Irina Pisareva is a partner in the New York office of Crowell & Moring. She has 25 years of experience advising businesses and investors on transaction tax and cross-border tax matters.
Irina’s most recent practice focused on providing tax advice to investment funds, corporations, tax-exempt investors, venture capital and private equity groups and high net worth individuals and family offices. She also advises clients on tax compliance and tax operational issues relevant to cross-border investments, credit and distressed debt transactions, global securities trading and mobile workforce. She is a frequent contributor on these topics and has been quoted in Law360 and Bloomberg Law.
Irina also practices in the growing area of litigation finance. She provides tax advice to litigation funders, private equity firms, and multi-strategy hedge fund clients in connection with their investments in funding transactions, including claims monetization and the provision of non-recourse capital to both plaintiffs and law firms. Irina’s other areas of professional focus include taxation of novel asset classes, such as crypto currency.
Irina is a well-regarded international tax adviser with significant experience in international taxation of corporations, partnerships and their investors. She frequently advises her clients on recent U.S. and global tax developments (e.g., BEAT, GILTI, FDII, OECD and BEPS initiatives). Irina has led multiple complex cross-border operational transformation and restructuring projects for U.S. and non-U.S. based multinationals including design, implementation and reporting for tax and financial statement purposes. She has assisted her clients with various aspects of digitally transforming and automating their tax function, obtaining private letter rulings in multiple jurisdictions, managing withholding tax obligations and refunds and matters related to transfer pricing documentation and controversy.
Irina is an active member of the New York City Bar Association and is a member of its Private Investment Funds and Taxation of Business Entities Committees. She is also a member of the International Bar Association and multiple other professional organizations.
Prior to joining the firm, Irina was a partner with Sullivan & Worcester LLP and before that a senior tax partner with EY. Her most recent publication is the chapter on the USA corporate tax laws and regulations which she has co-authored for the GLI’s Global Tax Laws and Regulations 2021.
Representative Matters
- Structured distressed debt and infrastructure credit funds; assisted a large institutional asset manager with structuring a loan origination fund, based on investor type, with some of the options resulting in 0% effective tax rate.
- Advised a litigation funding provider on tax aspects of providing litigation funding in Germany and Greece.
- Advised private equity firms on the implications of the 2017 Tax Cuts and Jobs Acts for its portfolio companies; assisted private equity firms with diligence and structuring of new investments including in the life science and high-tech industries.
- Advised mutual fund managers on transfer pricing, informational reporting, withholding tax reclaim and tax compliance matters related to cross-border securities trading and fund structures.
- Designed and implemented ASC 740 assessment and documentation processes for multiple hedge funds and institutional asset managers.
- Structured investment vehicles for sovereign wealth funds and tax-exempt investors.
- Advised on foreign investment in real estate and natural resource assets worldwide, airplane leasing structures, CLOs and other asset securitization vehicles.
- Advised on global workforce projects, including payroll, intellectual property management, taxable presence and individual tax implications of expatriate assignments.
- Advised on U.S. and international tax implications of litigation finance strategies.
- Assisted investment managers with setting up investment management companies in the UK, Singapore, Hong Kong, New Delhi and Chile, among others.
- Advised high-net-worth individuals (HNWI) and executives on global relocation, estate management matters and succession planning. Structured private businesses, including acquisitions, divestitures for HNWI and family offices and advised on tax implications of their investment portfolios and real estate holdings.
Speeches & Presentations
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"Looking Over the Horizon," Managing Tax Audits and Appeals Seminar 2022, Washington, D.C.
(October 7, 2022).
Speaker: Irina Pisareva and Eric Homsi.
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"Tax Treatment of S Corp Distributions: Income and Deduction Rules, Basis, Salary vs. Income, Tax Distributions," Strafford Webinar
(April 6, 2022).
Speakers: Irina Pisareva and Eric Homsi.
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"Hot Topics in Litigation Finance," The Association of Commercial Finance Attorneys Webinar
(March 29, 2022).
Panelist: Irina Pisareva.
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"Global and U.S. Tax Reform Update," Federal Bar Association - 2022 Tax Law Conference Webinar
(March 4, 2022).
Speaker: Irina Pisareva.
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"Green Energy Tax Incentives to Advance American Infrastructure," Crowell & Moring Webinar
(January 13, 2022).
Speakers: David B. Blair, Adelicia R. Cliffe, Irina Pisareva, and Eric Su.
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"IRC Section 367 Outbound Transfers of Assets: Identifying Transactions, Reporting Requirements and Exceptions," Strafford Webinar
(December 1, 2021).
Panelists: Irina Pisareva, Anthony V. Diosdi.
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"China Advance Pricing Arrangement: An Effective Tool for Cross Border Tax Planning," Crowell & Moring Webinar
(October 27, 2021).
Speakers: David B. Blair, Jackson C. Pai, Irina Pisareva, and Ye Zhou, Ph.D.
