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's currently represents VF Corporation, and is preparing for trial, in the U.S. Tax Court on a Section 367(d) issue involving a $1.4 billion income adjustment by the IRS. This closely watched case involves a cutting-edge tax approach to international M&A. Julia also was counsel in Conversant et al. v. Commissioner, Tax Court Docket No. 030476-14, and was on the trial team that won 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; and 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.
Julia received Euromoney's "Americas Women in Business Law Awards" Rising Star: Tax in 2017. She's also a nominee for International Tax Review's "Women in Tax Leaders."
In addition, Julia speaks at conferences for professional tax groups and her publications include:
- "IRS Taking a Hard Look at Transfer Pricing", Daily Journal, September 2016;
- "New Intercompany Debt Rules Shock Multinational Companies", Euromoney's LMG Rising Stars, 2nd Edition, Summer 2016;
- "US Tax Developments Affecting Financial Institutions and Products", International Tax Review, Financial Services, 1st Edition, Spring 2014, Number 90, pp. 53-56;
- "Seeking Privileged Information Under Schedule UTP: Protections and Privileges for Taxpayers", DePaul Business & Commercial Law Journal, Vol. 9, Spring 2011, Number 3, pp. 445-70.
Julia received her J.D. from the University of California, Berkeley, School of Law (Boalt Hall), where she served as the Supervising, Development, and Executive Editor for the Berkeley Business Law Journal. She received her honors B.S.B.A., summa cum laude, in accounting from the University of Arizona, Eller College of Management.