David B. Blair

Speeches & Presentations

• "Audits Part One: Selection to Resolution," Crowell & Moring's Managing Tax Audits and Appeals Seminar 2019, Washington, D.C. (September 12, 2019). Presenters: David B. Blair and Carina C. Federico.
• "45Q Update," 85TH Annual API Federal Tax Forum, Houston, TX (April 30, 2019). Presenters: David B. Blair and David J. Fischer.
• "Managing Tax Controversies," Tax Executives Institute Detroit Chapter, Dearborn, MI (February 13, 2019). Presenters: David Blair, Brad Anwyll and Teresa Abney.
• "Managing Tax Controversies," Tax Executives Institute Philadelphia Chapter, Malvern, PA (October 11, 2018). Presenters: David Blair, Teresa Abney, and Carina Federico.
• "Federal Audits Update – Current Developments in International Tax and Transfer Pricing," Tax Executives Institute Philadelphia Chapter, Malvern, PA (December 6, 2017). Presenters: David B. Blair and David J. Fischer.
• "Federal Audits Update – Developments at IRS Appeals," Tax Executives Institute Philadelphia Chapter, Malvern, PA (December 6, 2017). Presenters: David B. Blair and David J. Fischer.
• "LB&I's Issue Focused Audit Paradigm," Crowell & Moring's Managing Tax Audits and Appeals Seminar 2017, Washington, D.C. (October 5, 2017). Presenter: David B. Blair.
• "What Trump Means for Business," Crowell & Moring Webinar (May 24, 2017). Presenters: Angela B. Styles, W. Scott Douglas, Paul M. Rosen, Evan D. Wolff, Thomas A. Lorenzen, Christine M. Clements, Daniel Cannistra, and David B. Blair.
• "IRS Update," 83rd Annual API Federal Tax Forum, Houston, TX (April 24, 2017). Presenters: David B. Blair and David J. Fischer.
• "Connecting and Converging Transfer Pricing, Customs, Duty and BEPS - It's Not Getting Any Easier!" IPBA’s 27th Annual Meeting and Conference, Auckland, New Zealand (April 7, 2017). Presenter: David B. Blair.
• "Effective Management of IRS Transfer Pricing Disputes," Tax Executives Institute 67th Midyear Conference, Washington, D.C. (March 20, 2017). Presenter: David B. Blair.
• "Navigating LB&I's New Issue-Focused Audit Process," TEI Detroit Chapter's IRS Roundtable, Dearborn, MI (February 16, 2017). Speakers: David B. Blair and Jennifer A. Ray.
• "Trump and Taxes: Is Corporate Tax Reform Here?" Webinar, Crowell & Moring's First 100 Days Series (December 21, 2016). Presenters: James G. Flood, David B. Blair, David J. Fischer, and W. Scott Douglas.
• "IRS Administrative Procedures Issues," NFTC Fall Tax Committee Meeting, Washington, D.C. (October 20, 2016). Presenter: David B. Blair.
• "LB&I’s New Issue-Focused Audit Paradigm," Managing Tax Audits and Appeals Seminar 2016, Washington, D.C. (September 29, 2016). Presenter: David B. Blair.
• "The Guidance Process at IRS and Treasury," Managing Tax Audits and Appeals Seminar 2016, Washington, D.C. (September 29, 2016). Presenters: David B. Blair.
• "LB&I’s New Issue-Focused Audit Paradigm," Crowell & Moring’s Managing Tax Audits and Appeals Seminar 2016, Marina del Rey, CA (September 22, 2016). Presenter: David B. Blair.
• "Upcoming Changes to IRS Audits of Partnerships," Crowell & Moring’s Managing Tax Audits and Appeals Seminar 2016, Marina del Rey, CA (September 22, 2016). Presenter: David B. Blair.
• "The New LB&I Division and Examination Process: Structure & Function," TEI 2016 Audits & Appeals Seminar – East, Boston, MA (June 13, 2016). Presenter: David B. Blair.
• "Altera v. Commissioner – Keeping the IRS at Arm’s Length Under Section 482 and the Administrative Procedure Act," BNA Paper Presentation to the Bloomberg BNA U.S. International Tax and Transfer Pricing Advisory Board (February 18, 2016). Presenter: David B. Blair and David J. Fischer.
• "Handling Intangibles Tax Controversies," Bloomberg BNA Seminar, Washington, D.C. (December 8, 2015). Presenters: David J. Fischer and David B. Blair.
• "Transfer Pricing Controversy & Competent Authority," Bloomberg BNA Seminar, Washington, D.C. (December 4, 2015). Presenters: David J. Fischer and David B. Blair.
• "LB&I and the Road Ahead," TEI's 70th Annual Conference, Dallas, TX (October 21, 2015). Presenter: David B. Blair.
• "Fast Track and Appeals," Crowell & Moring's Managing Tax Audits and Appeals Seminar 2015, San Francisco, CA (October 9, 2015). Presenters: David B. Blair and David J. Fischer.
• "IRS Hires Outside Counsel," Crowell & Moring's Managing Tax Audits and Appeals Seminar 2015, San Francisco, CA (October 9, 2015). Presenters: David B. Blair and David J. Fischer.
• "New Audit Paradigm: 'Issue-Focused' LB&I Examination," Crowell & Moring's Managing Tax Audits and Appeals Seminar 2015, San Francisco, CA (October 8, 2015). Presenter: David B. Blair.
