概述

Jenny Austin is a partner in Mayer Brown's Chicago office and a member of the Tax Controversy practice. She concentrates her practice on federal tax controversy and litigation, working across all industries, including medical device, pharmaceutical, health care, retail, and technology companies. She guides clients through all stages of tax controversies, from Internal Revenue Service (IRS) audits to administrative appeals, alternative dispute resolution proceedings, and litigation. Jenny is prepared to respond to a variety of both domestic and international issues that the IRS audits and challenges. Jenny favors strategies to resolve issues successfully with the IRS at the earliest possible stage without litigation.

Jenny’s tax controversy experience spans a diverse array of subject matter areas, including: transfer pricing, cross-border acquisition issues, debt-equity issues, settlement agreements, withholding, privileges, summons enforcement, and penalties. She also has experience with transfer pricing issues at the state level.

Jenny maintains an active pro bono practice, most notably working to exonerate an individual wrongfully convicted of murder through a series of cases heard by the trial court, the Illinois Appellate Court, and the Illinois Supreme Court [People v. Ortiz, 919 N.E.2d 941 (2009)]. She successfully represented a client before the Illinois Department of Children and Family Services who faced a death by neglect indicated finding. She also has taught trial skills for prosecutors with the Tanzanian Prevention and Combating of Corruption Bureau in Tanzania.

业务专长

业务领域
行业

执业经验

  • Represented various pharmaceutical, medical device, health care, retail, and consumer product companies in disputes with the IRS over the tax consequences of cross-border operations, including section 482
  • Represented various companies in disputes with the IRS over cost-sharing and buy-in (pre-existing intangibles and acquisitions) related issues
  • Represented various technology companies in disputes with the IRS over global marketing activities and charges
  • Represented a multinational company in dispute with the IRS over outbound F reorganizations and related acquisition issues
  • Represented a multinational company in dispute with the IRS over a minority-financing partnership transaction
  • Represented various companies in disputes with the IRS over a variety of section 199 issues
  • Represented multinational companies in disputes with the IRS over section 956 (investment in US property)
  • Represented various companies in disputes with the IRS about the tax consequences of legal settlements, including section 162(f)
  • Represented a telecommunications company in a cross-border debt-equity dispute
  • VERITAS Software Corp. v. Commissioner, 133 T.C. 297 (2009)
  • Garcia v. Commissioner, 140 T.C. 141 (2013)
  • Medtronic, Inc. v. Commissioner, T.C. Memo 2016-112, rev’d and remanded for further factual findings, 900 F.3d 610 (8th Cir. 2018)
  • Medtronic, Inc. v. Commissioner, T.C. No. 17488-08
  • Garcia v. Commissioner, T.C. No. 11574-13
  • Apollo Education Group Inc. v. Department of Revenue, State of Oregon, Case No. 150352C
  • The University of Phoenix Inc. v. Indiana Department of State Revenue, 88 N.E.3d 805 (Ind. Tax Ct. 2017)

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教育背景

美国纽约大学法学院, LLM in Taxation

Washington University School of Law, 法律博士
Washington University Law Review

Washington University, BSBA, AB

执业资格

  • 伊利诺伊州

出庭资格

  • US Court of Appeals for the Eighth Circuit
  • US Tax Court

会员资格

  • Board Member, Midwest Region, UNICEF USA
  • Member, Tax Authority: Federal, US Editorial Advisory Board, Law360 (2019)
  • 40 Under 40, Chicago Lawyer and Chicago Daily Law Bulletin (2018)
  • Recommended, Tax: US taxes: contentious, The Legal 500 US (2018)
  • Member, Practice Group of the Year, Tax, Law360 (2017)
  • Vice Chair, Transfer Pricing Committee, Tax Section, American Bar Association (2017–present)