Elizabeth Ann Smith has a diverse tax practice, working in both transactional tax and controversy matters, with an emphasis in the hedge fund industry and in New York state residency and domicile cases.
In addition, she has significant experience representing taxpayers before the IRS in the voluntary disclosure programs as well as assisting clients with the new streamlined procedures and “opt outs.”
Betsy frequently advises on mergers and acquisitions and also advises onshore and offshore investment managers regarding fund formation and strategic tax planning.
She is responsive and engaged with her clients and truly understands their attitudes toward a matter, which allows her to determine the best strategy to employ in resolving their disputes. Betsy is a member of the firm’s Policy Committee.
- A $200 million tax transactional case challenged by the IRS required aggressive representation of a client. The matter involved the transfer of stock options, which had been disallowed by the IRS. Defeated the IRS without ever having to litigate in U.S. Tax Court, saving the client legal fees as well as penalties and interest.
- Experienced in providing tax advice and counsel to energy companies on industry-related tax concerns, recently obtained a private letter ruling from the IRS for a client in the energy credit area, saving the client millions of dollars in U.S. federal income taxes.
- In a fact-intensive and multimillion-dollar matter, represented a well-known sportscaster in a New York City residency challenge, obtaining a “no change on audit” by being able to factually prove that the taxpayer was not in New York the requisite period of time required to be considered a statutory resident and legally defeating a domicile challenge.
- A settlement in favor of a client was obtained during representation of a former CEO of a public company in a New York state residency and domicile challenge.
- Managed Fund Association
- American Bar Association: Tax Section
- New York State Bar Association: Tax Section
- Her Justice: Designated Corporate Partner
- The Junior League of the City of New York, Inc.
- Board of Directors (2010 to 2013)
- Former Treasurer and Chief Financial Officer
- Trinity College (Hartford, Connecticut): Parent Director (2010 to present)
- Colonial Dames of New York: Assistant Treasurer (2013)
- St. Bernard’s School: Centennial Benefit Co-Chair
- LL.M., New York University
- J.D., Rutgers University
- B.A., University of Pennsylvania
- U.S. Tax Court
- U.S. Court of Federal Claims
- New York
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