• "Developments in Work-Product Doctrine and Attorney-Client Privilege Issues," Crowell & Moring's Managing Tax Audits and Appeals Seminar 2015, San Francisco, CA (October 8, 2015). Presenters: Shelley d.A. Leonard and David B. Blair.
• "New Audit Paradigm: 'Issue-Focused' LB&I Examinations," Crowell & Moring's Managing Tax Audits and Appeals Seminar 2015, Washington, D.C. (October 1, 2015). Presenter: David B. Blair.
• "IRS Hires Outside Counsel," Crowell & Moring's Managing Tax Audits and Appeals Seminar 2015, Washington, D.C. (October 1, 2015). Presenter: David B. Blair.
• "BEPS, Transfer Pricing and EU State Aid Investigations," 81st Annual API Federal Tax Forum for the Oil and Natural Gas Industry in Houston, Texas (April 27-28, 2015). Panelists: David Blair and Dr. Salomé Cisnal de Ugarte.
• "Opportunities and Perils in 'Issue-Focused' LB&I Examinations," Tax Executive Institute 65th Mid-Year Conference, Washington, D.C. (March 24, 2015). Presenter: David B. Blair.
• "Transfer Pricing Overview, Controversy & Competent Authority," BNA/CITE Intermediate U.S. International Tax Seminar, Washington, D.C. (December 5, 2014). Presenters: David M. Blair and David J. Fischer.
• "Ethical Issues in Discovery Processes: Circular 230, AICPA, ABA Rules," TEI's 69th Annual Conference, Houston, TX (November 5, 2014). Panelist: David B. Blair.
• "Compliance Assurance Process - Navigating Recent and Pending Developments in CAP Audits," Managing Tax Audits and Appeals, Washington, D.C. (October 9-10, 2014) San Francisco, CA (October 23-24, 2014). Presenter: David B. Blair.
• "Developments in Transfer Pricing Audits; Advance Pricing Agreements and Competent Authority Procedures; OECD Base Erosion and Profit Shifting Proposals," Managing Tax Audits and Appeals, Washington, D.C. (October 9-10, 2014) San Francisco, CA (October 23-24, 2014). Presenters: David M. Blair and David J. Fischer.
• "Compliance Assurance Process," Tax Executives Institute 13th Annual Conference, New York, NY (September 18, 2014). Panelist: David B. Blair.
• "Navigating Into, Through and Out of CAP," TEI - 2014 IRS Audits & Appeals Seminar: Insights and Skills for Tax Controversy Success, New York, NY (May 22, 2014). Presenters: Harold J. Heltzer and David B. Blair.
• "Sustainability of Taxes: Base Erosion and Profit Shifting," Inter Pacific Bar Association 24th Annual Meeting & Conference, Vancouver, Canada (May 10, 2014). Presenter: David B. Blair.
• "IRS Update: Evolution of IRS's Strategy for Auditing Specialized Industries, and LB&I's Current Structure," API Federal Tax Forum (April 28, 2014). Presenters: David B. Blair and David J. Fischer.
• "Tax: The OECD BEPS Project," T-TIP, Tax and Technology: Emerging Issues in Transatlantic Trade, National Foreign Trade Council Forum, London (March 20, 2014). Panelist: David B. Blair.
• "Transfer Pricing Overview, Controversy & Competent Authority," BNA/CITE Intermediate U.S. International Tax Seminar (December 6, 2013). Presenters: David J. Fischer and David B. Blair.
• "Managing Transfer Pricing Risk," Association of Corporate Counsel Webinar (November 13, 2013). Presenters: David B. Blair and David J. Fischer.
• "Current Developments: Transfer Pricing," Managing Tax Audits and Appeals, Washington, D.C. (October 3-4, 2013) San Francisco, CA (October 17-18, 2013). Presenters: David B. Blair and David J. Fischer.
• "Compliance Assurance Process: Best Practices for CAP Audits," Managing Tax Audits and Appeals, Washington, D.C. (October 3-4, 2013) San Francisco, CA (October 17-18, 2013).
• "Administrative Procedure Act--Impacts on IRS Audits and IRS Actions," 79th Annual American Petroleum Institute Federal Tax Forum (April 29, 2013). Presenters: David B. Blair and David J. Fischer.
• "Tax Controversy Developments," and "Transfer Pricing," TEI Portland Chapter Tax Conference (April 25, 2013). Presenters: David B. Blair and David J. Fischer.
• "Strategies for Managing Royalty Agreements from a Transfer Pricing Perspective," C&M Global Royalties: Best Practices and Strategies Session (April 10, 2013). Presenters: David B. Blair and David J. Fischer.
• "Handling Penalty Cases: Views from the Bench and the Bar," Federal Bar Association 2013 Tax Law Conference (March 1, 2013). Presenter: David B. Blair.
• "Hot Topics in Tax Controversy," TEI New Orleans Chapter Meeting (February 19, 2013). Presenters: David B. Blair and David J. Fischer.
• "Transfer Pricing," BNA/CITE Intermediate U.S. International Tax Seminar (December 7, 2012). Presenters: David B. Blair and David J. Fischer.
• "Handling Transfer Pricing Adjustments Before and After the Return; Preparation for a Transfer Pricing Audit; Claiming Setoffs; Current Developments in Transfer Pricing," Crowell & Moring Tax Seminar (October 2012). Presenters: David Blair and David J. Fischer.

