Larissa Neumann focuses her practice on US tax planning and tax controversy with an emphasis on international transactions. She has broad experience advising clients on mergers and acquisitions, restructurings and has extensive transfer pricing experience.
Keen analytical skills coupled with a focus on providing clients practical solutions to complex tax issues have earned Larissa a reputation as a leading tax advisor both in the Silicon Valley and nationwide. She appears in Euromoney's World's Leading Tax Advisers and International Tax Review's World's Tax Controversy Leaders. Euromoney's Women in Business Law named Larissa America's Best Transfer Pricing Lawyer in 2017 and 2018. She also is consistently named by Euromoney as one of the World's Leading Transfer Pricing Advisors.
Larissa has successfully represented clients in federal tax controversies at the audit level and in appeals, Tax Court and other federal courts. She was counsel in the recent important taxpayer victory for Analog Devices, Inc. v. Commissioner, 147 T.C. No. 15 (2016), and the successful resolution for Sanofi in Aventis, S.A. v. United States, US Court of Federal Claims Dkt. No. 11647T. She currently is counsel for VF Corporation/Timberland in TBL Licensing LLC v. Commissioner, Tax Court Dkt. No. 2114615.
Larissa teaches International Tax at the University of California, Berkeley, School of Law.
For Tax Notes International, Larissa coauthors a monthly column on all recent development in US international tax. She is also on the executive committee of the International Fiscal Association (IFA) and serves as the Chair of the Technology Committee.
Larissa appears in Euromoney's Women in Business Law (a short list of the top women tax lawyers in the world) and ITR's Women in Tax Leaders. She has also been shortlisted for Euromoney's Women in Business Law America's Best Lawyer in Tax Dispute Resolution.
Larissa was named to the Daily Journal's 2017 list of Top Women Lawyers in California and was honored with the Women of Influence award by the Silicon Valley Business Journal in 2017.
Larissa frequently speaks at conferences for professional tax groups, including TEI, IFA, Pacific Rim Tax Institute, and the ABA. She is the ABA International Law Tax Liaison.
Fenwick has one of the World's Top Tax Planning and Transactional Practices, according to ITR, and is first tier, according to World Tax.
Fenwick is consistently named the San Francisco Tax Firm of the Year by ITR and has been named US Tax Litigation Firm of the Year. ITR has recognized Fenwick as the Americas M&A Tax Firm of the Year and the West Coast Transfer Pricing Firm of the Year.
Fenwick has advised over 100 Fortune 500 companies on tax matters, and has served as counsel in more than 150 large corporate IRS Appeals proceedings and more than 75 federal court tax cases.
Larissa is a leader on Fenwick's Pro Bono Review Committee and regularly provides pro bono services to various nonprofit organizations.
Fenwick was recognized by The National Law Journal Pro Bono Hot List and Larissa's nonprofit work is pointed to as exemplary in the profile.
Reasonable Cause Defense Waives Privilege?
In the pending Eaton transfer pricing advance pricing agreement (APA) case the court ordered that Eaton waived privilege and work product protections needed to withhold documents as a consequence of the company asserting the reasonable cause defense. The...