Larissa concentrates her practice on U.S. tax planning and tax controversy with an emphasis on international transactions. She has broad experience advising clients on mergers and acquisitions, restructurings and has extensive transfer pricing experience. Larissa has a reputation as a leading tax advisor due to her keen analytical skills coupled with a focus on providing clients practical solutions to complex tax issues.
Chambers and Partners recognized Larissa for the second consecutive year in 2020 for her “wide-ranging practice,” with clients noting that she has "strong international tax expertise" and "a lot of insight, and is thorough, responsive and careful." Larissa has been named 2021 Tax Leaders by the International Tax Review’s Tax Leaders Expert Guide. Euromoney’s Women in Business Law named Larissa America’s Best Transfer Pricing Lawyer in 2017 and 2018, and she is consistently named as one of the World’s Leading Transfer Pricing Advisors. In addition, The Legal 500 has recognized Larissa several times, most recently as a Next Generation Lawyer for both her tax dispute and international tax work. She was also named to the Daily Journal’s 2017 list of Top Women Lawyers in California and honored with the Women of Influence award by the Silicon Valley Business Journal in 2017.
Larissa has successfully represented clients in federal tax controversies at the audit level, and in appeals, the U.S. Tax Court and other federal courts. She was counsel in the important taxpayer victory case Analog Devices v. Commissioner (2016), and the successful resolution for Sanofi in Aventis v. United States in the U.S. Court of Federal Claims. She is currently serving as counsel for VF Corporation/Timberland before the Tax Court in TBL Licensing v. Commissioner.
Larissa teaches international tax at the University of California, Berkeley, School of Law. She frequently speaks at conferences for professional tax groups, including TEI, IFA, Pacific Rim Tax Institute and the ABA. Larissa also coauthors a monthly column on all recent developments in U.S. international tax for the Tax Notes International. She is also on the executive committee of the International Fiscal Association, serves as the chair of the Technology Committee and is the ABA International Law Tax liaison.
Larissa has advised on numerous noteworthy transactions, including:
- Tim Hortons in its high-profile $11.4B inversion transaction with Burger King, which won ITR’s America’s M&A Deal of the Year award
- Facebook in its serial acquisition program, including in the $2B acquisition of Oculus VR as well as the acquisitions of Redkix, Ozlo, LiveRail, Nascent Objects, Wit.ai, PrivateCore and CrowdStar
- Goldman Sachs and 13 major New York banks in their investment in Symphony Communications, which won ITR’s America’s Banking Tax Deal of the Year
- JPMorgan, Barclays and ICAP in their investment in Cloud9 Technologies, which was shortlisted for ITR’s America’s Banking Tax Deal of the Year
- Consortium of 40 leading domestic and foreign banks, including Citibank, Bank of America and Merrill Lynch in their consortium investment in R3, which won ITR’s America’s Financing Services Tax Deal of the Year
Larissa is a leader on Fenwick's Pro Bono Review Committee and regularly provides pro bono services to various nonprofit organizations. Fenwick was recognized by The National Law Journal Pro Bono Hot List and Larissa's nonprofit work is pointed to as exemplary in the profile.
Fenwick has advised over 100 Fortune 500 companies on tax matters, and has served as counsel in more than 150 large-corporate IRS Appeals proceedings and more than 75 federal court tax cases. Fenwick is recognized by ITR as having one of the world’s top tax planning and transactional practices, and is listed as a tier-one firm by World Tax. The firm is also consistently named San Francisco & Silicon Valley’s Tax Firm of the Year by ITR and has been named U.S. Tax Litigation Firm of the Year. ITR has also recognized Fenwick as Americas M&A Tax Firm of the Year and West Coast Transfer Pricing Firm of the Year.
Larissa “brings a lot of insight, and is thorough, responsive and careful.”
Education & Admissions
J.D., University of California, Berkeley, School of Law
M.A., Public Health
B.S., Molecular Cell Biology
University of California, Berkeley
Admitted to practice in California and Pennsylvania
Member of ABA Section of Taxation
Admitted to practice in the U.S. Tax Court, the Federal Court of Claims and the U.S. Court of Appeals for the Ninth Circuit
Groups & Associations
Executive Committee Member of International Fiscal Association and Chair of the Technology Committee
Member of the IFA NorCal Region Steering Committee
Member of the ABA International Law Section Tax Committee
Member of the Animal Legal Defense Fund