Publications

• "INSIGHT: Automation And Data Analytics To Drive LB&I Audit Selection," Bloomberg Tax (June 5, 2019). Authors: Carina C. Federico, and David B.Blair
• "Treasury Issues Policy Statement That May Be The Death Knell For 'Auer' Deference In Tax Cases And Zombie Notices," Bloomberg (March 19, 2019). Author: Carina C. Federico, David B. Blair, and Robert L. Willmore.
• "Recent Developments In The IRS Partnership Audit Regime," Law360 (January 18, 2019). Authors: David B. Blair, and Teresa Abney.
• "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.
• "Tax – New Burdens for the IRS," Crowell & Moring's Regulatory Forecast 2018 (February 2018). Contributors: David Blair and David Fischer.
• "Altera Corp. v. Commissioner: Keeping the IRS at Arm's Length Under S482 and the Administrative Procedure Act," Tax Management International Journal, 45 TMIJ 251 (May 13, 2016). Authors: David B. Blair and David J. Fischer.
• "Consequences of EU's Belgium Tax Scheme Decision," Law360 (January 21, 2016). Authors: Dr. Salomé Cisnal de Ugarte and David B. Blair.
• "Likely Impact of the EU's Fiat, Starbucks Tax Rulings," Law360 (October 21, 2015). Authors: David B. Blair, Salomé Cisnal de Ugarte, and David J. Fischer.
• "Your Energy Tax Credit May Not Be Safe," Law360 (January 20, 2015). Co-Authors: Jennifer A. Ray and David B. Blair.
• "Litigation Forecast 2015: What Corporate Counsel Need to Know for the Coming Year," a Crowell & Moring LLP publication (January 2015). Contributor.
• "EU Tax Rulings For Companies Threatened By State Aid Law," Law360 (November 24, 2014). Co-Authors: David B. Blair, David J. Fischer, and Dr. Salomé Cisnal de Ugarte.
• "Transfer Pricing Answer Book 2014," Practising Law Institute (2014). Editor: David B. Blair.
• "Transfer Pricing Answer Book 2013," Practising Law Institute (2013). Editor: David B. Blair.

