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. She has successfully represented clients in federal tax controversies at the audit level and in IRS appeals, the US tax court and in other federal courts.
Larissa's keen analytical skills coupled with her focus on providing clients practical solutions to complex tax issues have earned her a reputation as a leading tax advisor both in the Silicon Valley and nationwide. Larissa appears in Euromoney's World's Leading Tax Advisers and International Tax Review's World's Tax Controversy Leaders.
Larissa teaches International Tax at the University of California, Berkeley Law School and coauthors a monthly column in Tax Notes International.
Larissa was counsel in the recent important taxpayer Tax Court victory involving transfer pricing for Analog Devices, Inc. v. Commissioner, 147 T.C. No. 15 (2016), and the 2017 successful resolution for Sanofi in Aventis, S.A. v. United States, US Court of Federal Claims Dkt. No. 11-647T. She also is counsel for VF Corporation/Timberland in TBL Licensing LLC v. Commissioner, Tax Court Dkt. No. 21146-15, a pending Tax Court case that involves § 367(d) and § 482.
Euromoney's Women in Business Law named Larissa the America's Best Transfer Pricing Lawyer in 2017. She also was named by Euromoney as one of the World's Leading Transfer Pricing Advisors (2017).
Larissa appears in Euromoney's Women in Business Law (a short list of the top women tax lawyers in the world) and International Tax Review's Women in Tax Leaders. Euromoney Women in Business Law shortlisted Larissa twice for the award 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. In 2016, Larissa was named a Rising Star in tax by Law360 and named to the Silicon Valley Business Journal's 40 Under 40.
Larissa frequently speaks at conferences for professional tax groups, including TEI, IFA, Pacific Rim Tax Institute, Bloomberg, and the ABA. She is the ABA International Law Tax Liaison.
Fenwick has one of the World's Top Tax Planning and Tax Transactional Practices, according to International Tax Review, and is first tier in tax, according to World Tax. Fenwick is consistently named the San Francisco Tax Firm of the Year by International Tax Review and has been named U.S. Tax Litigation Firm of the Year a number of times.
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...