WASHINGTON—Joanne Fay, former Special Counsel in the Office of Chief Counsel at the Internal Revenue Service, has joined Covington in its Washington office in its Tax Practice.
Before joining the firm, Joanne was Special Counsel, Litigation and Advisory, in the Office of Chief Counsel at the Internal Revenue Service, where she was a leader in cases involving the most complex cross border transactions under audit and related issues under the 2017 “Tax Cuts and Jobs Act” (TCJA). She worked closely with the IRS Examination function on issue identification and case development, analyzing tax return data and disclosures, including information returns, attribute calculations, transactional step plans, third party opinions and valuations, IDR responses, NOPAs, protests, rebuttals, and statutory notices of deficiency. Joanne also advised multiple IRS stakeholders on the development of legal theories and controversy strategy for structured cases and related TJCA planning, on the government’s defense against challenges to TCJA regulations, and on the development of alternative arguments to challenge related transactional planning.
Before joining the IRS, Joanne served as in-house tax counsel for multinational businesses, and in a prior tour of government service she served as Branch Chief in the IRS Office of Associate Chief Counsel (Corporate), the office responsible for regulatory and other guidance on all tax matters involving corporations and consolidated groups. At Covington, Joanne will focus on corporate tax matters, including structural and transactional planning, in addition to tax controversy.
“Joanne’s extensive experience at the IRS Office of the Chief Counsel and her in-house tax experience provides her with unique insight into the issues our clients are dealing with,” said Dirk Suringa, chair of the firm's Tax Practice Group. “This sophisticated understanding will provide clients with the ability to navigate complex regulations, structure transactions efficiently, and provide reliable guidance to support their long-term objectives.”
“I am thrilled to be joining Covington and look forward to collaborating with colleagues across the firm and deliver meaningful results for clients,” said Joanne. “I look forward to applying my tax law background in tackling challenges and delivering practical and strategic solutions for clients.”
Joanne received her J.D. at the University of Chicago Law School, her LL.M in Tax at the Georgetown University Law Center, and her B.A./B.S. at The Wharton School of the University of Pennsylvania.