When clients face complex commercial and tax disputes, they rely on S. Starling Marshall as their advocate and counselor. Starling is a trial lawyer with over 15 years of experience who has successfully represented clients before federal and state courts, arbitration panels, and administrative tribunals. Drawing on her years of government service and private practice, she guides clients toward business-minded solutions throughout all phases of an investigation or litigation.
Starling is a partner in the Litigation and Tax groups in the firm’s New York office. In addition to representing clients in all stages of litigation, she guides clients through complex IRS audits and administrative appeals, provides tax-related advice, conducts internal investigations, and represents individuals and corporate entities in criminal tax matters.
Prior to entering private practice, Starling served as a trial attorney in the U.S. Department of Justice’s Tax Division. During her time at the DOJ, she litigated cases before federal district courts and the Court of Federal Claims. Starling focused on complex tax shelter matters involving partnerships and penalty issues and cases in the energy industry, including cases involving Section 1603 grants for renewable energy projects and nuclear decommissioning liabilities. For her service, the DOJ awarded her the Outstanding Attorney Award (2015) and the Special Commendation for Outstanding Contribution (2013). From 2010 to 2014, Starling worked with the DOJ’s Office of Legal Policy to vet candidates for the federal judiciary.
From 2008 to 2009, Starling served as a law clerk to the Hon. Victor Marrero of the U.S. District Court for the Southern District of New York.
Her pro bono work includes serving as lead counsel with the American Civil Liberties Union’s Immigrant Rights Project and with ACLU-Utah in a Bivens action against U.S. marshals who raided a family’s home on two successive days. Starling received the New York County Lawyers Association Conspicuous Service Award for authoring a chapter in “Commercial Litigation in New York State Courts,” fifth edition, a joint venture of Thomson Reuters and the New York County Lawyers Association.
Affiliations
Professional Activities and Memberships
- J. Edgar Murdock Inn of Court, 2013-present
- Dave Nee Foundation, President of the Board of Directors, 2013-present
- Fordham Law Alumni Association of Washington, President of the Board of Directors, 2012-2016
- Federal Bar Association - New York Chapter, 2016-present; Taxation Steering Committee, 2012-present
- American University's Washington College of Law, Adjunct Professor, 2012-2016
Speeches & Presentations
-
"In Re Grand Jury," Beverly Hills Bar Association
(May 2023).
Presenter: S. Starling Marshall.
-
"ABA Section of Taxation 2023 MidYear Tax Meeting," American Bar Assocation, San Diego, CA.
(February 11, 2023).
Speaker: S.Starling Marshall.
-
"Navigating Privilege in the Audit Context," Managing Tax Audits and Appeals Seminar 2022, Washington, D.C.
(October 7, 2022).
Speakers: S. Starling Marshall and Reid Tomasello.
-
"Best Practices for Responding to IDRs, Including Privilege and Controlling Information Flow in an Audit Setting", TEI 2022 Audits & Appeals Seminar, Tysons, VA.
(September 21, 2022).
Speaker: S. Starling Marshall.
-
"Campaigns and Cases Impacting Multinationals," 50th Annual Conference of the USA Branch of the International Fiscal Association, Washington, D.C.
(June 3, 2022).
Speaker: S. Starling Marshall.
-
"Cross-Border Enforcement Trends: Taxpayer Responses to New Enforcement Strategies," ABA's Webinar, 2022.
(March 30, 2022).
Speaker: S. Starling Marshall.
-
"72nd Midyear Conference"
(March 20, 2022).
Speakers: Starling Marshall.
-
"Positioning Your Transportation Disputes in a Supply-Constrained Era: Emerging Strategies in Force Majeure and Allocation" Eighth Annual In-House Recovery Conference, Dana Point, CA
(March 10, 2022).
Panelists: S. Starling Marshall and Chahira Solh.
-
"Welcome Remarks," Federal Bar Association - 2022 Tax Law Conference Webinar
(March 4, 2022).
Speaker: S. Starling Marshall.
-
"Crowell & Moring and Detroit Tax Executives Institute Chapter 2022," IRS Administrative Affairs Webinar
(February 16, 2022).
Speakers: David B. Blair, S. Staring Marshall, Carina C. Federico.
-
"Penalty Defense," Crowell & Moring's Managing Tax Audits and Appeals Seminar 2021
(October 5, 2021).
Speakers: S. Starling Marshall and Carina C. Federico.
-
"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.
-
"The Charging Stations," Crowell & Moring Webinar
(July 1, 2021).
