Julia Ushakova-Stein focuses her practice on U.S. tax planning and tax controversy matters, with an emphasis on international tax planning (inbound and outbound) and restructurings, M&A, and transfer pricing. She represents clients from a diverse set of industries and geographic areas. She has represented a number of Fortune 500 companies in U.S. federal income tax matters and has successfully represented clients in federal tax controversies at all levels.
Julia was the only person to win Euromoney's Women in Business Law's "Americas Rising Star - Tax" award in 2017. She appears in Euromoney's 2017 Expert Guides, "Rising Stars" in the Tax category and International Tax Review's 2017 "Women in Tax Leaders." Julia was also recognized by California Super Lawyers as a Rising Star in 2018.
Julia's currently represents VF Corporation in TBL Licensing LLC v. Commissioner, a pending Tax Court case that involves Section 367(d) and a $1.4 billion income adjustment by the IRS. Julia also was counsel in successfully settled Conversant et al. v. Commissioner, and was on the trial team that was successful in Analog Devices, Inc. & Subsidiaries v. Commissioner, 147 T.C. No. 15 (Nov. 22, 2016).
In some noteworthy transactions, Julia represented Facebook, Inc. in its $2 billion acquisition of Oculus, which won International Tax Review's Consumer Products Deal of the Year; Goldman Sachs and 13 major New York banks in their investment in Symphony Communications, which won International Tax Review's Joint Venture of the Year award; J.P. Morgan, Barclays and ICAP in their investment in Cloud9 Technologies LLC, which was shortlisted for International Tax Review's America's Banking Tax Deal of the Year; 35 major domestic and foreign banks (e.g., Citibank, Bank of America and Merrill Lynch) in their consortium investment in R3, which won International Tax Review's America's Financial Services Tax Deal of the Year award; General Motors in its acquisition of Cruise Automation, a leader in autonomous driving technology, which was shortlisted for International Tax Review's America's Consumer Products Tax Deal of the Year; Jet.com in its acquisition by Walmart, which was shortlisted for International Tax Review's America's Consumer Products Tax Deal of the Year; and Symantec in its acquisition of Lifelock, which was shortlisted for International Tax Review's America's Consumer Products Tax Deal of the Year.
In addition, Julia regularly speaks at major tax conferences for professional tax groups, including for the International Fiscal Association, International Tax Review, and Euromoney. Her publications include:
- "IRS Notice 2018-26: Important New Guidance on the Mandatory Repatriation Tax", April 6, 2018, http://www.fenwick.com/publications/Pages/IRS-Notice-2018-26-Important-New-Guidance-on-the-Mandatory-Repatriation-Tax.aspx?share;
- "OECD's Recent Discussion Drafts Give Broad Power to the Taxing Authorities", ITR Women in Tax Leader's Guide, 3rd Edition, September 2017;
- "IRS Taking a Hard Look at Transfer Pricing", Daily Journal, September 2016.