Insights

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.

On October 29, 2024, Crowell partner Starling Marshall will speak at the 79th Annual Tax Executives Institute’s Conference in San Antonio, TX. Starling will speak on the panel entitled “Current Developments in Privilege Claims".

Hot Topics in Tax Controversy: From Audit Challenges to Courtroom Battles

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.

The annual NYU School of Professional Studies Tax Controversy Forum features interactive presentations delivered by expert practitioners who cover a broad range of issues regarding tax audits and tax litigation at all levels.

This two-day seminar will be held June 18-19 in beautiful Chicago and provide the latest information on interpreting and applying available tax credits, providing everything you need to navigate the rapidly changing tax and legal issues. As the preeminent professional membership-based association for in-house tax professionals, TEI is uniquely positioned to offer a definitive and forward-looking perspective into the complex and high-stakes area of credits & incentives (C&I). Step into the future of C&I at TEI’s first comprehensive Seminar in this important tax area.

This panel will provide a comprehensive update on U.S. international tax controversies, with an emphasis on disputes that have reached the trial court or proceeded to judicial appeal. The panel will analyze ongoing challenges to the validity of Treasury regulations (particularly regulations implementing the Tax Cuts & Jobs Act), as well as the rising tide of cases involving the codified economic substance doctrine. 

Crowell’s Carina Federico will be a moderator at ABA’s May Tax Meeting in Washington, DC from May 2-4. Carina will moderate the panel More Data, More Problems? Information Overload for Legal and Tax Practitioners on May 3 at 12:00 pm EST. This panel will explore the myriad consequences of big data, with a particular emphasis on the use of data for tax research, fact development, and news gathering.

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.

On January 19, Carina Federico will speak at ABA's Section of Taxation 2024 Midyear Tax Meeting, on the panel, "What Happens If Chevron is Overturned?". The U.S. Supreme Court will hear two cases this session, Loper Bright Enterprises v. Raimondo and Relentless v. U.S. Department of Commerce, that could dramatically change nearly 40 years of case law under Chevron v. Natural Resources Defense Counsel. With the fate of agency deference under Chevron unclear, panelists will consider how to navigate current controversies and what changes might be in store for the Service and taxpayers.