Tax Planning: Companies appreciate Larissa’s international tax knowledge and her ability to develop strategic forward-thinking plans that can withstand tax controversy challenges. Representations include: Univision in its integration with Televisa to form the largest Spanish-language media company in the world; Meta’s international structure, foreign tax credits and intercompany agreements; Viacom, Paramount and CBS with global media distribution operations; ViX streaming OTT platform with treaty, pricing, and withholding issues; Estee Lauder on transfer pricing issues; Tim Hortons in its inversion transaction with Burger King, which won an ITR award; Eaton’s inversion with Cooper; and Goldman Sachs and 13 other banks in their FINOS venture.
Tax Controversy: Larissa is a committed advocate who is sought out for her ability to resolve tax disputes at all stages. Representations include: Analog Devices v. Commissioner, 147 Tax Court No. 15 (2016), Aventis v. United States, U.S. Court of Federal Claims Dkt. No. 11 647T (2017), Amicus Curiae for Xilinx in support of Altera’s Ninth Circuit appeal, and TBL Licensing v. Commissioner, Tax Court Dkt. No. 21146-15.
Transactional Tax: Larissa is a strong practical negotiator with significant transactional tax experience. Representations include: Facebook in its $2B acquisition of Oculus, which won ITR’s Consumer Products Deal of the Year; Facebook on its 2020 $5.7 billion investment in Jio Platforms, the biggest telecom operator in India; ViacomCBS in its partnership with beIN Media via acquisition of a 49% stake in Miramax; Glu Mobile in it $2.4 Billion acquisition by Electronic Arts; J.P. Morgan and Barclays in their investment in Cloud9 Technologies, which was shortlisted for ITR's America’s Banking Tax Deal of the Year; and 35 major domestic and foreign banks (e.g., Citibank, Bank of America and Merrill Lynch) in their consortium investment in R3, which won ITR's America’s Financial Services Tax Deal of the Year award.
She 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.