Crowell & Moring provides federal and state tax advice and representation in business transactions, controversies and litigation to U.S. and non-U.S. corporations and joint ventures.
Our practice encompasses all U.S. tax aspects of business dealings and all administrative and litigation forums. Our lawyers have deep knowledge of tax law, IRS and state administrative proceedings, and tax litigation. Our clients benefit from their prior experience in positions with the Department of Justice Tax Division, the Treasury Department Office of Tax Legislative Counsel, the IRS Office of Chief Counsel, the Office of Management and Budget, and the United States Tax Court. We are well-known for tax controversy and litigation, tax planning for corporate and financing transactions, international tax, partnership tax, accounting methods, and employee benefits and executive compensation.
Tax Audits, Appeals & Litigation: We have a long history of achieving outstanding results in tax controversy and litigation. We have litigated numerous tax cases before the U.S. Tax Court, U.S. Court of Federal Claims, U.S. district courts, U.S. bankruptcy courts, U.S. courts of appeals, and various state courts. We recognize that litigation is a last resort and make innovative use of alternative dispute resolution techniques. Some of our greatest successes never appear in reported decisions because we resolve tax controversies through advance pricing agreements (APAs), audits, fast track settlements, IRS Appeals, mediation, competent authority, and other litigation alternatives.
International Tax: We have extensive experience litigating international tax issues, including transfer pricing and foreign tax credits. Our lawyers handle IRS audits and appeals of international tax issues and advise multinational corporations and joint ventures regarding the U.S. tax aspects of their most important inbound and outbound transactions.
Partnership Tax: We advise corporations in connection with joint ventures and the use of partnerships, limited liability companies (LLCs), and disregarded entities in tax planning. We draft LLC and partnership agreements, analyze partnership allocations, and structure “profits interest” or “carried interest” arrangements. Tax Reform Implementation: We advise on projects related to tax legislation, including GILTI, FDII, BEAT, deemed repatriation, and other provisions of the Tax Cuts and Jobs Act.
ERISA, Employee Benefits & Executive Compensation: We assist clients in complying with tax and other federal and state laws governing executive compensation, retirement and other health care and employee benefit matters. Crowell & Moring authors a book and presents an annual conference on Managing Tax Audits and Appeals. David Blair, Practice Group Leader, is the editor of the Transfer Pricing Answer Book published by the Practising Law Institute (PLI) (2012-present).
For four decades, [Bennett Thrasher LLP] (www.btcpa.net/) has provided clients with strategic business guidance and solutions. Our unwavering dedication to our core values, client service and collaboration has catapulted us into the ranks of the largest and fastest-growing certified public accounting and consulting firms. With a global reach and strong local ties, we provide businesses and high net worth individuals with professional tax, audit, advisory and business process outsourcing services. Our family-oriented “Better Together” approach is grounded in diverse thinking and enables our clients to become more efficient and profitable. Our commitment to diversity and to our community is an essential part of who we are, and it reflects the values on which our firm was founded.
The goal of the firm’s [Transfer Pricing practice] (www.btcpa.net/services/tax/transfer-pricing/) is to help businesses be aware of the transfer pricing issues they face and be pragmatic when deciding how to address these unique risks. Our service offerings include strategic transfer pricing, transfer pricing compliance and controversy managements/APAs.
Fenwick & West LLP has represented 6 of the top 10 Fortune 500 largest companies, over 50 of the Fortune top 100 companies and over 100 of the top 500 Fortune companies in US federal and international tax planning matters, including tax dispute resolution. This work has involved general international tax planning, transfer pricing, acquisitions, joint ventures, administrative tax dispute resolution and tax litigation.
International Tax Review named us in 2019 as first-tier in tax in the San Francisco Bay Area. It also named us in 2019 as the first tier in the US in transfer pricing, tax planning and tax transactional. Eight of our partners appear in ITR's Tax Controversy Leaders (2019).
We are pleased to have been named nine times as ITR's San Francisco Bay Area Tax Firm of the Year and four times as ITR's US (or Americas) Tax Court or Tax Ligation Firm of the Year. We are equally proud to have won a number of ITR's Tax Deal of the Year awards, including America's M&A Tax Firm of the Year.
Ten of our partners have appeared in Euromoney Legal Media Group's World's Leading Tax Advisors (plus two more who have appeared in the rising stars category) and five have appeared in its World's Leading Transfer Pricing Advisors.
Our practice this past year has involved substantial planning and restructuring under the US's new tax laws for our multinational corporate clients as well as work regarding the BEPS changes such as CbC reporting, the EC’s ATAD2 and DAC6 rules and the revised OECD transfer pricing guidelines.