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Crowell & Moring offers its clients one of the nation's leading tax accounting practices. In today's environment, the need for tax advice from experienced professionals is more critical than ever. Crowell & Moring's Tax Accounting Practice is recognized by our clients—and by the IRS and Department of the Treasury—for our depth of knowledge, experience, integrity, professionalism, and, most importantly, for our results. Our attorneys have assisted many of the largest and most well-respected companies in the world with the planning and resolution of the most complex tax accounting issues.

Crowell & Moring's tax accounting attorneys, have held senior positions within the IRS, the Department of Justice, and the Department of the Treasury; have advised policy makers on tax accounting issues; and are well-versed in the ruling policies and inner workings of the IRS, which has enabled them to obtain favorable rulings and technical advice memoranda from the IRS national office.

In addition, the Crowell & Moring tax accounting team has resolved tax accounting issues for our clients using a variety of alternative dispute resolution techniques, including Industry Issue Resolution, Fast-Track appeals, post-appeals mediation, and alternative-timing and time-value of money resolutions. Our attorneys have represented clients on significant tax accounting issues during all phases of resolution, including IRS audit, administrative appeals, and, when necessary and advisable, through litigation.

Representative Engagements

  • Represented several large, multinational companies before IRS Appeals with respect to deductions under section 199, the "production deduction."
  • Obtained a private letter ruling for a heavy manufacturer with respect to a LIFO pooling issue.
  • Represented a high-technology company before IRS Appeals with respect to an exclusion under section 118 for a non-shareholder contribution to capital.
  • Advised a leading retailer changing its method of accounting for its inventory.
  • Represented several leading hospitality companies before IRS Appeals with regard to issues arising under their loyalty reward programs.
  • Provided an opinion to a large, multinational manufacturer with respect to its deduction under section 199.
  • Represented a leading manufacturer with respect to its research and development credit.

View More

"NOL Carryback Waiver Guidance for Consolidated Groups," Tax Alert (August 4, 2020). Contacts: David B. Blair, Charles C. Hwang, S. Starling Marshall, Eric Homsi
Client Alert/Newsletter
4 Tax Questions To Ask Before Signing An Enviro Settlement (July 27, 2020). Authors: Monty Cooper, and Teresa Abney.
Publications
A Primer On The Tax Credit For Carbon Oxide Sequestration (July 27, 2020). Authors: David B. Blair, David J. Fischer, Teresa Abney, and Carina C. Federico.
Publications
The Glass Ceiling In IP Is Beginning To Fracture, Claims Hall Of Fame Inductee Stanek Rea Intellectual Asset Management (July 17, 2020)
Media Mentions
"Cross-Border Digital Asset Payments: What You Need to Know About Regulations in the U.S. and Canada," Crowell & Moring Webinar (July 16, 2020). Presenters: Michelle Ann Gitlitz, Ambassador Robert Holleyman, Carlton Greene, and Jorge Pesok.
Speech/Presentation
Federal Tax Policy To Watch In The 2nd Half Of 2020 Law360 (July 13, 2020)
Media Mentions
"LB&I Tells Employees to Resume Normal Operations," Tax Alert (July 6, 2020). Contacts: David J. Fischer, Teresa Abney
Client Alert/Newsletter
"Supreme Court Declines Certiorari in Altera, Stock-Based Compensation Cost Sharing Regulations Stand," Tax Alert (June 26, 2020). Contacts: David J. Fischer, Eleanor Moran McWaters
Client Alert/Newsletter
INSIGHT: Impact Of Proposed IRS Regulations Under Section 45Q For Carbon Capture Credit (June 17, 2020). Authors: David B. Blair, David J. Fischer, Teresa Abney, Carina C. Federico.
Publications
"IRS Announces Proposed Regulations Under Section 45Q for Carbon Capture Credit," Tax Alert (June 2, 2020). Contacts: David B. Blair, David J. Fischer, Teresa Abney, Carina C. Federico
Client Alert/Newsletter

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Crowell & Moring LLP is an international law firm with more than 500 lawyers representing clients in litigation and arbitration, regulatory, and transactional matters. The firm is internationally recognized for its representation of Fortune 500 companies in high-stakes litigation, as well as its ongoing commitment to pro bono service and diversity. The firm has offices in Washington, DC, New York, Los Angeles, San Francisco, Orange County, London, and Brussels.

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