Lindsay Kitzinger

Lindsay Kitzinger is an associate in the firm’s Tax practice group.  Ms. Kitzinger’s practice focuses on advising multinational companies on restructurings, with an emphasis on outbound transactions, as well as the application of the subpart F and the foreign tax credit rules.  She also advises on the formation and structuring of partnership and joint ventures, as well as the tax aspects of corporate acquisitions.

Representative Matters

• Advised multiple multinational corporations on the U.S. tax aspects of the integration of their foreign operations.
• Advised multinational corporation on the application of the subpart F rules to the sale of its partnership interest in a joint venture.
• Advised client on the application of U.S withholding rules on payments to foreign entities.
• Advised multinational corporation under IRS audit on international tax provisions.
• Advised clean energy companies on the availability of treasury grants and investment tax credits.

Pro Bono

• Advised a 501(c)(3) in amending their IRS disclosures.
• Advised a 501(c)(3) in amending their Articles of Incorporation and maintaining their tax exempt status.

Publications and Speeches

• "Recent IRS Guidance Concerning Section 48C Manufacturing Credit Reminds that Standard for a "Significant Change" is Low, but Indicates Willingness to Consult with DOE on Whether Changes are Significant," Covington E-Alert (1/5/2011), Co-Author
• "The American Jobs and Closing Tax Loopholes Act of 2010 - Expected and Unexpected International Proposals," Covington E-Alert (5/20/2010), Co-Author