Eleanor Moran McWaters is an associate in the Tax Group and resident in the firm’s Washington, D.C. office.
She practices in the areas of tax controversy, litigation, and planning. Eleanor represents clients involved in controversy with the IRS at all levels of the proceedings, including during examination, at appeals, and in litigation before the U.S. Tax Court, Court of Federal Claims, and U.S. District Court.
Eleanor also counsels a variety of tax-exempt organizations, including private foundations, supporting organizations, educational institutions, religious organizations, museums, and trade associations. Her practice includes advice on compliance with the private foundation rules, including self-dealing and excess business holdings. Eleanor routinely advises tax-exempt organizations regarding exemption issues, joint ventures, public charity status, and the consequences of unrelated trade or business activities.
Eleanor received her undergraduate and law degrees from the University of Virginia. She was a member of Phi Beta Kappa, an executive editor of the Virginia Tax Review, and a member of the UVA Law tax competition team in the 2017 KU Leuven International and European Tax Moot Court.
Affiliations
Admitted to practice: District of Columbia, Virginia
Speeches & Presentations
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"Cradle to Crypt(o): Tax Exempts and the Life Cycle of a Cryptocurrency Donation," American Bar Association 2022 May Tax Meeting
(May 13, 2022).
Speaker: Eleanor Moran McWaters.
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"The Ethical Tax Professional in the Digital Age," 2022 Virtual ABA Midyear Tax Meeting, 2022.
(February 3, 2022).
Speakers: Carina Federico and Eleanor Moran McWaters.
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"Developments at the Independent Office of Appeals," Crowell & Moring's Managing Tax Audits and Appeals Seminar 2021
(October 8, 2021).
Speakers: Andy Keyso, David J. Fischer, and Eleanor Moran McWaters.
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"Advance Pricing Agreements and Competent Authority," Crowell & Moring's Managing Tax Audits and Appeals Seminar 2021
(October 7, 2021).
Speakers: John C.C Hughes, David J. Fischer, and Eleanor Moran McWaters.
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"IRS Appeals Procedures and Priorities during the COVID-19 Pandemic; Hot Topics in IRS Enforcement," 2021 TEI Cincinnati-Columbus Ohio Chapter IRS Administrative Affairs Meeting
(January 21, 2021).
Presenters: David J. Fischer, S. Starling Marshall, Carina C. Federico, and Eleanor Moran McWaters.
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"LB&I Procedures and Priorities during the COVID-19 Pandemic," 2021 TEI Cincinnati-Columbus Ohio Chapter IRS Administrative Affairs Meeting
(January 19, 2021).
Presenters: David J. Fischer, S. Starling Marshall, Carina C. Federico, and Eleanor Moran McWaters.
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"Independent Office of Appeals," Crowell & Moring's Managing Tax Audits and Appeals Seminar 2020
(October 9, 2020).
Presenters: David J. Fischer and Eleanor McWaters.
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"Appeals Part One: Overview of the Appeals Process," Crowell & Moring's Managing Tax Audits and Appeals Seminar 2019, Washington, D.C.
(September 13, 2019).
Presenters: David J. Fischer and Eleanor Moran.
Publications
Client Alerts & Newsletters
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"Eighth Circuit Partially Overturns Mayo and the Invalidation of the Primary-Function and Merely-Incidental Requirements in Treasury Regulations,"
Tax Alert
(May 21, 2021).
Contacts: Charles C. Hwang, Eleanor Moran McWaters
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"Contractor vs. Client: Research Tax Credit Update,"
Tax Alert
(January 20, 2021).
Contacts: Dwight N. Mersereau, Eleanor Moran McWaters
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"Chief of Appeals Keyso Discusses Effect of COVID 19 on IRS Appeals at Crowell & Moring Tax Seminar,"
Tax Alert
(October 21, 2020).
Contacts: David J. Fischer, Eleanor Moran McWaters
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"Supreme Court Declines Certiorari in Altera, Stock-Based Compensation Cost Sharing Regulations Stand,"
Tax Alert
(June 26, 2020).
Contacts: David J. Fischer, Eleanor Moran McWaters
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"Deductions for Charitable Contributions during the Pandemic: Five Things to Know,"
Tax Alert
(May 7, 2020).
Contacts: Dwight N. Mersereau, Eleanor Moran McWaters
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"Proposed Regulations Change Calculation of Unrelated Business Taxable Income, Reducing Administrative Burden and Taxes Paid by Some Exempt Organizations,"
Tax Alert
(May 1, 2020).
Contacts: Charles C. Hwang, Eleanor Moran McWaters
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"IRS Issues Welcomed Guidance on Carbon Capture Tax Credit,"
Tax Alert
(March 2, 2020).
Contacts: David B. Blair, David J. Fischer, Eleanor Moran McWaters
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"District Court Invalidates the "Primary Purpose" and "Merely Incidental" Requirements of Treasury Regulation Defining "Educational Organization","
Tax Alert
(October 7, 2019).
Contacts: Charles C. Hwang, Eleanor Moran McWaters
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"Director of APMA Hughes Discusses APAs and MAP at Crowell & Moring Tax Seminar,"
Tax Alert
(September 27, 2019).
Contacts: David J. Fischer, Eleanor Moran McWaters
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"Deputy Chief of Appeals Keyso Discusses Conferencing Initiative at Crowell & Moring Tax Seminar,"
Tax Alert
(September 25, 2019).
Contacts: David J. Fischer, Eleanor Moran McWaters
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"IRS Issues Guidance on Taxation of Cloud Transactions,"
Tax Alert
(August 15, 2019).
Contact: Eleanor Moran McWaters
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"Ninth Circuit Revisits Altera and Again Reverses Tax Court,"
Tax Alert
(June 20, 2019).
Contacts: David J. Fischer, Eleanor Moran McWaters
Firm News & Announcements