Jenny advises US taxpayers with respect to international tax implications of offshore operations, and handles matters involving transfer pricing, including cross-border transfer pricing of tangible and intangible assets and intellectual property, services, and cost sharing arrangements. She also has experience with transfer pricing issues at the state level. Additionally, Jenny counsels international taxpayers and partnerships with respect to their US tax obligations, and advises on withholding, excise tax, and information reporting obligations.
A large part of Jenny’s work involves advising and representing clients in administrative matters, including pre-audit planning and representation of taxpayers in examination, and the preparation of company personnel for IRS interviews. She is also heavily involved in other aspects of the controversy process, including IRS appeals, appeals mediation procedures, and competent authority. Jenny favors strategies to resolve issues successfully with the IRS at the earliest possible stage.
Jenny acts as lead for all aspects of case development from pretrial matters through post-trial briefing, including factual and strategic case development, discovery, stipulations, witness and expert preparation and examination, and drafting pleadings and legal briefs. Her experience includes defending against civil tax penalties and in addressing evidentiary privileges in the tax controversy contest, including the attorney client privilege and work product protection. She also has headed the trial of several state tax income cases involving costs of performance issues.