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"Partnerships: The New BBA Audit Regime Kicks into Gear," Crowell & Moring's Managing Tax Audits and Appeals Seminar 2021
(October 5, 2021).
Speakers: Charles C. Hwang, Eric Homsi, and Irina Pisareva.
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"Understanding the Impact of the Organisation for Economic Co-Operation and Development’s Base Erosion and Profit Shifting (BEPS) Project," Crowell & Moring's Managing Tax Audits and Appeals Seminar 2021
(October 4, 2021).
Speakers: S. Starling Marshall and Irina Pisavera.
Publications
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"New Legislation Positions New York To Become A Leading U.S. Chip Production Hub," Westlaw Today
(September 12, 2022).
Authors: Irina Pisareva, and Eric Su.
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"The Importance of an 83(b) Election for Startup Founders," GrowthStudio
(May 2, 2022).
Authors: Anthony Provenzano, Irina Pisareva, Hillary Webb, and Matthew Moisan
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"Build Back Better Green Energy Tax Credit Proposals: Direct Pay," Bloomberg Tax
(February 24, 2022).
Authors: David B. Blair, and Irina Pisareva.
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"Build Back Better Green Energy Tax Credit Proposals: Buy America," Bloomberg Tax
(February 23, 2022).
Authors: David B. Blair, Addie R. Cliffe, Irina Pisareva.
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"Build Back Better Green Energy Tax Credit Proposals: Labor Laws," Bloomberg Tax
(February 22, 2022).
Authors: Ira M. Saxe, David B. Blair, Eric Su, and Irina Pisareva.
Client Alerts & Newsletters
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"IRS Issues New Guidance on Sustainable Aviation Fuel Credit,"
Tax Alert
(January 13, 2023).
Contacts: Irina Pisareva, Christopher B. Younger
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"IRS Issues Guidance on the Inflation Reduction Act’s Clean Vehicle Provisions and Treasury Releases White Paper on Forthcoming Critical Minerals and Battery Guidance,"
Tax Alert
(January 10, 2023).
Contacts: Irina Pisareva, Tyler A. O'Connor, Byron R. Brown
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"Treasury, IRS Provide Transitional Guidance for Broker Reporting on Digital Assets,"
Tax Alert
(January 5, 2023).
Contacts: Irina Pisareva, Charles C. Hwang
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"Internal Revenue Service and Department of Labor Issue Guidance on Prevailing Wage and Apprenticeship Requirements Under the Inflation Reduction Act,"
Tax Alert
(December 15, 2022).
Contacts: Ira M. Saxe, Eric Su, Irina Pisareva, Eric Homsi, Katie Aber
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"Inflation Reduction Act Increases Utilization of Research Credit by Small and Emerging Businesses,"
Tax Alert
(August 19, 2022).
Contacts: Irina Pisareva, Charles C. Hwang
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"New Legislation Positions New York to Become A Leading U.S. Chip Production Hub,"
Tax Alert
(August 18, 2022).
Contacts: Irina Pisareva, Eric Su
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"President Biden To Sign New Inflation Reduction Act,"
Biden 2021 Series
(August 15, 2022).
Contacts: Byron R. Brown, Rebecca Baden Chaney, Stephanie L. Crawford, James G. Flood, Eric Homsi, Irina Pisareva, Mary-Caitlin Ray, Tim Shadyac, Siyi Shen, Hillary C. Webb, Scott L. Winkelman
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"The CHIPS Bill Introduces New Tax Credit to Incentivize U.S. Semiconductor Industry,"
Government Contracts Bullet Points
(August 3, 2022).
Contact: Irina Pisareva
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"President Biden Employs Defense Production Act and Tariff Act in Domestic Clean Energy Manufacturing Push,"
Government Contracts Bullet Points
(June 7, 2022).
Contacts: Stephanie L. Crawford, Irina Pisareva, Jonathan M. Baker, Paul Freeman, Larry F. Eisenstat, Robert L. LaFrankie, John B. Brew
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"Deposit Penalty Relief for Superfund Chemical Taxes,"
Tax Alert
(April 18, 2022).
Contact: Irina Pisareva
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"President Biden Issues Executive Order Directing “Whole of Government” Assessment of Digital Assets,"
Financial Services Alert
(April 5, 2022).
Contacts: Alexander Urbelis, Anand Sithian, Stephanie L. Crawford, Caroline E. Brown, Richard J. Lee, Irina Pisareva, Carlton Greene
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"SEC Announces 2022 Examination Priorities,"
Financial Services Alert
(April 1, 2022).
Contacts: Carlton Greene, Anand Sithian, Irina Pisareva, Richard J. Lee, Nimrod Haim Aviad, Caroline E. Brown, Alexander Urbelis
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"Overview of the Tax Provisions in the Infrastructure Investment and Jobs Act,"
Tax Alert
(November 15, 2021).
Contacts: Irina Pisareva, Anthony G. Provenzano
Press Coverage
Firm News & Announcements