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Firm News 11 results

Firm News | 8 min read | 08.21.25

The Best Lawyers in America 2026 Recognizes 49 Crowell & Moring Attorneys, One Selected as Lawyer of the Year

Washington – August 21, 2025: The 2026 edition of The Best Lawyers in America® has recognized 49 Crowell & Moring lawyers as Best Lawyers and 33 lawyers as Best Lawyers: Ones to Watch. The publication also named partner Jason Murray as Lawyer of the Year for Antitrust Law in Los Angeles.
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Firm News | 11 min read | 06.05.25

Crowell Attains Leading Rankings in Chambers USA 2025

Washington – June 5, 2025: Crowell & Moring earned 80 rankings for 71 lawyers, as well as 43 national and statewide practice area rankings, in the Chambers USA 2025 guide. The rankings are driven by independent interviews of clients and lawyers at peer firms.

Firm News | 8 min read | 08.15.24

The Best Lawyers in America 2025 Recognizes 42 Crowell & Moring Attorneys, Three Selected as Lawyer of the Year

Washington – August 15, 2024: The 2025 edition of The Best Lawyers in America® has recognized 42 Crowell & Moring lawyers as "Best Lawyers" and 29 lawyers as “Ones to Watch.”
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Client Alerts 53 results

Client Alert | 6 min read | 11.14.25

Relevancy Reigns, But IRS Prevails: Tax Court Holds in Patel Case that Threshold Relevancy Determination Required Prior to Application of Codified Economic Substance Doctrine

On November 12, 2025, the Tax Court issued a reviewed opinion in Patel v. Commissioner holding in favor of the IRS that the taxpayers’ transaction lacked economic substance, and therefore the taxpayers were liable for penalties under the codified economic substance doctrine at the increased penalty rate, as well as accuracy-related penalties. The Court previously held in a separate opinion that the taxpayers’ purported captive transactions did not constitute insurance because they failed to distribute risk, and in the alternative, that the micro-captives did not act as an insurer commonly would. 
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Client Alert | 6 min read | 10.24.25

Will Jarkesy Stop the IRS from Asserting Penalties Against Taxpayers?

In 2024, the U.S. Supreme Court determined that the civil penalties issued by the SEC against individuals for committing securities fraud were unconstitutional because they were levied without a jury trial.[1]
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Client Alert | 3 min read | 10.15.25

Developers Adapt Timelines and Strategies for Wind and Solar Projects Following Recent IRS Guidance and Expected IRS Enforcement Activity

On August 15, 2025, the Treasury Department and IRS released updated guidance concerning Beginning of Construction requirements to qualify for clean energy tax credits. This new guidance is critical for developers to consider as they rush to qualify for the tax credits before they expire entirely. The much-anticipated guidance followed the July 7, 2025 Executive Order 14315, Ending Market Distorting Subsidies for Unreliable, Foreign-Controlled Energy Sources (“July 7, 2025 Executive Order”), which signaled that the Trump Administration was planning to strictly enforce the termination of production and investment tax credits for solar and wind facilities that are set to expire under the One Big Beautiful Bill Act (OBBB Act), covered in more detail here. The new guidance comes at a time when many in the industry are struggling to keep up with the myriad ways that the new administration is working to roll back wind and solar tax credits, leaving developers to piece through the recent guidance to determine how best to structure and invest in clean energy projects given the volatile position of the current administration vis-a-vis wind and solar energy.
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Press Coverage 27 results

Publications 16 results

Publication | August 2024

Transfer of Clean Energy Tax Credits

Practical Law - Reuters

Events 16 results

Event | 10.29.25 - 10.30.25

39th Annual Managing Tax Audits and Appeals Seminar: Resolving Issues with the IRS in the New Enforcement Landscape

In this program, government representatives and experienced tax attorneys will provide timely insights on recent updates. Attendees will gain practical guidance to help taxpayers efficiently and effectively resolve audits and appeals in today’s changed environment.

Event | 11.07.24 - 11.08.24, 8:00 AM EST - 6:30 PM EST

Novogradac 2024 Fall Renewable Energy Tax Credit Conference

On November 7, 2024, Carina Federico will speak at the Novogradac 2024 Fall Renewable Energy Tax Credit Conference. Carina will speak on the panel “Hot Topics and Technical Tax Issues”. This panel will get up to speed on IRS guidance concerning clean energy tax incentives with a particular focus on best practices related to qualifying for and underwriting the following: Prevailing wage and apprenticeship compliance, the Domestic content adder, the environmental justice awards process, unique scenarios involving energy communities and more.

Event | 09.10.24 - 09.12.24

2024 TEI Audits and Appeals Seminar

Offered for the first time since 2022, TEI’s 2024 Audits & Appeals Seminar will examine how Federal and State & Local tax administration has changed after significant new funding at the IRS, including investments in technology, thousands of new professionals hired, and ongoing work on the IRS’ Strategic Operating Plan. These changes continue to have major impacts on business’ tax administration, audits, and appeals - both at the IRS and state and local levels. We will explore these shifts and equip in-house tax professionals with the tools and knowledge to succeed in this new environment.

Webinars 3 results

Webinar | 12.13.24, 1:00 PM EST - 2:30 PM EST

President-Elect Trump’s Impact On the Transportation Industry: A Lightning Round Discussion

This Transportation industry-focused discussion will help you identify, understand, and prepare for the impact of the new administration on your business.

Webinar | 05.25.21, 8:00 AM EDT - 9:00 AM EDT

Biden's Tax Agenda: What's Next?

The current administration is focused on proposing large shifts in tax law that will affect corporate and individual taxpayers, paired with $80 billion to boost the IRS enforcement efforts. Join us to hear about all aspects of Biden’s tax agenda, from legislative proposals in the American Families and Made in America Tax Plan, to Biden’s enforcement initiatives.
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Webinar | 12.10.20, 7:00 AM EST - 8:00 AM EST

Transition 2021: Tax in 2021 and Beyond

Tax will be front and center in 2021. Crowell & Moring tax lawyers will review the new Administration’s tax legislative priorities for the new year and discuss their likely effects. We will also highlight IRS enforcement priorities, and look ahead to hot topics in tax controversy for 2021.
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Speaking Engagements 64 results