Charles C. Hwang is a partner in the firm's Tax Group. Resident in the D.C. office, Mr. Hwang joined the firm in 1994.
Mr. Hwang is an experienced transactional tax lawyer. He has reviewed and assisted in the negotiation and drafting of numerous merger agreements, stock purchase agreements, asset purchase agreements, partnership, joint venture and limited liability company agreements, contribution agreements, and executive compensation agreements, and has provided tax advice in connection with many other transactions, including rollover transactions, loans, and start-ups. Representative transactions including acquisitions of publicly held corporations, restructuring and sale of distressed businesses, formation of consortia to trade financial derivatives, restructuring of international operations, and taxable and tax-free mergers and reorganizations.
He also counsels tax-exempt organizations on UBIT and exemption issues, including royalty, investment, and structural issues. He is general counsel of a local bar association and has a similar role with Crowell & Moring’s affiliated foundation.
Mr. Hwang received his undergraduate degree with honors from Harvard University in 1984, where he majored in mathematics. He obtained a law degree in 1988 from Columbia University, where he was an articles editor for the Columbia Law Review and a Harlan Fiske Stone Scholar. Mr. Hwang also received an LL.M. in taxation, with honors, from Georgetown in 1998. He is a member of the Taxation Sections of the American Bar Association and the D.C. Bar. He is admitted to the bar in the District of Columbia and New York.
Affiliations
Admitted to practice: District of Columbia, New York
Highlights, News & Knowledge
Speeches & Presentations
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"Tax Reform: Business Provision of the Tax Cuts and Jobs Act," ABA Business Law Section Spring Meeting, Orlando, FL
(April 13, 2018).
Presenter: Charles C. Hwang.
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"BEPS, TAX AND CUSTOMS DUTY – Efficient Supply Chain Management: Seamless Cooperation in ASEAN and Beyond," 28th IPBA Annual Meeting and Conference, Manila, Philippines
(March 15, 2018).
Presenter: Charles C. Hwang.
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"Corporate Developments - Section 6901," Crowell & Moring's Managing Tax Audits and Appeals Seminar 2017, Washington, D.C.
(October 6, 2017).
Presenter: Charles C. Hwang.
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"Tax Issues Related to New Technologies (Including Crypto-Currencies)," 25th Annual IAKL Conference, Seoul, Korea
(September 2017).
Presenter: Charles C. Hwang.
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"When is a Favorable Tax Ruling Impermissible State Aid Under EU Law," Crowell & Moring’s Managing Tax Audits and Appeals Seminar 2016, Washington, D.C.
(September 30, 2016).
Presenter: Charles C. Hwang.
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"Zero Returns and the Statute of Limitations: Law Office of John H. Eggertsen (6th Cir. 2015)," Crowell & Moring's Managing Tax Audits and Appeals Seminar 2015, Washington, D.C.
(October 1, 2015).
Presenter: Charles C. Hwang.
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"The Inversions Notice: An Administrative Law Analysis, Including Authority and Retroactivity Issues," Managing Tax Audits and Appeals, Washington, D.C.
(October 9-10, 2014).
Presenter: Charles C. Hwang.
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"Sham Partnerships," Managing Tax Audits and Appeals, Washington, D.C. (October 3-4, 2013) San Francisco, CA
(October 17-18, 2013).
Presenter: Charles C. Hwang.
Publications
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"Tax – Got Tax Questions? Be a Squeaky Wheel," Crowell & Moring's Regulatory Forecast 2019
(February 27, 2019).
Contributors: Dwight N. Mersereau and Charles C. Hwang.
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"Altera Reversal Is A Transfer Pricing And APA Win For IRS," Law360
(July 30, 2018).
Authors: David J. Fischer, David B. Blair, Charles C. Hwang, and Madeline Obler.
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"American Recovery and Reinvestment Act of 2009," published by CCH
(2009).
Contributing Authors: Alex E. Sadler, Charles C. Hwang and Jennifer A. Ray.
