Caitlyn Jacobs is of counsel in the firm’s Silicon Valley office. Ms. Jacobs advises clients on a variety of domestic and international tax issues, with a particular focus on controversy matters. She has represented multinationals through all stages of the administrative process, as well as in litigation matters and before the IRS National Office.
Ms. Jacobs has successfully resolved controversies in a number of subject matter areas, including cross-border trading structures, foreign tax credits, complex transfer pricing disputes, capitalization and amortization issues, methods of accounting, and the domestic production deduction. She also advises clients on cross-border distribution structures, cross-border services arrangements, and IP transactions, among others.
- Harvard Law School, J.D., 2010
- Stanford University, M.A., 2006
- Stanford University, B.A., 2005
Bar Admissions :
- District of Columbia
Representative Matters :
- Advising professional sports and esports leagues regarding formation and operating issues.
- Advising multinationals on requests for bilateral APAs.
- Advising multinationals regarding the application of Subpart F to offshore leasing and financing activities.
- Obtaining a private letter ruling regarding the capitalization of significant contractual payments.
- Advising multinationals regarding the application of income tax treaties to certain cross-border payments.
- Advising multinationals regarding foreign tax credit planning, foreign tax credit splitting events, and the creditability of certain foreign taxes.
Memberships and Affiliations :
- International Fiscal Association – Central YIN Committee
- IFA USA – YIN Representative
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