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Firm News 5 results

Firm News | 9 min read | 06.06.24

Crowell Attains Leading Rankings in Chambers USA 2024

Washington – June 6, 2024: Crowell & Moring earned 78 rankings for 67 lawyers, as well as 41 national and statewide practice area rankings, in the Chambers USA 2024 guide. The rankings are driven by independent interviews of clients and lawyers at peer firms.
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Firm News | 10 min read | 01.09.23

Crowell & Moring Elects 16 New Partners, Promotes Five to Senior Counsel, and 25 to Counsel

Crowell & Moring elected 16 lawyers to the firm’s partnership, effective January 1, 2023. The firm also promoted five lawyers to the position of senior counsel and 25 associates to the position of counsel.

Firm News | 2 min read | 01.13.15

Crowell & Moring Releases Third Annual Litigation Forecast Report and Inaugural Regulatory Forecast

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."
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Client Alerts 2 results

Client Alert | 4 min read | 02.06.24

Tax Treaty with Chile Enters into Force

On December 19, 2023, the bilateral income tax treaty between the United States and Chile (formally, the Convention between the Government of the United States of America and the Government of the Republic of Chile for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with Respect to Taxes on Income and Capital, and hereafter referred to as, the “Treaty”) entered into force more than a decade after it was signed.
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Client Alert | 10 min read | 05.10.21

Advance Pricing Arrangement in China: An Effective Tax Planning Tool for Multinational Companies

The China State Taxation Administration (“STA”) recently published its eleventh “China Advance Pricing Arrangement Annual Report (2019)” that summarized the circumstances under which the STA signed advance pricing arrangements (“APA”) and introduced the latest APA regulations and requirements for the implementation of the APA program in China. The report included data for the period from January 1, 2005 until December 31, 2019. In the United States, the Internal Revenue Service’s (“IRS”) Advance Pricing and Mutual Agreement program (“APMA”) issued its annual report on activities of the U.S. APA program during 2020. The two reports underline the importance of APAs as tax planning tools for multinational companies operating in China and the United States. The two tax authorities have been meeting regularly for years to discuss APA and competent authority cases, have developed a productive working relationship, and are handling an increasing number of cases.
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Press Coverage 2 results

Press Coverage | 03.27.15

4 Tips for Negotiating IRS Advance Pricing Agreements

Law360
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.
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Press Coverage | 12.19.14

2014 Federal Tax Litigation In Review

Law360
Washington, D.C.-based partner and member of the firm's Tax Group, David J. Fischer, talks with Law360 about the major high-stakes tax cases that closed in 2014. Fischer provided his viewpoints on three of the cases, including U.S. v. Clarke, which the court said taxpayers have a right to examine their IRS agents if they can point to specific facts or circumstances — including circumstantial evidence — that raise an inference of bad faith. "Tax law is like a pendulum, and right now our pendulum is swinging toward procedural fights because the IRS has changed its summons process and the Supreme Court has changed the litigation standards for looking behind an IRS summons," stated Fischer.
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Events 11 results

Event | 06.12.24 - 06.14.24, 11:00 AM EDT - 8:30 PM EDT

16th Annual U.S. And Latin America Tax Practice Trends

The panel will explore the issues and challenges related to Latin America investors investing into the United States (excluding real estate) with a focus on the structures used to make those investments and take advantage therefrom to expand within the United States or to use the United States as a platform for distribution and sales globally.

Event | 05.23.24, 12:00 PM EDT - 1:00 PM EDT

International Tax Series: International Tax Controversy Update

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. 

Event | 04.10.24 - 04.12.24

ABA’s 24th Annual U.S. and Europe Tax Practice Trends

Crowell & Moring partners, Starling Marshall and Carina Federico will be attending ABA’s 24th Annual U.S. and Europe Tax Practice Trends. Carina Federico will be serving as a reporter for the event. Starling Marshall will be co-chair on the panel, "Privilege, Penalties and Good Faith Across Jurisdictions,”  covering trends in the use of documents and information in European and US tax enforcement.

Webinars 1 result

Webinar | 10.27.21, 6:00 AM EDT - 7:00 AM EDT

China Advance Pricing Arrangement: An Effective Tool for Cross Border Tax Planning

China’s advance pricing arrangement (“APA”) has been a valid tax planning tool for multinational companies. In fact, the China’s State Taxation Administration has developed a productive working relationship with the IRS’s Advance Pricing and Mutual Agreement (“APMA”) program.
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Speaking Engagements 1 result