Firm overview
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.
Corporate Transactions & Finance: We advise U.S. and non-U.S. corporations, joint ventures, and partnerships on tax aspects of business transactions.
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).
