A Period of Great Tax Uncertainty
International tax planners today live in a period of great uncertainty. In the US, in particular, we expect soon to have significant changes made to our international tax rules20/04/2021
Larissa concentrates her practice on U.S. 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. Larissa has a reputation as a leading tax advisor due to her keen analytical skills coupled with a focus on providing clients practical solutions to complex tax issues.
Chambers and Partners recognized Larissa for the second consecutive year in 2020 for her “wide-ranging practice,” with clients noting that she has “strong international tax expertise” and “a lot of insight, and is thorough, responsive and careful.” Larissa has been named 2021 Tax Leaders by the International Tax Review’s Tax Leaders Expert Guide. Euromoney’s Women in Business Law named Larissa America’s Best Transfer Pricing Lawyer in 2017 and 2018, and she is consistently named as one of the World’s Leading Transfer Pricing Advisors. In addition, The Legal 500 has recognized Larissa several times, most recently as a Next Generation Lawyer for both her tax dispute and international tax work. She was also named to the Daily Journal’s 2017 list of Top Women Lawyers in California and honored with the Women of Influence award by the Silicon Valley Business Journal in 2017.
Larissa has successfully represented clients in federal tax controversies at the audit level, and in appeals, the U.S. Tax Court and other federal courts. She was counsel in the important taxpayer victory case Analog Devices v. Commissioner (2016), and the successful resolution for Sanofi in Aventis v. United States in the U.S. Court of Federal Claims. She is currently serving as counsel for VF Corporation/Timberland before the Tax Court in TBL Licensing v. Commissioner. Larissa is known for her collaborative working style and is an expert at negotiating intricate tax issues.
Larissa teaches international tax at the University of California, Berkeley, School of Law. She frequently speaks at conferences for professional tax groups, including TEI, IFA, Pacific Rim Tax Institute and the ABA. Larissa also coauthors a monthly column on all recent developments in U.S. international tax for the Tax Notes International. She is also on the executive committee of the International Fiscal Association and serves as President of the Women in IFA Network.
Larissa has advised on numerous noteworthy transactions, including:
- Tim Hortons in its high-profile $11.4B inversion transaction with Burger King, which won ITR’s America’s M&A Deal of the Year award
- Facebook in its serial acquisition program, including in the $2B acquisition of Oculus VR as well as the acquisitions of Redkix, Ozlo, LiveRail, Nascent Objects, Wit.ai, PrivateCore and CrowdStar
- Goldman Sachs and 13 major New York banks in their investment in Symphony Communications, which won ITR’s America’s Banking Tax Deal of the Year
- JPMorgan, Barclays and ICAP in their investment in Cloud9 Technologies, which was shortlisted for ITR’s America’s Banking Tax Deal of the Year
- Consortium of 40 leading domestic and foreign banks, including Citibank, Bank of America and Merrill Lynch in their consortium investment in R3, which won ITR’s America’s Financing Services Tax Deal of the Year
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Since the “new tax act” (the Tax Cuts and Jobs Act or TCJA) was signed into law in December 2017, tax has received a newly heightened importance20/08/2019
Transfer Pricing: Current issues
The 2017 Tax Reform Act added a new third sentence to § 482 that allows aggregation and the consideration of realistic alternatives if it produces the most reliable means of valuation29/03/2018
New Intercompany Debt Rules Shock Multinational Companies
On April 4, 2016, the United States Treasury and the Internal Revenue Service (“IRS”) issued proposed regulations under § 385 of the Internal Revenue Code (the “Code”)23/06/2016
US Tax Overview
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...
24/06/2015
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