Speakers: Thomas Lorenzen, S. Starling Marshall, and Byron Brown.
-
"Changing Approaches to IRS Tax Enforcement: An Assessment," Tax Executives Institute (TEI) 71st Midyear Conference
(March 25, 2021).
Panelist: S. Starling Marshall.
-
"Keep it Between Us: Recent Developments in Attorney/Client and Tax Practitioner Privileges and Work Product Protections in Tax Cases," Federal Bar Association [Virtual] Tax Law Conference
(March 4, 2021).
Presenter: S. Starling Marshall.
-
"TEI Detroit Chapter," 2021 IRS Administrative Affairs Meeting
(February 23, 2021).
Presenters: David J. Fischer, S. Starling Marshall, and Teresa Abney.
-
"Biden First 100 Days: A Look at the Laws Impacting the New Administration’s Regulatory Priorities," Crowell & Moring Webinar
(January 22, 2021).
Presenters: Amanda Shafer Berman, Daniel W. Wolff, S. Starling Marshall, and Byron R. Brown.
-
"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.
-
"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.
-
"Transition 2021: Tax in 2021 and Beyond," Crowell & Moring Webinar
(December 10, 2020).
Presenters: David J. Fischer, S. Starling Marshall, Eric Homsi, and Carina C. Federico.
-
"What are the legal implications of extended remote work arrangements?" Crowell & Moring Webinar
(December 9, 2020).
Presenters: Gregory D. Call, Thomas P. Gies, Kate M. Growley, S. Starling Marshall, and Nicole Janigian Simonian.
-
"Is Congress likely to pass another COVID stimulus bill and what is the latest thinking on what that may mean for companies?" Crowell & Moring Webinar
(December 9, 2020).
Presenters: James G. Flood, S. Starling Marshall, Byron R. Brown, W. Scott Douglas, and Tim Shadyac.
-
"Asserting and Protecting Your Privilege Claims During an Audit," Crowell & Moring's Managing Tax Audits and Appeals Seminar 2020
(October 8, 2020).
Presenters: S. Starling Marshall and Robert L. Willmore.
-
"Introduction to the Joint Committee on Taxation," Crowell & Moring's Managing Tax Audits and Appeals Seminar 2020
(October 7, 2020).
Presenters: S. Starling Marshall and John Arszulowicz.
-
Election 2020 and the Implications for Your Business
(September 3, 2020).
Presenters: Byron R. Brown, Robert A. Burton, Jodi G. Daniel, James G. Flood, Thomas P. Gies, Ambassador Robert Holleyman, S. Starling Marshall, and W. Scott Douglas.
-
"Tax Relief is Here: How to Take Advantage and is There More to Come?" Crowell & Moring Webinar
(April 3, 2020).
Presenters: David B. Blair, S. Starling Marshall, Teresa Abney, and Eric Homsi.
-
"What’s Next for Your Employees: Congress Responds with New Rules for Employment and Benefit Programs," Crowell & Moring Webinar
(April 2, 2020).
Presenters: Thomas P. Gies, David McFarlane, S. Starling Marshall, and Christine B. Hawes.
-
"The Big Picture: Top Ten Things You Need to Know About the COVID-19 Stimulus Law," Crowell & Moring Webinar
(March 30, 2020).
Presenters: James G. Flood, W. Scott Douglas, Paul J. Pollock, Scott A. Lessne, Amy Laderberg O'Sullivan, S. Starling Marshall, Thomas P. Gies, Jacinta Alves, and Jerrica Mathis.
-
"Challenges for the Taxation of the Digital Economy," Leading Women in Tax Forum 2020, New York, NY
(March 3, 2020).
Panelist: S. Starling Marshall.
Publications
Client Alerts & Newsletters
-
"Supreme Court Ruling Reduced Taxpayer’s Penalties by $2.67 Million,"
Tax Alert
(March 6, 2023).
Contacts: S. Starling Marshall, Carina C. Federico, Carlton Greene, Samantha Skabelund
-
"IRS Commissioner Nominee Daniel Werfel Testifies Before Senate Finance Committee,"
Tax Alert
(February 24, 2023).
Contacts: Carina C. Federico, S. Starling Marshall, James G. Flood
-
"Supreme Court Weighs Whether “Dual Purpose” Communications Are Privileged in In re Grand Jury,"
Tax Alert
(January 11, 2023).
Contacts: Carina C. Federico, S. Starling Marshall, Meshach Y. Rhoades, Rebecca Monck Ricigliano, Stephen J. McBrady, Peter Eyre
-
"Key Takeaways From Crowell’s 2022 Transportation & Logistics Industry Workshop,"
(March 31, 2022).
