tax Info Under New Reg
December 4, 2015 — Law360
20 Percent Additional Tax Applies to Retention Bonus
May 12, 2015 — Law360
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Jennifer Ray, a Washington, D.C. based partner in Crowell & Moring's Tax Group, discusses the implications of the Internal Revenue Service's recently issued Chief Counsel Advice (CCA) stating that an executive's retention agreement violated Code section 409A[2] and therefore was subject to an additional 20 percent federal income tax. Ray notes that the CCA is "a cautionary tale for companies playing the ‘audit lottery.'"
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4 Tips for Negotiating IRS Advance Pricing Agreements
March 27, 2015 — Law360
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Washington, D.C.-based partner and member of the firm's Tax Group, David J. Fischer, talks with Law360 about the expert tips and best practices taxpayers should keep in mind when negotiating an advance pricing agreement (APA)."You have to think about the likelihood of succeeding with an APA and whether you're willing to take a somewhat less aggressive position. Most APAs involve transactions with affiliates in jurisdictions with tax rates similar to the U.S. rate, so the IRS's tendency to push of the results toward the middle has less impact on the overall effective tax rate," said Fischer.
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At Some D.C. Firms, More Women Than Men Make Partner
January 19, 2015 — National Law Journal
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Crowell & Moring managing partner Ellen M. Dwyer is quoted in a National Law Journal article highlighting the trend that women accounted for half or more of new partners at eight of the largest firms in Washington, D.C. This year, three of Crowell & Moring's six attorneys that were promoted to partnership were women, which Dwyer attributes to the firm's long-term campaign of making more opportunities available to women. Washington, D.C.-based tax partner, Jennifer Ray is noted as one of the firm's newly promoted partners.
Federal Tax Cases to Watch In 2015
January 2, 2015 — Law360
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David B. Blair, a Washington, D.C.-based partner in Crowell & Moring's Tax Group, shares his thoughts on a major pricing dispute case, Amazon.com Inc. v. Commissioner of Internal Revenue, and its importance for the Internal Revenue Service (IRS). "This could be the IRS' second attempt after the Veritas case to win this issue of cost-sharing arrangements and whether a buy-in should be based on a cost-sharing method. Veritas was a big loss for the IRS," Blair noted.
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2014 Federal Tax Litigation In Review
December 19, 2014 — Law360
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Washington, D.C.-based partner and member of the firm's Tax Group, David J. Fischer, talks with Law360 about the major high-stakes tax cases that closed in 2014. Fischer provided his viewpoints on three of the cases, including U.S. v. Clarke, which the court said taxpayers have a right to examine their IRS agents if they can point to specific facts or circumstances — including circumstantial evidence — that raise an inference of bad faith. "Tax law is like a pendulum, and right now our pendulum is swinging toward procedural fights because the IRS has changed its summons process and the Supreme Court has changed the litigation standards for looking behind an IRS summons," stated Fischer.
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BNA Videos: Crowell's Conversations in Bloomberg BNA
February 21, 2014 — Bloomberg BNA
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Tax Group attorneys Donald Griswold, Walter Nagel, both partners, and Jeremy Abrams, counsel, sat down with Bloomberg BNA to discuss the Tax Groups' monthly column with the publication, "Crowell's Conversations." In this video, the attorneys tell the audience about what makes "Crowell's Conversations" so unique and what to expect to read in their column this year.
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Recent MTC Trends, States Begin to Respond to 'Gillette'
June 25, 2013 — Bloomberg BNA "Expert Insight" / June 28, 2013 — Bloomberg BNA "Tax Management Weekly State Tax Report"
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Washington, D.C.-based Tax Group attorney, Jeremy Abrams, shares his perspective on the impact that three recent cases, Anheuser-Busch v. Michigan Dept. of Treas., IBM v. Michigan Dept. of Treas. and Gillette Co. et al v. FTB, will have on the Multistate Tax Compact (MTC) with Bloomberg BNA. His comments are published in Bloomberg BNA's Tax Management Weekly State Tax Report and Expert Insight blog. According to Abrams, "The flurry of repealing legislation that we're seeing confirms that Compact states are taking this issue very seriously, and for good reason. States potentially could owe millions of dollars in refunds if more decisions like Gillette are handed down. This risk creates some leverage for taxpayers, and they ought to use that leverage to their advantage during audits."
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