Insights

Washington – June 6, 2024: Crowell & Moring earned 78 rankings for 67 lawyers, as well as 41 national and statewide practice area rankings, in the Chambers USA 2024 guide. The rankings are driven by independent interviews of clients and lawyers at peer firms.

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.

On August 19, 2025, the U.S. Senate Committee on Finance (“Senate Finance Committee”) sent Paul Atkins, Chairman, U.S. Securities and Exchange Commission (“SEC”) a letter calling on the SEC to investigate White River Energy Corp (“White River”). In the letter, the Senate Finance Committee confirmed a criminal investigation into White River related to the sale of so-called “tribal tax credits” that according to both Congress and the IRS, do not exist. The letter further states that White River allegedly earned millions of dollars selling these credits and has not been forthcoming with investors regarding the existence of the criminal investigation. According to the Senate Finance Committee, White River has failed to file financial disclosure documents with the SEC since March 15, 2024, missing six consecutive reporting periods. The letter instructs White River to disclose the existence of the DOJ criminal tax investigation, and calls on the SEC to take action if White River fails to do so.

On July 23, 2025, the Internal Revenue Service (“IRS”) issued interim guidance for Large Business & International Division (“LB&I”) audit procedure. The IRS announced three major changes: (1) the Acknowledgement of Facts Information Document Request (“AOF IDR”) will be eliminated; (2) Accelerated Issue Resolution (“AIR”) applies to Large Corporate Compliance (“LCC”) cases; and (3) the IRS must conduct additional review before denying a taxpayer’s request to participate in the Fast Track Settlement (“FTS”). These changes reflect the IRS’s continued push to make its examinations “more efficient and current.”

In April 2025, the IRS and the Department of Homeland Security (DHS) formalized a Memorandum of Understanding (MOU) enabling Immigration and Customs Enforcement (ICE) to create a system of information sharing between the agencies. Under the MOU, the IRS can share tax return information for non-tax criminal investigation purposes. More specifically, the MOU permits ICE to request sensitive tax information from the IRS for purposes of pursuing immigration related cases and deportations. Given the Trump administration’s focus on undocumented workers, the implications of the MOU likely will go even further as sharing this information will result in tax enforcement against employers of deported individuals.

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.