Julia Ushakova-Stein focuses her practice on U.S. tax planning and tax controversy matters, with an emphasis on international tax planning (inbound and outbound) and restructurings, M&A, and transfer pricing. She represents clients from a diverse set of industries and geographic areas. She has represented a number of Fortune 500 companies in U.S. federal income tax matters and has successfully represented clients in federal tax controversies at all levels.
Julia currently represents VF Corporation, and is preparing for trial, in the U.S. Tax Court on a Section 367(d) issue involving a $1.4 billion income adjustment by the IRS. This closely watched case involves a cutting-edge tax approach to international M&A. Julia also was counsel in Conversant et al. v. Commissioner, Tax Court Docket No. 030476-14, and was on the trial team that won Analog Devices, Inc. & Subsidiaries v. Commissioner, 147 T.C. No. 15 (Nov. 22, 2016).
In some noteworthy transactions, Julia represented Facebook, Inc. in its $2 billion acquisition of Oculus, which won International Tax Review’s Consumer Products Deal of the Year; Goldman Sachs and 13 major New York banks in their investment in Symphony Communications, which won International Tax Review's Joint Venture of the Year award; J.P. Morgan, Barclays and ICAP in their investment in Cloud9 Technologies LLC, which was shortlisted for International Tax Review's America’s Banking Tax Deal of the Year; and General Motors in its acquisition of Cruise Automation, a leader in autonomous driving technology, which was shortlisted for International Tax Review’s America’s Consumer Products Tax Deal of the Year.
Julia received Euromoney’s “Americas Women in Business Law Awards” Rising Star: Tax in 2017 and appears in Legal Media Group’s 2017 Expert Guides: Rising Stars publication. She’s also a nominee for International Tax Review’s “Women in Tax Leaders.”
In addition, Julia speaks at conferences for professional tax groups and her publications include:
- “IRS Taking a Hard Look at Transfer Pricing”, Daily Journal, September 2016;
- “New Intercompany Debt Rules Shock Multinational Companies”, Euromoney’s LMG Rising Stars, 2nd Edition, Summer 2016;
- “US Tax Developments Affecting Financial Institutions and Products”, International Tax Review, Financial Services, 1st Edition, Spring 2014, Number 90, pp. 53-56;
- "Seeking Privileged Information Under Schedule UTP: Protections and Privileges for Taxpayers", DePaul Business & Commercial Law Journal, Vol. 9, Spring 2011, Number 3, pp. 445-470.
Fenwick is first tier in Tax Planning, Tax Transactional, and Transfer Pricing, according to International Tax Review. Fenwick & West was named San Francisco Tax Firm of the Year eight times by International Tax Review. Fenwick also was U.S. Tax Litigation Firm of the Year three times, and received multiple ITR M&A tax awards including “Americas M&A Tax Firm of the Year.”
Julia is a member of the firm’s Pro Bono Committee and regularly provides pro bono services to various nonprofit organizations.
During law school, Julia served as the Supervising, Development, and Executive Editor for the Berkeley Business Law Journal.