Latham & Watkins LLP's Jean Pawlow has represented Netflix as tax counsel in its string of successes in class actions across federal and state courts against claims that it was liable for state-based franchise fees.
Jean Pawlow is a partner in the Washington, D.C. and Silicon Valley offices of Latham & Watkins and a member of the Tax Controversy Practice.
Drawing on more than three decades of experience, Ms. Pawlow represents companies and individuals in high-profile tax controversy matters. She is recognized for being a strong litigator in matters of federal, state, and local tax controversies.
Her controversy experience involves handling a myriad of complex tax issues, including:
- Transfer pricing and other valuation issues
- Financial instruments, including credit card interchange and OID
- Foreign tax credit and research credit issues
- Leveraged leases
- Withholding and reporting issues
- Excise taxes
- Estate and gift tax issues
- Franchise taxes
- Tax incentives
Ms. Pawlow has a breadth of experience in all stages of the IRS administrative process, federal litigation, and Tax Court litigation. She has litigated cases before US district and appellate courts, as well as the US Tax Court, the US Court of Federal Claims, and the US Supreme Court. She has broad knowledge of the IRS alternative dispute resolution (ADR) procedures, including fast-track settlement, rapid appeals, post-appeals mediation, pre-filing agreements, and compliance assurance process (CAP) audits. Ms. Pawlow regularly represents clients who are undergoing audits by the IRS Global High-Wealth Industry Group.
Ms. Pawlow is a frequent speaker and writer and has appeared on CBS and CNBC, and was a contributing editor of Getting the Deal Through: Tax Controversy 2016. Ms. Pawlow formerly served on the firm’s Women Enriching Business (WEB) Committee, which promotes women in business both inside and outside the firm.
- American College of Tax Counsel Fellow
- US Court of Federal Claims Advisory Council, Tax Committee
- San Jose State University Lucas College and Graduate School of Business, Tax Advisory Board
Recent Speaking Engagements
- Panelist, "TEI Chicago" (February 2021)
- Panelist, “TEI Audits & Appeals Seminar” (August 2020)
- Panelist, “TEI San Francisco Ethics for In-House Tax Professionals” (January 2020)
- Panelist, “TEI Las Vegas” (December 2019)
- Panelist, “TEI Denver” (December 2019)
- Co-Chair, “Implications of State Aid Cases/OECD Transfer Pricing Guidelines,” Tax Planning Strategies, US and Europe (April 2018)
- Closing Your Examination, Tax Executive, July/August 2020
- The IRS’s Assault on Section 199 (Computer Software) Doesn’t Compute, Bloomberg BNA Daily Tax Report, April 24, 2017
- The New LB&I: Recent IRS Reorganization Raises Panoply of Significant Issues, Tax Executive, February 23, 2016