Insights

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.”

Washington, D.C. – January 13, 2015: Crowell & Moring LLP is pleased to announce the publication of its third annual "Litigation Forecast: What Corporate Counsel Need to Know in the Coming Year," and the introduction of its first-ever "Regulatory Forecast 2015: What Corporate Counsel Need to Know in the Coming Year."

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. 

In 2021, two Circuit Court of Appeals, held diametric positions regarding penalties for taxpayers who non-willfully failed to file a Report of Bank and Financial Accounts (FBAR): The Ninth Circuit concluded that the penalty was $10,000 per untimely filed FBAR, while the Fifth Circuit concluded that the penalty was $10,000 per account on each untimely filed FBAR. On February 28, 2023, the Supreme Court resolved this conflict, ruling that the penalty is calculated on a per-form basis, rather than a per-account basis.

On February 15th, Daniel Werfel, the nominee for IRS Commissioner, testified before the Senate Finance Committee during his nomination hearing. As expected, Werfel faced tough questioning about how he would oversee the use of $80 billion in new funding coming to the IRS over the next decade. The Inflation Reduction Act, which passed late last year, appropriated the additional funding for the IRS to increase compliance and provide better customer service to taxpayers. 

Washington, D.C.-based partner and member of the firm's Tax Group, David J. Fischer, talks with Law360 about the expert tips and best practices taxpayers should keep in mind when negotiating an advance pricing agreement (APA)."You have to think about the likelihood of succeeding with an APA and whether you're willing to take a somewhat less aggressive position. Most APAs involve transactions with affiliates in jurisdictions with tax rates similar to the U.S. rate, so the IRS's tendency to push of the results toward the middle has less impact on the overall effective tax rate," said Fischer.

Crowell & Moring’s Tax Group invites you to join us for the 36th Annual Managing Tax Audits and Appeals Seminar. The seminar will provide an update on recent developments in tax audits and appeals, as well as the opportunity to hear from leading government officials about their compliance programs. 

S. Starling Marshall will present at TEI's 2022 Audits and Appeals Seminar as part of the panel discussion "Best Practices for Responding to IDRs, Including Privilege and Controlling Information Flow in an Audit Setting."