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Firm News 7 results

Firm News | 11 min read | 06.05.25

Crowell Attains Leading Rankings in Chambers USA 2025

Washington – June 5, 2025: Crowell & Moring earned 80 rankings for 71 lawyers, as well as 43 national and statewide practice area rankings, in the Chambers USA 2025 guide. The rankings are driven by independent interviews of clients and lawyers at peer firms.

Firm News | 8 min read | 08.15.24

The Best Lawyers in America 2025 Recognizes 42 Crowell & Moring Attorneys, Three Selected as Lawyer of the Year

Washington – August 15, 2024: The 2025 edition of The Best Lawyers in America® has recognized 42 Crowell & Moring lawyers as "Best Lawyers" and 29 lawyers as “Ones to Watch.”
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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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Client Alerts 17 results

Client Alert | 6 min read | 11.14.25

Relevancy Reigns, But IRS Prevails: Tax Court Holds in Patel Case that Threshold Relevancy Determination Required Prior to Application of Codified Economic Substance Doctrine

On November 12, 2025, the Tax Court issued a reviewed opinion in Patel v. Commissioner holding in favor of the IRS that the taxpayers’ transaction lacked economic substance, and therefore the taxpayers were liable for penalties under the codified economic substance doctrine at the increased penalty rate, as well as accuracy-related penalties. The Court previously held in a separate opinion that the taxpayers’ purported captive transactions did not constitute insurance because they failed to distribute risk, and in the alternative, that the micro-captives did not act as an insurer commonly would. 
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Client Alert | 6 min read | 10.24.25

Will Jarkesy Stop the IRS from Asserting Penalties Against Taxpayers?

In 2024, the U.S. Supreme Court determined that the civil penalties issued by the SEC against individuals for committing securities fraud were unconstitutional because they were levied without a jury trial.[1]
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Client Alert | 3 min read | 10.10.25

New Post Appeals Mediation Pilot Program

On October 1, 2025, the IRS Independent Office of Appeals launched a two-year pilot program to make Post Appeals Mediation (PAM) more attractive and accessible to taxpayers. See IRS Announcement 2025-10. The new PAM pilot program offers taxpayers the opportunity to be assigned to a new Appeals team, which is otherwise unconnected to the underlying case, who will represent the original Appeals team in the mediation session. The assignment of the new Appeals team does not begin a new appeals process but rather is intended to help facilitate an expedited and impartial look at the underlying case with the goal of further exploring all potential paths to resolution prior to litigation.
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Press Coverage 8 results

Publications 2 results

Publication | 01.31.13

Litigation Forecast 2013: What Corporate Counsel Need to Know for the Coming Year

Crowell & Moring LLP publication

Events 23 results

Event | 10.29.25 - 10.30.25

39th Annual Managing Tax Audits and Appeals Seminar: Resolving Issues with the IRS in the New Enforcement Landscape

In this program, government representatives and experienced tax attorneys will provide timely insights on recent updates. Attendees will gain practical guidance to help taxpayers efficiently and effectively resolve audits and appeals in today’s changed environment.

Event | 11.07.24 - 11.08.24, 8:00 AM EST - 6:30 PM EST

Novogradac 2024 Fall Renewable Energy Tax Credit Conference

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.

Event | 10.27.24 - 10.30.24, 7:00 AM CDT - 11:00 PM CDT

TEI 79th Annual Conference

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".

Speaking Engagements 28 results