Photograph of Irina Pisareva

Irina Pisareva

Partner


Irina Pisareva is a partner in the New York office of Crowell & Moring. She has 25 years of experience advising businesses and investors on transaction tax and cross-border tax matters.

Irina’s most recent practice focused on providing tax advice to investment funds, corporations, tax-exempt investors, venture capital and private equity groups and high net worth individuals and family offices. She also advises clients on tax compliance and tax operational issues relevant to cross-border investments, credit and distressed debt transactions, global securities trading and mobile workforce. She is a frequent contributor on these topics and has been quoted in Law360 and Bloomberg Law

Irina also practices in the growing area of litigation finance. She provides tax advice to litigation funders, private equity firms, and multi-strategy hedge fund clients in connection with their investments in funding transactions, including claims monetization and the provision of non-recourse capital to both plaintiffs and law firms. Irina’s other areas of professional focus include taxation of novel asset classes, such as crypto currency.

Irina is a well-regarded international tax adviser with significant experience in international taxation of corporations, partnerships and their investors. She frequently advises her clients on recent U.S. and global tax developments (e.g., BEAT, GILTI, FDII, OECD and BEPS initiatives). Irina has led multiple complex cross-border operational transformation and restructuring projects for U.S. and non-U.S. based multinationals including design, implementation and reporting for tax and financial statement purposes. She has assisted her clients with various aspects of digitally transforming and automating their tax function, obtaining private letter rulings in multiple jurisdictions, managing withholding tax obligations and refunds and matters related to transfer pricing documentation and controversy.

Irina is an active member of the New York City Bar Association and is a member of its Private Investment Funds and Taxation of Business Entities Committees. She is also a member of the International Bar Association and multiple other professional organizations.

Prior to joining the firm, Irina was a partner with Sullivan & Worcester LLP and before that a senior tax partner with EY. Her most recent publication is the chapter on the USA corporate tax laws and regulations which she has co-authored for the GLI’s Global Tax Laws and Regulations 2021.

Representative Matters

  • Structured distressed debt and infrastructure credit funds; assisted a large institutional asset manager with structuring a loan origination fund, based on investor type, with some of the options resulting in 0% effective tax rate.
  • Advised a litigation funding provider on tax aspects of providing litigation funding in Germany and Greece.
  • Advised private equity firms on the implications of the 2017 Tax Cuts and Jobs Acts for its portfolio companies; assisted private equity firms with diligence and structuring of new investments including in the life science and high-tech industries.
  • Advised mutual fund managers on transfer pricing, informational reporting, withholding tax reclaim and tax compliance matters related to cross-border securities trading and fund structures.
  • Designed and implemented ASC 740 assessment and documentation processes for multiple hedge funds and institutional asset managers.
  • Structured investment vehicles for sovereign wealth funds and tax-exempt investors.
  • Advised on foreign investment in real estate and natural resource assets worldwide, airplane leasing structures, CLOs and other asset securitization vehicles.
  • Advised on global workforce projects, including payroll, intellectual property management, taxable presence and individual tax implications of expatriate assignments.
  • Advised on U.S. and international tax implications of litigation finance strategies.
  • Assisted investment managers with setting up investment management companies in the UK, Singapore, Hong Kong, New Delhi and Chile, among others.
  • Advised high-net-worth individuals (HNWI) and executives on global relocation, estate management matters and succession planning. Structured private businesses, including acquisitions, divestitures for HNWI and family offices and advised on tax implications of their investment portfolios and real estate holdings.

Education

  • New York University School of Law, LL.M. International Taxation
  • Saint Petersburg State University, J.D.

Affiliations

Admitted to practice: New York

View More

"President Biden Employs Defense Production Act and Tariff Act in Domestic Clean Energy Manufacturing Push," Government Contracts Bullet Points (June 7, 2022). Contacts: Stephanie L. Crawford, Irina Pisareva, Jonathan M. Baker, Paul Freeman, Larry F. Eisenstat, Robert L. LaFrankie, John B. Brew
Client Alert / Newsletter
"The Importance of an 83(b) Election for Startup Founders," GrowthStudio (May 2, 2022). Authors: Anthony Provenzano, Irina Pisareva, Hillary Webb, and Matthew Moisan
Publication
"Deposit Penalty Relief for Superfund Chemical Taxes," Tax Alert (April 18, 2022). Contacts: Irina Pisareva, David B. Blair
Client Alert / Newsletter
"Tax Treatment of S Corp Distributions: Income and Deduction Rules, Basis, Salary vs. Income, Tax Distributions," Strafford Webinar (April 6, 2022). Speakers: Irina Pisareva and Eric Homsi.
Speech/Presentation
"President Biden Issues Executive Order Directing “Whole of Government” Assessment of Digital Assets," Financial Services Alert (April 5, 2022). Contacts: Alexander Urbelis, Anand Sithian, Stephanie L. Crawford, Caroline E. Brown, Richard J. Lee, Irina Pisareva, Carlton Greene
Client Alert / Newsletter
"SEC Announces 2022 Examination Priorities," Financial Services Alert (April 1, 2022). Contacts: Carlton Greene, Anand Sithian, Irina Pisareva, Richard J. Lee, Nimrod Haim Aviad, Caroline E. Brown, Alexander Urbelis
Client Alert / Newsletter
"Hot Topics in Litigation Finance," The Association of Commercial Finance Attorneys Webinar (March 29, 2022). Panelist: Irina Pisareva.
Speech/Presentation
"Global and U.S. Tax Reform Update," Federal Bar Association - 2022 Tax Law Conference Webinar (March 4, 2022). Speaker: Irina Pisareva.
Speech/Presentation
"Build Back Better Green Energy Tax Credit Proposals: Direct Pay," Bloomberg Tax (February 24, 2022). Authors: David B. Blair, and Irina Pisareva.
Publication
"Build Back Better Green Energy Tax Credit Proposals: Buy America," Bloomberg Tax (February 23, 2022). Authors: David B. Blair, Addie R. Cliffe, Irina Pisareva.
Publication

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Crowell & Moring LLP is an international law firm with offices in the United States, Europe, MENA, and Asia that represents clients in litigation and arbitration, regulatory and policy, and transactional and corporate matters. The firm is internationally recognized for its representation of Fortune 500 companies in high-stakes litigation and government-facing matters, as well as its ongoing commitment to pro bono service and diversity, equity, and inclusion.

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