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"Emergency Economic Stabilization Act of 2008: Law, Explanation and Analysis," published by CCH
(2008).
Contributing Authors: Alex E. Sadler, Charles C. Hwang and Jennifer A. Ray.
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"Country Q&A: United States Information Technology," Practical Law Company, Information Technology Handbook, 2nd Edition
(2007-08).
Co-Authors: Gaela Bailey, Benjamin T. Butler, Christopher Calsyn, Robin B. Campbell, Charles C. Hwang, Kris D. Meade and John I. Stewart, Jr.
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"Country Q&A: United States Data Protection," Practical Law Company, Vol. 2: Data Protection
(2006-07).
Co-Authors: Gaela Bailey, David Z. Bodenheimer, Benjamin T. Butler, Christopher Calsyn, Robin B. Campbell, Charles C. Hwang, Kris D. Meade, Jeremy Rhyne and John Stewart.
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Barter Exchange Reporting Relief,
(January 14, 2000).
Author: Charles C. Hwang.
Client Alerts & Newsletters
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"IRS Releases First Cryptocurrency Tax Guidance Since 2014,"
Tax Alert
(October 10, 2019).
Contacts: Charles C. Hwang, Carina C. Federico, S. Starling Marshall, Michelle Ann Gitlitz
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"District Court Invalidates the "Primary Purpose" and "Merely Incidental" Requirements of Treasury Regulation Defining "Educational Organization","
Tax Alert
(October 7, 2019).
Contacts: Charles C. Hwang, Eleanor Moran McWaters
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"IRS Issues BBA Guidance to Appeals,"
Tax Alert
(March 29, 2019).
Contacts: Charles C. Hwang, David B. Blair, Teresa Abney
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"IRS No Longer Requires Partnership Representative to Provide TIN,"
Tax Alert
(March 15, 2019).
Contacts: Charles C. Hwang, Teresa Abney
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"Who Says There’s No Free Parking in New York?,"
Health Care Alert
(December 12, 2018).
Contacts: Charles C. Hwang, Paul Mourning, Deirdre Long Absolonne
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"IRS Scores a Resounding Transfer Pricing and APA Win: Ninth Circuit Reverses Tax Court Holding in Altera,"
Tax Alert
(July 25, 2018).
Contacts: David J. Fischer, David B. Blair, Charles C. Hwang
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"Penalty Litigation Updates: IRS Guidance to its Attorneys and Tax Court’s Decision re Frivolous Penalties ,"
Tax Alert
(July 6, 2018).
Contacts: Charles C. Hwang, Teresa Abney
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"Supreme Court Turns the Page on Quill,"
Tax Alert
(June 22, 2018).
Contact: Charles C. Hwang
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"Cryptocurrency in Small Bytes: Should You Set Up a Foreign Entity for Your ICO?,"
Blockchain Alert
(April 4, 2018).
Contact: Charles C. Hwang
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"Cryptocurrency in Small Bytes: How Does the IRS Treat the Tokens You Issue in Your ICO?,"
Blockchain Alert
(March 2, 2018).
Contact: Charles C. Hwang
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"Tax Court Rules That It Has Jurisdiction to Review Whether Penalties Have Been Authorized,"
Tax Alert
(February 15, 2018).
Contacts: Charles C. Hwang, Teresa Abney
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"Tax Reform in Small Bites: Beating the BEAT (Base Erosion and Anti-Abuse Tax),"
Corporate Alert
(January 30, 2018).
Contacts: David J. Fischer, Charles C. Hwang
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"Tax Reform May Impose Tax Filing Burdens on Funds,"
Tax Alert
(January 5, 2018).
Contact: Charles C. Hwang
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"House Tax Bill Proposes to Make Five-Year Amortization of Research and Experimental Expenditures Mandatory,"
Tax Alert
(November 13, 2017).