Contacts: Meagan T. Bachman, Lorraine M. Campos, Rebecca Baden Chaney, S. Starling Marshall, Chahira Solh, Byron R. Brown, Mary-Caitlin Ray
-
"Recent Tax Changes Affecting Research and Development Expenses and Credit Claims,"
Tax Alert
(March 9, 2022).
Contacts: S. Starling Marshall, Carina C. Federico
-
"Anti-Injunction Suit Doesn’t Bar APA Challenge to Tax-Penalty Backed Reporting Requirement,"
Tax Alert
(May 20, 2021).
Contacts: S. Starling Marshall, Daniel W. Wolff
-
"Biden Administration Asks Congress for $80 Billion to Increase Enforcement Efforts and Announces Sweeping Legislative Agenda for Individual and Corporate Tax Enforcement,"
Administrative Law Alert
(May 11, 2021).
Contacts: Carina C. Federico, S. Starling Marshall
-
"Biden’s First 100 Days: Developments to Date and What Lies Ahead,"
Administrative Law Alert
(May 7, 2021).
Contacts: James G. Flood, Michael K. Atkinson, Tim Shadyac, Troy A. Barsky, Byron R. Brown, Caroline E. Brown, Robert A. Burton, Matthew Cohen, Kelly T. Currie, Jodi G. Daniel, W. Scott Douglas, Carina C. Federico, Paul Freeman, Thomas P. Gies, Alexis J. Gilman, Christine B. Hawes, Robert Holleyman, Stacie Heller, S. Starling Marshall, Shelley Su, Jeane A. Thomas, CIPP/E, Scott L. Winkelman, Tiffany Wynn, Kate Beale
-
"Patent litigation fees deductible, Tax Court Rules,"
Tax Alert
(May 4, 2021).
Contacts: Anne Elise Herold Li, S. Starling Marshall
-
"IRS Continues to Boost Enforcement Efforts with New Promotor Investigation Office,"
Administrative Law Alert
(April 26, 2021).
Contacts: Carina C. Federico, S. Starling Marshall, Glen G. McGorty, Lisa Nicole Umans
-
"Biden Administration Plans Tax Bill to Fund Economic Recovery, Appoints Lily Batchelder to Assistant Secretary for Tax Policy, U.S. Department of Treasury,"
Administrative Law Alert
(March 18, 2021).
Contacts: Carina C. Federico, James G. Flood, S. Starling Marshall, W. Scott Douglas, Tim Shadyac
-
"New Developments for Employers and PPP Loan Borrowers,"
Administrative Law Alert
(March 15, 2021).
Contacts: S. Starling Marshall, Eric Homsi
-
"Maryland's Digital Advertising Tax: A Contentious Start, and an Uncertain Future,"
Administrative Law Alert
(February 19, 2021).
Contacts: S. Starling Marshall, Preetha Chakrabarti, Roy A. Abernathy
-
"Biden Administration Appoints Four to Positions in Office of Tax Policy, Department of Treasury; IRS Announces Director of Taxpayer First Office,"
Administrative Law Alert
(February 8, 2021).
Contacts: Carina C. Federico, S. Starling Marshall
-
"The Biden Administration Begins: The Pandemic, Economy, and Changing Course,"
Administrative Law Alert
(January 18, 2021).
Contacts: James G. Flood, Thomas P. Gies, S. Starling Marshall, W. Scott Douglas, Stacie Heller, Tim Shadyac
-
"Transition 2021: Shining a Light on Midnight Rules and the Biden Regulatory Agenda,"
Biden 2021 Series
(January 13, 2021).
Contacts: Byron R. Brown, S. Starling Marshall, Daniel W. Wolff
-
"Permanent Establishment Risks Arising From Sending Employees to China,"
(December 28, 2020).
Contacts: S. Starling Marshall, Nicole Janigian Simonian, Zhongdong Zhang, Yi Huang, Jackson C. Pai, Ye Zhou, Ph.D.
-
"Congress Passes Combined COVID-19 Relief and Omnibus Spending Bill,"
(December 23, 2020).
Contacts: Troy A. Barsky, Peter Eyre, James G. Flood, Glenn D. Grant, Olivia Lynch, S. Starling Marshall, Amy Laderberg O'Sullivan, Paul J. Pollock, Michael E. Samuels, Tim Shadyac
-
"Remote Working Abroad: 10 Tips for Global Employers,"
Labor & Employment Law Alert - US
(November 30, 2020).
