In the News
Growing IRS Reliance on Informal Guidance Sows Uncertainty
August 6, 2015 — Law360
Jennifer A. Ray, a Washington, D.C.-based partner in the firm's Tax Group, discusses with Law360 the impact of funding cuts on the Internal Revenue Service (IRS). The cuts have delayed the IRS' ability to place regulations on controversial tax issues, which leads them to only issue guidance's in the form of notices. However, Ray states, "The notices don't have the force of a full regulation, but sometimes that is all taxpayers have to go on, leaving them uncertain about what the IRS' position is."
20 Percent Additional Tax Applies to Retention Bonus
May 12, 2015 — Law360
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 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.'"
4 Tips for Negotiating IRS Advance Pricing Agreements
March 27, 2015 — Law360
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.
From Lateral to Chairwoman in Eight Years at Crowell & Moring
March 16, 2015 — The National Law Journal
Newly elected Crowell & Moring chair Angela B. Styles, partner and co-chair of the Government Contracts Group, is profiled by The National Law Journal. Styles discusses her childhood, past experience in both the federal government and private practice, and how she arrived at Crowell & Moring. When referring to the firm's visions for the firm's future, Styles notes that she plans "not growing for growth's sake," and hopes to strengthen practices such as cybersecurity and health care while maintaining the firm's government contracts, regulatory, and litigation reputation.
Crowell & Moring Law Firm Names Angela Styles As Chair
March 10, 2015 — The Washington Post
Newly-elected chair of Crowell & Moring, Angela B. Styles, is featured in The Washington Post's "Capital Business" section after assuming her new role. The article notes that Styles, who joined the firm in 2007, is the second woman to serve as chair in firm history. "I am honored to serve as chair of Crowell & Moring and to be part of a long tradition of firm leaders who have helped to build a truly unique firm over the past 35 years," Styles said.
Angela Styles, Government Contracts Lawyer, Named Chair of Crowell & Moring
March 9, 2015 — The National Law Journal
The National Law Journal reports the news that Angela Styles, partner and co-chair of Crowell & Moring's Government Contracts Group, has been elected as the firm's new chair. Referring to her predecessor, Kent A. Gardiner, who stepped down due to term limits, Styles notes: "It's a pretty good foundation I have to start with. I'm sure I will change some things. But we're at such a good place right now, we just need to keep thinking forward," she said.
@Work Advice: When Your Company Plays Fast and Loose with Your Retirement Savings
February 20, 2015 — The Washington Post Magazine
Crowell & Moring's Washington, D.C.-based counsel and member of the firm's ERISA & Employee Benefits Group, Joel D. Wood addresses a question regarding concerns over employee-sponsored retirement plans for the weekly Washington Post Magazine column focused on wide-ranging questions affecting the workplace. This particular column featured inquires about legal issues related to retirement savings in the workplace.
At Some D.C. Firms, More Women Than Men Make Partner
January 19, 2015 — National Law Journal
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
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.
2014 Federal Tax Litigation In Review
December 19, 2014 — Law360
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.
Netflix Streaming Suites Highlight Tax-Tech Mismatch
March 24, 2014 — Tax Analysts
Walter Nagel, a Washington, D.C.-based Tax Group partner, discusses the important difference between streaming and cable and how the different ways consumers watch television can and should be taxed. He says, "Streaming may be like cable from a comsumer perspective, but there is a fundamental difference between streaming and cable… cable is served to customers in a very real, tangible way, but with streaming, there is this nexus piece that is missing."
BNA Videos: Crowell's Conversations in Bloomberg BNA
February 21, 2014 — Bloomberg BNA
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.
Practitioners Anticipate a Resurgence of Due Process Nexus Litigation
November 1, 2013 — 2013 State Tax Today 212-1
Don Griswold, partner in Crowell & Moring's Tax Group and member of the Washington, D.C. office, is quoted from the 20th annual Paul J. Hartman State & Local Tax Forum about recent developments in the U.S. Supreme Court's due process jurisprudence. He notes, "In just the past couple of years, we've seen almost a revolution of thinking about due process minimum contacts, due process nexus, due process jurisdiction."
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"
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."
Crowell & Moring Tax Partner Offers Insight on Whistleblowers to Tax Notes
September 10-14, 2012 — Tax Notes
Washington, D.C.-based Tax Group partner David Blair shares his thoughts on the impact of the Birkenfeld award and tax reserve reporting in September issues of Tax Notes.
Face Time, Surveys Boost Client Service At 17 Firms: GCs
November 30, 2011 — Legal Industry Law360
Crowell & Moring is listed among 17 firms that received praise from corporate counsel for improving their client focus in the BTI Client Service A-Team 2012 report by the BTI Consulting Group Inc.
According to the article, “While many firms have been increasing their emphasis on client service to remain competitive, a few made strong pushes toward more in-person meetings, satisfaction surveys and follow-up calls this year, earning them the designation of most improved in a new survey of corporate counsel.”
Company Lawyers Sniff Out Revenue
May 11, 2011 — The Wall Street Journal
Crowell & Moring LLP is highlighted for its corporate plaintiff's recovery practice in this story about how in-house counsel are turning their legal departments into profit centers. Major companies, such as DuPont Co., Ford Motor Co., Tyco International Ltd., and Michelin SCA, among others, say their lawyers are devoting more time and effort to bringing in extra cash by thinking like plaintiffs.
Crowell & Moring chairman Kent A. Gardiner told The Wall Street Journal that the firm’s docket of such cases has doubled over the past five years. The firm’s recovery efforts for clients include a full suite of practice areas, ranging from tax and customs to intellectual property and antitrust.