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Firm News 1 result

Firm News | 9 min read | 01.02.25

Crowell & Moring Elects 12 New Partners, Promotes Four to Senior Counsel and 25 to Counsel

Crowell & Moring elected 12 new partners effective January 1, 2025. The firm also promoted four lawyers to the senior counsel and 25 associates to counsel.

Client Alerts 5 results

Client Alert | 3 min read | 08.13.25

Faster Audits, More ADR: IRS Rolls Out Significant LB&I Changes

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.”
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Client Alert | 4 min read | 07.24.25

What’s Old is New Again: the Expansion of Sharing Tax Information and the Effect on Employment and Immigration Cases

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.
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Client Alert | 2 min read | 05.22.25

What Trump’s Nominee for IRS Commissioner Could Mean for Employee Retention Tax Credit Enforcement

On May 20, 2025, former Missouri congressman, Billy Long, appeared before the Senate Finance Committee for his confirmation hearing as President Donald Trump’s nominee for IRS Commissioner.  Senators questioned Long about his role in promoting questionable tax credits, including Employee Retention Tax Credits (“ERTC”) after leaving the House of Representatives in 2023.  Long also disclosed receiving financial compensation from these entities for his work promoting ERTC.  Given Long’s support for ERTC, there is speculation that the IRS could ease enforcement activity directed towards these credits.
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Press Coverage 1 result

Publications 1 result

Events 3 results

Event | 03.17.24 - 03.20.24

TEI's 2024 Midyear Conference

Two of Crowell’s Tax attorneys will be featured on separate panels at this year’s TEI Midyear Conference.
On Monday, March 18th from 4:30 p.m. – 5:30 p.m. Christopher Gurley will be discussing “Critical Developments in Information Reporting and Electronic Filing: Broader Reach, New Requirements, and Increased Audits.” Carina Federico will be speaking on “Key Developments in Tax Regulatory Challenges,” on Tuesday, March 19th from 11:15 a.m. – 12:15 p.m. 

Event | 02.13.24, 9:00 AM EST - 3:00 PM EST

TEI Cincinnati / Columbus Chapter - TEI's IRS Administrative Affairs Meeting

On February 13, 2024, Starling Marshall, Carina Federico and Chris Gurley will speak at the TEI Cincinnati / Columbus Chapter - TEI's IRS Administrative Affairs Meeting. This chapter meeting, Hosted by Crowell & Moring and will discuss Managing IRS Tax Audits and Appeals.

Event | 09.14.23 - 09.15.23

37th Annual Managing Tax Audits and Appeals: Hot Topics in Tax from Planning to Litigation

Crowell & Moring’s Tax Group invites you to join us for the 37th Annual Managing Tax Audits and Appeals. The seminar will provide an overview of everything you need to know about recent developments and hot topics in tax, from planning through litigation, including perspectives from the IRS.
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Speaking Engagements 6 results