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Lauren Ann Ross

Partner

Washington +1 202 662 5017

  • About
  • Representative Matters
  • Credentials
  • About

    Lauren Ann Ross advises clients on transfer pricing issues and in tax controversy matters. Lauren represents clients in securing Advance Pricing Agreements, in Mutual Agreement Procedures, in obtaining Pre-Filing Agreements, in IRS examinations, at IRS Appeals, and in Tax Court litigation. Lauren's clients include U.S- and foreign-based multinationals and professional sports leagues and clubs.

    Lauren helps clients implement cross-border intercompany transaction flows and transfer pricing policies, often partnering with foreign tax advisors and transfer pricing economists. Lauren helps clients evaluate their existing transfer pricing documentation and Country-by-Country Reporting practices. As appropriate, she helps clients achieve certainty on transfer pricing issues through the Advance Pricing Agreement (APA) process and on other tax issues through the Pre-Filing Agreement (PFA) program. When examinations arise, Lauren provides strategic advice to clients undergoing IRS and foreign tax audits. She also represents clients at IRS Appeals, including in Fast Track and the Rapid Appeals Process, and in Mutual Agreement Procedure (MAP) proceedings under tax treaties.

    As a member of the firm’s Sports Industry Group, Lauren advises multiple professional sports organizations, including FIFA, MLS, the NBA, the NFL, the NHL, and dozens of professional sports teams. She has particular expertise in matters involving League governance, licensing and media agreements, and cross-border transactions. Lauren has helped sports organizations achieve no change letters in a number of recent audits, and she was a member of the team that successfully litigated a Tax Court case regarding the deductibility of meal expenses for an NHL club.

    Lauren is the co-author of the Bloomberg BNA Tax Management Portfolio on Section 482 and the chapter on IRS Examination and Appeals in the Practical Guide to Transfer Pricing treatise. Prior to joining Covington, Lauren clerked for the Honorable Allyson K. Duncan on the Fourth Circuit Court of Appeals.

    Areas of Expertise

  • Practices and Industries
  • Representative Matters
    • Represents U.S. multinationals and U.S. subsidiaries of foreign-based multinationals in securing Advance Pricing Agreements.
    • Advises multiple Fortune 500 companies under IRS Examination or at IRS Appeals, including on transfer pricing issues and FDII.
    • Represents taxpayers in responding to IRS summonses, tax-related subpoenas, and exchange of information requests, including managing extensive collection, search, and review of electronically stored information.
    • Advises in particular foreign-based multinationals in major cross-border restructurings, including providing analysis of tax-treaty, transfer pricing, and TCJA issues.
    • Advises four major sports organizations on cross-border tax and transfer pricing issues, including international game series and international licensing transactions.
    • Secured “no change” letters from the IRS Examination division in three separate audits of professional sports leagues and related legal entities.
    • Secured a Pre-Filing Agreements on a tax treaty issue for a foreign-based multinational.
    • Represented the audit committee of a foreign-based multinational in internal investigation of whistleblower allegations of tax and accounting fraud.
    • Provided domestic and international tax advice to the National Basketball Association regarding its formation of NBA Africa and the Basketball Africa League.
    • Counsel to National Hockey League team in in successful trial before the U.S. Tax Court involving limitations to the deductibility of certain business expenses. Jacobs v. Commissioner, 148 T.C. No. 24 (2017).
    • Represented multiple sports clubs in IRS Fast Track and IRS Appeals proceedings.

     

    Areas of Expertise

  • Credentials
    Education
    • Duke University School of Law, J.D., 2013
        • magna cum laude
        • Order of the Coif
        • Duke Law Journal, Executive Editor
        • Moredecai Scholar
    • Vanderbilt University, B.A., 2010
        • summa cum laude
        • Phi Beta Kappa
        • Cornelius Vanderbilt Scholar
    Bar Admissions
    • District of Columbia
    • Pennsylvania
    • U.S. Court of Appeals for the Fourth Circuit
    • U.S. Tax Court
    Judicial Clerkship
    • Hon. Allyson K. Duncan, U.S. Court of Appeals, Fourth Circuit, 2013 - 2014
    Pro Bono
    • Represents nonprofit organizations and low-income taxpayers in federal and state tax controversy matters.
    • Assists low-income homeowners and renters in applying for the District of Columbia’s Schedule H tax credit.

    Areas of Expertise

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