Client Alerts & Newsletters

• "IRS Expected to Issue Section 965 Audit Notifications Soon," Tax Alert (January 8, 2020). Contacts: David B. Blair, Teresa Abney, J. Bradford Anwyll
• "Chief Counsel Desmond Discusses IRS Areas of Focus at Crowell & Moring Tax Seminar," Tax Alert (September 26, 2019). Contacts: David B. Blair, Carina C. Federico, J. Bradford Anwyll
• "Deputy Commissioner (LB&I) Flax and Deputy Division Counsel (International) Askey Discuss Recent Developments at LB&I at Crowell & Moring Tax Seminar," Tax Alert (September 26, 2019). Contacts: David B. Blair, Carina C. Federico, J. Bradford Anwyll
• "IRS Issues BBA Guidance to Appeals," Tax Alert (March 29, 2019). Contacts: Charles C. Hwang, David B. Blair, Teresa Abney
• "What You Need to Know About Congress’s Role in Refund Claims," Tax Alert (January 22, 2019). Contacts: David B. Blair, Teresa Abney
• "Recent Developments in Partnership Audits," Tax Alert (January 3, 2019). Contacts: David B. Blair, Teresa Abney
• "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
• " IRS Expands Audit Campaigns to Include Economic Development Incentives," Tax Alert (November 8, 2017). Contacts: Robert L. Willmore, David B. Blair, Dwight N. Mersereau, Teresa Abney
• "Tax Court Applies the Economic Substance Doctrine in Austin v. Commissioner," Tax Alert (May 24, 2017). Contacts: David B. Blair, Charles C. Hwang
• "IRS Releases Final Regulations on MLPs," Tax Alert (February 8, 2017). Contact: David B. Blair
• "Initial IRS Audit Campaigns Include Several International Tax Issues," Tax Alert (February 3, 2017). Contacts: David B. Blair, David J. Fischer
• "Your Government at Work: IRS and SEC Take Contrary Positions on Disgorgement," Tax Alert (June 3, 2016). Contacts: David B. Blair, Thomas A. Hanusik, Daniel L. Zelenko, Jared Engelking
• "Only in Belgium? – The EU Commission Declares Belgian Excess Profits Tax Rulings for Multinationals to be Illegal," Tax Alert (January 19, 2016). Contact: David B. Blair
• "IRS Requests Comments on Potential Investment Tax Credit Regulations," Tax Alert (November 13, 2015). Contact: David B. Blair
• "New Legislation Will Allow IRS to Impose Tax at Partnership Level," Tax Alert (November 2, 2015). Contacts: Charles C. Hwang, David B. Blair
• "European Commission Declares Tax Rulings Granted by Luxembourg and The Netherlands to Fiat and Starbucks Are Illegal State Aid," Tax Alert (October 21, 2015). Contacts: David B. Blair, David J. Fischer
• "Tax Court Strikes Down Treasury Regulation Requiring Cost Sharing of Stock-Based Compensation," Tax Alert (July 29, 2015). Contacts: David J. Fischer, David B. Blair
• "IRS Guidance Helps Small Wind Projects Claiming the Investment Tax Credit," Tax Alert (July 16, 2015). Contact: David B. Blair
• "IRS Clarifies Qualifying Income for MLPs," Tax Alert (May 6, 2015). Contact: David B. Blair
• "Update on the Status of Master Limited Partnership Guidance," Tax Alert (March 17, 2015). Contact: David B. Blair
• "Your Energy Tax Credit May Not Be Safe," Tax Alert (January 23, 2015). Contact: David B. Blair
• "Corporate Taxation and EU Competition Law – Are Tax Rulings for Individual Companies Threatened by EU State Aid Law?," Antitrust Law Alert (November 17, 2014). Contacts: David B. Blair, David J. Fischer
• "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
• "IRS Tightening of Inversion Rules Demands Monitoring," Government Contracts Bullet Points (September 29, 2014). Contacts: David B. Blair, Charles C. Hwang, David J. Fischer
• "Managing Tax Audits – C&M Annual Conference," Government Contracts Bullet Points (August 25, 2014). Contacts: David B. Blair, David J. Fischer, Harold J. Heltzer
• "IRS Clarifies Position on Recovery Period for Assets Used in Fuel-Grade Ethanol Production," Regulatory Alert (May 27, 2014). Contacts: David J. Fischer, David B. Blair
• "Wasted Energy: Treasury Reexamines Eligibility Requirements for Renewable Energy Credits (Again) as Uncertainty Remains," Regulatory Alert (May 6, 2014). Contacts: David B. Blair, David J. Fischer
• "Supreme Court Holds Valuation Misstatement Penalty Applicable; Rejects Blue Book Analysis," Regulatory Alert (December 9, 2013). Contact: David B. Blair
• "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
• "Managing Tax Audits -- C&M Annual Conference," Government Contracts Bullet Points (September 5, 2013). Contacts: David B. Blair, David J. Fischer, Harold J. Heltzer
• "IRS Extends Segregation Principle of Farm Services Co-op to Section 199 Deductions," Tax Alert (July 26, 2013). Contact: David B. Blair
• "Chief Counsel Memo Reveals IRS Seeks to Build on its Recent Victories in Partnership Cases," Tax Alert (March 4, 2013). Contacts: David B. Blair, David J. Fischer
• "Third Circuit Reverses Tax Court, Clarifies Scope of Economic Substance Doctrine in Historic Boardwalk Hall, LLC v. Commissioner," Tax Alert (September 11, 2012). Contacts: David B. Blair, David J. Fischer
• "IRS Intends to Issue New Tax Regulations on Outbound Transfers of Intangible Property," Tax Alert (August 2, 2012). Contacts: David J. Fischer, David B. Blair

In the News

• Treasury's Guidance Job Made Harder By Tax Official's Exit
  March 2, 2018 — Law360
• Washingtonian Top Lawyers: Tax Lawyers
  December 30, 2015 — Washingtonian
• Federal Tax Cases to Watch In 2015
  January 2, 2015 — Law360
• Crowell & Moring Tax Partner Offers Insight on Whistleblowers to Tax Notes
  September 10-14, 2012 — Tax Notes

Firm News & Announcements