Elnaz Manoucheri

Elnaz Manoucheri

Elnaz Manoucheri is an associate in the firm’s Tax Practice Group and advises clients on a variety of international and domestic tax issues. Ms. Manoucheri’s practice focuses on advising multinational companies on tax-efficient structuring of cross-border acquisitions, dispositions, restructurings, financings, and internal reorganizations. Most recently, Ms. Manoucheri has advised on the application of the subpart F and the foreign tax credit rules.

Prior to law school, Ms. Manoucheri worked for five years in the financial accounting industry as a financial statements assurance associate in a “Big Four” accounting firm. In that role, she advised on the compliance of accounting principles, and analyzed and audited financial statements and other regulatory filings.

Prior to joining the firm, Ms. Manoucheri gained experience as an intern at the Office of the International Tax Counsel of the U.S. Treasury.

Subscribe to all posts by Elnaz Manoucheri

IRS Ramps Up Efforts to Target Taxpayers Who Deal in Cryptocurrency

Last July, the IRS announced its Virtual Currency Compliance Campaign, designed to intensify the IRS’s efforts to counter the underreporting of income related to cryptocurrency use. Through the campaign, the IRS will address noncompliance through taxpayer education, increased audits and initiations of criminal investigations. This past week the IRS began sending “educational” letters to more … Continue Reading

IRS Proposes Regulations under Section 1446(f) — Reporting Requirements and the “Backstop Withholding” Rules (Post 3 of 3)

In our first post regarding the proposed section 1446(f) regulations, we addressed the rules regarding which party is the withholding agent for purposes of section 1446(f). Sections 864(c)(8) and 1446(f) were adopted as part of tax reform. Section 864(c)(8) was enacted to reverse the holding of the Tax Court in Grecian Magnesite Mining v. Commissioner, which was affirmed by … Continue Reading

IRS Proposes Regulations under Section 1446(f) — Determining the Withholding Amount (Post 2 of 3)

In our first post on the proposed regulation under section 1446(f), we discussed which party is the withholding agent and outlined the various exceptions to withholding that could apply. Sections 864(c)(8) and 1446(f) were adopted as part of tax reform. Section 864(c)(8) was enacted to reverse the holding of the Tax Court in Grecian Magnesite Mining v. Commissioner, which … Continue Reading

IRS Proposes Regulations under Section 1446(f) — Which Party is Required to Withhold? (Post 1 of 3)

This post is the first of three installments providing an overview of recent proposed regulations under section 1446(f) that address withholding on certain sales of partnership interests by foreign partners of a partnerships engaged in the conduct of a U.S. trade or business (a “U.S. trade or business”). Sections 864(c)(8) and 1446(f) were adopted as part … Continue Reading
LexBlog