Insights

A Crowell team served as special tax counsel to Sweden-based music investment firm Pophouse Entertainment in its recent acquisition of the music catalogue, brand name, and intellectual property of iconic American rock band Kiss.  

Washington – August 17, 2023: The 2024 edition of The Best Lawyers in America® has recognized 47 firm lawyers as "Best Lawyers" and 41 lawyers as “Ones to Watch.”

Washington – June 1, 2023: Crowell & Moring earned 82 rankings for 68 lawyers across 48 categories, as well as 37 national and statewide practice area rankings, in the Chambers USA 2023 guide. The rankings are driven by independent interviews of clients and lawyers at peer firms.

Tax partner Carina Federico and Tax counsel Eleanor Moran McWaters discuss IRA and Tax Exempt Entities.

Tax partner and co-chair Starling Marshall and tax partner Carina Federico discuss where they predict tax disputes may arise with the IRS related to the IRA clean energy provisions. 

Last week, the IRS announced plans to begin a campaign to audit personal use of business aircraft. The audits will focus on whether large corporations, partnerships and high-and ultra-high net worth aircraft owners have properly reported their business and personal aircraft usage for tax purposes, with a particular focus on ensuring that owners are only taking deductions to which they are entitled. Given the value of an aircraft, the amount of a deduction for aircraft related expenditures on a given taxpayer’s return can be in the tens of millions of dollars, and with more than 10,000 corporate jets operating in the U.S., IRS Commissioner Daniel Werfel recognized that much is at stake with this campaign.  The audit campaign is expected to focus initially on multinational and domestic corporations and complex partnerships but is expected to expand from there.

The IRS has been underfunded for many years, but that changed significantly with the landmark Inflation Reduction Act of 2022 (IRA), which gave the agency an additional $80 billion to be spent over 10 years. Unlike annual congressional allocations, this has allowed the IRS to make long-term investments and plans. It is clear the agency’s strategy includes heightened scrutiny for various corporate tax credits.

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.

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.