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Julia Ushakova-Stein

Associate, Tax  

Mountain View 650.335.7848

Overview

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 was honored as one of the top 40 lawyers under 40 by the American Bar Association in 2018 and was the only person to win Euromoney’s Women in Business Law’s Americas Rising Star in Tax award in 2017. She appears in Euromoney’s 2018 and 2017 Expert Guides: Rising Stars in the Tax category and International Tax Review’s 2017 Women in Tax Leaders. Julia was also recognized by California Super Lawyers as a Rising Star in 2018 and shortlisted in the Best in Tax and Tax Disputes category for Euromoney’s 2018 Americas Rising Star Awards.

Julia’s currently represents VF Corporation in TBL Licensing v. Commissioner, Tax Court Dkt. No. 21146-15, a pending Tax Court case that involves Section 367(d) and a $1.4 billion income adjustment by the IRS. Julia also was counsel in successfully settled Conversant et al. v. Commissioner, Tax Court Docket No. 030476-14, and was on the trial team that was successful in Analog Devices & Subsidiaries v. Commissioner, 147 T.C. No. 15 (Nov. 22, 2016).

In some noteworthy transactions, Julia represented:

  • Facebook in its $2 billion acquisition of Oculus VR, 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, which was shortlisted for International Tax Review's America’s Banking Tax Deal of the Year;
  • 35 major domestic and foreign banks (e.g., Citibank, Bank of America and Merrill Lynch) in their consortium investment in R3, which won International Tax Review's America’s Financial Services Tax Deal of the Year award;
  • 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;
  • Jet.com in its acquisition by Walmart, which was shortlisted for International Tax Review’s America’s Consumer Products Tax Deal of the Year; and
  • Symantec in its acquisition of Lifelock, which was shortlisted for International Tax Review’s America’s Consumer Products Tax Deal of the Year.

In addition, Julia teaches international tax in the Master’s Program at San Jose State University and regularly speaks at major tax conferences for professional tax groups, including for the International Fiscal Association, International Tax Review, and Euromoney. She is the Young International Fiscal Association (YIN) Northern California regional representative. Her publications include:

  • Taxation of Intellectual Property under Domestic Law, EU Law and Tax Treaties,” International Bureau of Fiscal Documentation, EC and International Tax Law Series, June 2018
  • IRS Notice 2018-26: Important New Guidance on the Mandatory Repatriation Tax,” Fenwick & West, April 6, 2018
  • “OECD’s Recent Discussion Drafts Give Broad Power to the Taxing Authorities,” ITR Women in Tax Leader’s Guide, September 2017
  • “IRS Taking a Hard Look at Transfer Pricing,” Daily Journal, September 2016
  • “New Intercompany Debt Rules Shock Multinational Companies,” Euromoney’s LMG Rising Stars, Summer 2016
  • “US Tax Developments Affecting Financial Institutions and Products,” International Tax Review - Financial Services, Spring 2014
  • "Seeking Privileged Information Under Schedule UTP: Protections and Privileges for Taxpayers," DePaul Business & Commercial Law Journal, Spring 2011

Fenwick & West is first tier in Tax Planning, Tax Transactional, and Transfer Pricing, according to International Tax Review. Fenwick is consistently named San Francisco Tax Firm of the Year by International Tax Review. Fenwick has also been named U.S. Tax Litigation Firm of the Year numerous times and U.S. Tax Court Firm of the Year, and received multiple ITR M&A tax awards including “Americas M&A Tax Firm of the Year.”

During law school, Julia served as the Supervising, Development, and Executive Editor for the Berkeley Business Law Journal.