Contacts: Nicole Janigian Simonian, Emmanuel Plasschaert, Maarten Stassen, S. Starling Marshall, Robert Clifton Burns, Evelien Jamaels, Jackson C. Pai, Yi Huang
-
"Treasury Issues Guidance on Trump’s "Payroll Tax Holiday","
Tax Alert
(September 1, 2020).
Contact: S. Starling Marshall
-
"NOL Carryback Waiver Guidance for Consolidated Groups,"
Tax Alert
(August 4, 2020).
Contacts: Charles C. Hwang, S. Starling Marshall, Eric Homsi
-
"Top Questions Answered by New Section 162(f) Regulations,"
Tax Alert
(May 13, 2020).
Contact: S. Starling Marshall
-
"Continuing Uncertainty Around Loan Forgiveness in the Paycheck Protection Program,"
Government Contracts Bullet Points
(May 12, 2020).
Contacts: Olivia Lynch, S. Starling Marshall, Amy Laderberg O'Sullivan, Paul J. Pollock
-
"IRS Issues Guidance on the Employee Retention Credit: Who Can Claim It and How Much?,"
Tax Alert
(May 1, 2020).
Contact: S. Starling Marshall
-
"IRS Provides Relief to Taxpayers and IRS for Deadlines, "Time Sensitive" Actions,"
Tax Alert
(April 17, 2020).
Contact: S. Starling Marshall
-
"Top 5 Tax Benefits to Battle COVID-19 Impacts,"
Tax Alert
(April 2, 2020).
Contacts: S. Starling Marshall, Eric Homsi
-
"Mnuchin Encourages Businesses to Take Advantage of Payroll Retention Credit, and IRS Paves the Way with New Guidance and Form,"
Tax Alert
(April 1, 2020).
Contact: S. Starling Marshall
-
"Summary of COVID-19 (Coronavirus) Stimulus Legislation,"
Tax Alert
(March 27, 2020).
Contacts: James G. Flood, Robert Holleyman, Tim Shadyac, S. Starling Marshall, Laurel Pyke Malson, W. Scott Douglas, Thomas P. Gies, Scott Lessne, Eric Homsi, David W. O'Brien, Matthew Vicinanzo, Trey Flowers, Peter Gray, Lisa Kimmel, Ph.D.
-
"IRS Announces Extension to File,"
Tax Alert
(March 24, 2020).
Contact: S. Starling Marshall
-
"U.S. Treasury Action in Response to COVID-19,"
Tax Alert
(March 19, 2020).
Contact: S. Starling Marshall
-
"IRS Releases First Cryptocurrency Tax Guidance Since 2014,"
Tax Alert
(October 10, 2019).
Contacts: Carina C. Federico, Charles C. Hwang, S. Starling Marshall
Press Coverage
-
‘A Double-Edged Sword’: Why Young Judges Might Not Stick Around
February 3, 2023 — The National Law Journal
-
‘I’m Disappointed.’ Lawyers React to SCOTUS Setting Aside Attorney-Client Privilege Case
January 23, 2023 — The National Law Journal
-
Who Won Monday's SCOTUS Arguments Over Attorney-Client Privilege?
January 9, 2023 — Supreme Court Brief
-
Narrow Path Paved For Tax Rule Challenges After CIC Services
July 23, 2021 — Law360
-
IRS Crypto Crackdown Poised To Go Global
May 28, 2021 — Law360
-
More Prosecutions Likely In IRS Scheme Promoter Crackdown
April 23, 2021 — Law360
-
Federal Tax Cases To Watch In 2021
January 3, 2021 — Law360
-
Federal Tax Regs To Watch In 2021
January 3, 2021 — Law360
-
6 Captivating Tax Opinions By Justice Ginsburg
September 21, 2020 — Law360
-
Biden Win Could Spur Flurry Of Corp. Sales And Recognitions
August 5, 2020 — Law360
-
Federal Tax Policy To Watch In The 2nd Half Of 2020
July 13, 2020 — Law360
-
Utah Family Sues Parole Agents, Alleging Illegal Forced Entry And Arrests
January 30, 2020 — Deseret News
-
De Minimis Exception Could Hinder Crypto Tax Administration
November 19, 2019 — Law360
-
IRS Cryptocurrency Guidance Leaves Unanswered Questions
October 11, 2019 — Law360
-
Former DOJ Atty Named Partner At Crowell & Moring
September 23, 2019 — Law360
Firm News & Announcements