Photo of Irina Pisareva

Irina Pisareva is a partner in the New York office of Crowell & Moring. She has 25 years of experience advising businesses and investors on transaction tax and cross-border tax matters.

Irina’s most recent practice focused on providing tax advice to investment funds, corporations, tax-exempt investors, venture capital and private equity groups and high net worth individuals and family offices. She also advises clients on tax compliance and tax operational issues relevant to cross-border investments, credit and distressed debt transactions, global securities trading and mobile workforce. She is a frequent contributor on these topics and has been quoted in Law360 and Bloomberg Law.

Irina also practices in the growing area of litigation finance. She provides tax advice to litigation funders, private equity firms, and multi-strategy hedge fund clients in connection with their investments in funding transactions, including claims monetization and the provision of non-recourse capital to both plaintiffs and law firms. Irina’s other areas of professional focus include taxation of novel asset classes, such as crypto currency.

President Biden will soon sign into law the Inflation Reduction Act (IRA), which provides $750 billion in funding and major federal policy changes impacting the U.S. energy, environment, healthcare and tax sectors. On August 7, 2022, the IRA passed the U.S. Senate by an all-Democrat 50-50 party line vote, with Vice President Harris breaking the tie and ensuring passage. On August 12, 2022, the IRA passed the U.S. House by a vote of 220 to 207. The President’s signature, will make the bill law, and allow President Biden, U.S. Senate Majority Leader Chuck Schumer (D-NY), and U.S. House Speaker Nancy Pelosi (D-CA) to claim a major victory while making progress on a portion of the President’s Build Back Better agenda just three months before the mid-term elections on November 8, 2022.

The Crowell and Moring LLP and Crowell & Moring International (CMI) teams have put together this Client Alert with two main purposes. The first is to provide a summary of the highlights of the bill, which is included in Section I, and the second is to provide a more detailed section-by-section review of the bill, which is provided in Section II.

Continue Reading President Biden To Sign New Inflation Reduction Act

Background and expected impact. The House and Senate have passed the CHIPS Bill of 2022 (HR 4346), and President Biden has said that he will sign it. In furtherance of the broad goal of reducing U.S. reliance on foreign suppliers of semiconductor chips, the Bill will add the Advanced Manufacturing Investment Credit (the “AMI Credit”) to the Internal Revenue Code (the “Code”). 

The CHIPS Bill could produce more than $20 billion in AMI Credit for the semiconductor industry. However, its expected value could be significantly reduced if the minimum corporate tax on book earnings, revived as part of the Manchin-Schumer deal and endorsed by the President, is enacted. 

Continue Reading The CHIPS Bill Introduces New Tax Credit to Incentivize U.S. Semiconductor Industry

On June 6, 2022, President Biden issued a White House Fact Sheet (“Fact Sheet”) outlining President Biden’s “Bold Executive Action to Spur Domestic Clean Energy Manufacturing” along with five related Defense Production Act (“DPA”) Presidential Determinations[1] (“Presidential Determinations”) and a Declaration of Emergency and Authorization for Temporary Extensions of Time and Duty-Free Importation of Solar Cells and Module from Southeast Asia (the “Declaration”).  The Fact Sheet states the President is (1) authorizing use of the DPA to accelerate domestic production of clean energy technologies; (2) encouraging domestic solar manufacturing capacity through the use of master supply agreements with enhanced domestic preferences; and (3) creating a two-year trade regulation bridge as domestic manufacturing for solar products scales up.  The White House stated that these actions are being taken to lower energy costs, reduce risks to the power grid, and mitigate climate change.  The Department of Energy (“DOE”) also released a statement on June 6 about the DPA Presidential Determinations which describes DOE’s concerns with regard to each material or technology for which a determination was issued.  The statements made by the White House and DOE also make clear that these actions to employ the DPA are part of the Administration’s broader “all of government” approach to addressing Environmental Justice, with the intention to “strongly encourage projects with environmental justice outcomes that empower the clean energy transition in low income communities historically overburdened by legacy pollution.”

Continue Reading President Biden Employs Defense Production Act and Tariff Act in Domestic Clean Energy Manufacturing Push