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Firm News 6 results

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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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.

Client Alerts 5 results

Client Alert | 1 min read | 03.06.24

Crowell Talks Tax: IRA and Tax Controversy (VIDEO)

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. 
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Client Alert | 1 min read | 02.29.24

IRS to Kickoff Audit Campaign Focused on Business Aircraft Users

Last week, the IRS announced plans to begin a campaign to audit personal use of business aircraft. The audits will focus on whether large corporations, partnerships and high-and ultra-high net worth aircraft owners have properly reported their business and personal aircraft usage for tax purposes, with a particular focus on ensuring that owners are only taking deductions to which they are entitled. Given the value of an aircraft, the amount of a deduction for aircraft related expenditures on a given taxpayer’s return can be in the tens of millions of dollars, and with more than 10,000 corporate jets operating in the U.S., IRS Commissioner Daniel Werfel recognized that much is at stake with this campaign.  The audit campaign is expected to focus initially on multinational and domestic corporations and complex partnerships but is expected to expand from there.
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Client Alert | 3 min read | 03.06.23

Supreme Court Ruling Reduced Taxpayer’s Penalties by $2.67 Million

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.
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Press Coverage 4 results

Press Coverage | 01.09.23

Who Won Monday's SCOTUS Arguments Over Attorney-Client Privilege?

Supreme Court Brief

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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Publications 1 result

Publication | 01.31.13

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

Crowell & Moring LLP publication

Events 18 results

Event | 06.27.24, 3:20 PM EDT

2024 NYU Tax Controversy Forum

The annual NYU School of Professional Studies Tax Controversy Forum features interactive presentations delivered by expert practitioners who cover a broad range of issues regarding tax audits and tax litigation at all levels.

Event | 06.18.24 - 06.19.24, 7:45 AM CDT - 7:00 PM CDT

TEI's 2024 Credits & Incentives Seminar

This two-day seminar will be held June 18-19 in beautiful Chicago and provide the latest information on interpreting and applying available tax credits, providing everything you need to navigate the rapidly changing tax and legal issues. As the preeminent professional membership-based association for in-house tax professionals, TEI is uniquely positioned to offer a definitive and forward-looking perspective into the complex and high-stakes area of credits & incentives (C&I). Step into the future of C&I at TEI’s first comprehensive Seminar in this important tax area.

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. 

Speaking Engagements 12 results