Kristina Novak

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Kristina L. Novak, PC focuses her practice on defending individuals and businesses in all stages of federal civil and criminal tax controversies, including litigation, US Internal Revenue Service (IRS) examinations and administrative appeals. In addition, she has advised clients on tax-related aspects of public and private mergers and acquisitions, cross-border and private equity fund investments, and bankruptcies and restructurings of financially troubled companies. Kristina also has experience in estate planning and administration, and estate and trust taxation. Read Kristina Novak's full bio.

US Tax Reform: Potential Role of the APA Program

By and on Jan 31, 2018
Posted In Tax Reform, Transfer Pricing Resource, Uncategorized

US tax reform finally occurred in 2017 with what was formerly referred to as the Tax Cuts and Jobs Act of 2017 (the Act). The headline from a corporate standpoint is reduction in the maximum rate from 35 percent to 21 percent beginning in 2018. In the international context, the Act: (i) embraces a territorial...

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Tax Court: Prior Closing Agreement May Have Relevance in Coca-Cola’s Transfer Pricing Case

By and on Oct 20, 2017
Posted In Court Procedure Matters, IRS Guidance, Transfer Pricing Resource, Uncategorized

Coca-Cola is seeking a re-determination in Tax Court of certain Internal Revenue Service (IRS) transfer-pricing adjustments relating to its 2007–2009 tax years. In the case, the IRS moved for partial summary judgment seeking a ruling that a 1996 Internal Revenue Code Section 7121 “closing agreement” executed by the parties is not relevant to the case...

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You Must Comply: IRS LB&I Reveals Details of Its Inbound Distributor and OVDP Decline-Withdrawal Campaigns

By on May 15, 2017
Posted In IRS Guidance, Transfer Pricing Resource, Uncategorized

On Wednesday, May 10, 2017, the Internal Revenue Service (IRS) Large Business and International Division (LB&I) hosted a webinar with the Association of International Certified Professional Accountants (AICPA) regarding LB&I’s recently-announced campaigns targeting inbound distributors and taxpayers who either were declined by, or withdrew from, the IRS’s Offshore Voluntary Disclosure Program (OVDP). Our previous coverage of LB&I’s...

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IRS Practice Unit Advises Examiners to Use Aggregate Approach in Valuing Outbound Transfers

By and on Jan 12, 2017
Posted In IRS Guidance, Uncategorized

On January 4, 2017, the Internal Revenue Service (IRS) released a new “International Practice Unit” (IPU) on the value of intangibles in IRC Section 367(d) transactions in conjunction with cost sharing arrangements (CSA). See IPU here. The IPU notes that transferring highly valuable intangibles offshore has become a routine tax strategy for reducing a company’s...

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Attorney Cannot File Petition to Recover Administrative Costs under Section 7430

By on Nov 22, 2016
Posted In Court Procedure Matters, Uncategorized

In Greenberg v. Commissioner, 147 T.C. No. 13 (2016), an attorney sought the award of administrative costs (i.e., his attorney’s fees) for an earlier administrative proceeding in which he represented a taxpayer before the Internal Revenue Service. The attorney was owed fees for his representation of the taxpayer that remained outstanding, and the taxpayer agreed...

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IRS Releases Practice Unit on Residual Profit Split Method

By and on May 6, 2016
Posted In IRS Guidance, Transfer Pricing Resource, Uncategorized

On March 7, 2016, the Internal Revenue Service (IRS) released a new International Practice Unit (IPU) on a specific transfer pricing method—the residual profit split method (RPSM).  The IPU explains to IRS examiners how to determine if the RPSM is the “best method” under Section 482, and if so, how to apply such method between...

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Senate Finance Committee Approves Tax Court Nominees Copeland and Stoll

By and on Apr 19, 2016
Posted In Court Procedure Matters, Trial Courts, Uncategorized

Senate Finance Committee Ranking Member Ron Wyden (D-Oregon) issued an April 18, 2016 statement noting the committee’s approval of Tax Court nominees Elizabeth Copeland and Vik Stoll.  In 2015, President Obama nominated Copeland and Stoll to be judges at the US Tax Court. Copeland is a partner at the law firm Strasburger & Price, LLP....

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