Contacts: Charles C. Hwang, Dwight N. Mersereau
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"FinCEN Uses Updated Authority in New Sanctions Legislation to Expand Geographic Targeting Orders on Luxury Real Estate Purchases,"
International Trade Bulletin
(September 6, 2017).
Contacts: Carlton Greene, Charles C. Hwang
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"California Supreme Court Increases the Cost of M&A Deals in Expansive Real Estate Transfer Tax Decision,"
Tax Alert
(July 26, 2017).
Contacts: Charles C. Hwang, Scott J. Moore
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"Tax Court Applies the Economic Substance Doctrine in Austin v. Commissioner,"
Tax Alert
(May 24, 2017).
Contacts: David B. Blair, Charles C. Hwang
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"This Month in International Trade — January 2017,"
International Trade Bulletin
(February 9, 2017).
Contacts: John B. Brew, Frances P. Hadfield, Edward Goetz, Andrew Blasi, W. Scott Douglas, Patricia L. Wu, Jeffrey L. Snyder, Charles C. Hwang, Daniel Cannistra, Eduardo Mathison, Carlton Greene, David (Dj) Wolff, Gordon McAllister, Robert A. Burton, Lorraine M. Campos, Peter Eyre, Alan W. H. Gourley, James G. Flood, Maria Alejandra (Jana) del-Cerro, Monique D. Almy
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"This Month in International Trade — December 2016,"
International Trade Bulletin
(January 11, 2017).
Contacts: John B. Brew, Frances P. Hadfield, Edward Goetz, Daniel Cannistra, Carlton Greene, Patricia L. Wu, Jeffrey L. Snyder, Charles C. Hwang, David (Dj) Wolff, Gordon McAllister, Alan W. H. Gourley, Wing Cheung, James G. Flood, Daniel W. Wolff, Thomas A. Lorenzen
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"New Legislation Will Allow IRS to Impose Tax at Partnership Level,"
Tax Alert
(November 2, 2015).
Contacts: Charles C. Hwang, David B. Blair
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"Under Federal Circuit Decision, Asset Purchaser May Recognize Gain,"
Tax Alert
(March 18, 2015).
Contact: Charles C. Hwang
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"Proposed Regulations Create Rules for Closing Date Deductions,"
Tax Alert
(March 11, 2015).
Contact: Charles C. Hwang
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"IRS Notice 2014-52 Tightens Inversion Rules and Attacks Post-Inversion Tax Reduction Strategies; Government Contract Rules Remain Unchanged,"
Tax Alert
(September 29, 2014).
Contacts: David J. Fischer, David B. Blair, Charles C. Hwang
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"IRS Tightening of Inversion Rules Demands Monitoring,"
Government Contracts Bullet Points
(September 29, 2014).
Contacts: David B. Blair, Charles C. Hwang, David J. Fischer
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"Court of Federal Claims Rules Nuclear Decommissioning Obligations Assumed On Purchase Not Included In Basis,"
Tax Alert
(October 29, 2013).
Contacts: David J. Fischer, David B. Blair, Charles C. Hwang
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"New Regulations Can Treat Convertible Debt or Penny Warrants as Partnership Equity,"
Regulatory Alert
(October 22, 2013).
Contact: Charles C. Hwang
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"Relief for Payment Card Reporting Set to Expire Soon,"
Tax Alert
(October 18, 2012).
Contact: Charles C. Hwang
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"Congress Has A "Heart"?,"
Government Contracts Bullet Points
(June 20, 2008).
Contact: Charles C. Hwang
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"Fifth Circuit Faults IRS Attempt To Impose Intermediate Sanctions On Owners Of Home Health Care Agencies ,"
Health Care Alert
(July 24, 2006).
Contact: Charles C. Hwang
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"IRS Expands Period for Provider Incentive Payment Deductibility,"
Health Care Alert
(July 26, 2004).
Contacts: Charles C. Hwang, Barbara H. Ryland
Firm News & Announcements