Tax

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."

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.'"

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.

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.  

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.

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.

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.

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.

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.

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.