Insights

New York – July 13, 2023: The National Law Journal has named Crowell & Moring partner S. Starling Marshall to its 2023 list of Tax Law Trailblazers. The list features lawyers who are “agents of change” and have made significant marks on their sector.

New York – June 21, 2023: Crain’s New York Business named Crowell & Moring partner S. Starling Marshall to its annual Notable Women in Law list. The publication sought to recognize “women at the pinnacle of their profession whose impact radiates well beyond the clients they serve.”

Washington – August 18, 2022: The 2023 edition of The Best Lawyers in America® has recognized 54 firm lawyers as "Best Lawyers" and 32 lawyers as “Ones to Watch.”

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.

This week, IRS Commissioner Daniel Werfel informed a crowd at a conference that the IRS was looking to reset its approach to ERC claims after implementing a moratorium on processing claims in September. Mr. Werfel communicated that the IRS is focused on changing the way it processes these claims and on communicating the eligibility criteria to taxpayers. He also indicated a willingness to work with employers who received the credit, but were not actually entitled to it, allowing taxpayers to pay back the funds to the IRS in a way that works for their businesses.

The Virtual 22nd Annual U.S. and Europe Tax Practice Trends Conference will focus on practical tax practice trends for multinational corporations and their international advisors, as well as provide insight into how government tax officials may view the international tax landscape in light of important international developments that impact corporate taxpayers. Panelists will include industry leaders, senior government and OECD officials, and leading tax practitioners. Starling Marshall will be speaking on panel "Cross-Border Enforcement Trends: Taxpayer Responses to New Enforcement Strategies."

Just as with the introduction of the internal combustion engine vehicle more than a century ago, the success of EVs will depend on the buildout of infrastructure required to power them: high-speed charging stations. President Biden’s infrastructure package calls for the federal government to provide $174 billion in incentives for the purchase of EVs, but even more importantly, for the construction of 500,000 fast chargers across the nation by 2030. This webinar will focus on:

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.