Larissa Neumann is an internationally renowned tax advisor and Chair of the Tax Group at Fenwick, a firm known for their work in technology and life sciences. Neumann has extensive experience in tax structuring, dispute resolution and transaction negotiation for clients in Silicon Valley, New York and beyond. She also teaches international tax at UC Berkeley School of Law, writes for Tax Notes International and speaks at various conferences. Neumann is passionate about finding practical solutions for complex tax issues and helping her clients prepare for the IRS’s heightened scrutiny this year.
Lawdragon: Tell us about how you started off in tax law and your career trajectory.
Larissa Neumann: While I did not know that tax law would be my future when I started UC Berkley School of Law, after just a few classes of Professor Rakowski’s Intro to Tax course, I was hooked. It was fascinating to realize how the laws of taxation seemed to touch nearly every aspect of modern life, creating incentives that influence decisions as different as whether to form an LLC to whether you should marry your partner. That wide-ranging, practical applicability of tax law is what drew me to the field and makes my practice so rewarding. Tax is such a core part of any transaction and I absolutely love the feeling of helping clients navigate complicated tax systems and arrive at practical solutions that align with their business objectives.
LD: Tell us about your journey to Big Law.
LN: There was really no question of where I would land after law school because Fenwick was my immediate first choice. Fenwick’s robust international tax practice is unmatched and extremely well regarded. My summer internship program was such a wonderful experience, it was immediately apparent to me how much the team enjoyed solving complex tax problems together. This sense of camaraderie was infectious, and I connected with the Fenwick team through their enthusiastic love of all things tax and their authenticity. Our tax group has an incredibly exciting and sophisticated practice and, as an iconic Silicon Valley firm, Fenwick’s innovative client base keeps me engaged with the cutting edge of tech.
LD: As Chair of the Tax Group, what will you be focusing on this year and more broadly?
LN: We have a very strong team, so I want to double down on our collaborative approach and support the team and our clients by pulling in helpful resources and continuing to build our incredible practice. Fenwick’s client base continues to become more sophisticated. We will continue to keep pace with that growth by delivering sophisticated, high-quality counsel that advances the firm’s reputation as a leader in the industry.
I will also continue to champion diversity in our leadership roles, throughout the firm and with our clients as well. Fenwick has allowed me to advocate for diversity and has taken institutional steps to demonstrate a commitment to inclusion. As a leader, I am dedicated to creating the space and opportunities to empower diverse attorneys to advocate for their interests as well. For our clients, we have a history of supporting tax leaders by hosting and supporting women-led tax events as a way to inspire women to work beyond competition, be authentic, share their strengths and support each other.
LD: What are some trends that you see in the pipeline for 2023? Any major changes in tax law that are being discussed and potentially proposed?
LN: In 2023, the Internal Revenue Service is pouring significant resources into its controversy divisions. Increased scrutiny is coming for your business this year whether you are prepared or not. The IRS will ask for your business’ agreements and will review the economic substance of your transactions. That is why you need to get ahead of the curve through proactive tax planning. The right tax attorney can ensure that your structure is well thought out – having a “bigger picture” mindset when it comes to policy is crucial. It is also critical to have an advisor who can preview tax controversy risks and help you think through them at the planning stage as you analyze and solve related technical issues. Having a good sense of the likelihood of being pulled into a controversy proceeding and what that will look like is key in defending your position. Having a well-reasoned strategic plan in place long before you get that call from the IRS is the key to a favorable outcome in any tax controversy proceeding.
LD: What advice would you give young lawyers entering the profession?
LN: Be authentic and mindful of your strengths and weaknesses. Focus on your strengths, hone your expertise and be assertive when you have answers and insights that can be of value to your team and your clients. When there are gaps or weaknesses in your practice do not be afraid to leverage your colleagues’ strengths and collaborate! Great teams have members with a diversity of skills and viewpoints. Knowing where you can help and knowing where you need help will only make you a valuable member of any team.
Also, I cannot overstate how critical it is to be proactive from the beginning and take ownership of your projects. Be the captain of your own ship and the entrepreneur of your own business. You should seek as many mentors as possible and tailor their feedback to your needs. Express gratitude for their time by taking their advice to heart and putting their tips into practice. Lastly, jump in and get involved with key professional organizations, such as the International Fiscal Association (IFA), as that opens you up for more opportunities from mentorship to speaking engagements.