Marlene E. Laro

Marlene Laro is a Partner and Chief Operating Officer of the firm. As the COO of an alternative model law firm, Ms. Laro works to develop and support every aspect of the rapidly growing business. Ms. Laro is also a member of the firm’s Tax practice, advising companies on international and domestic restructurings and transactions, as well as providing clients with more general tax planning. Ms. Laro has worked with a broad range of clients, including international organizations, multinational and domestic corporations, educational institutions, LLCs, and high-net worth individuals. Ms. Laro possesses international expertise, having taught comparative tax law, provided technical assistance to foreign states on tax matters, and served as a frequent lecturer at international tax law conferences in Moscow, Russia.

REPRESENTATIVE EXPERIENCE

• Advised multinational corporations and high net-worth individuals on international tax planning, including issues regarding subpart F, PFIC, tax treaties, and foreign tax credits.
• Advised on domestic tax issues, including corporate transactions, structuring of tax-free and taxable transactions, LLCs and nonprofit corporations
• Counseled clients on tax litigation and tax controversy matters.
• Served as legal consultant to international organizations on tax policy and legal reform, including the International Monetary Fund, U.S. Russia Foundation, International Tax and Investment Center, AECOM International Development, and American Society of International Law.
• Drafted amendments to the corporate tax laws of CIS countries, and provided technical assistance to the Governments of Russia, Azerbaijan, Kazakhstan, and Georgia.

PREVIOUS EXPERIENCE

• Ivins, Phillips & Barker, Associate
• Dewey Ballantine LLP, Associate
• International Monetary Fund, Legal Consultant
• Georgetown University Law Center, Adjunct Professor

PRO BONO AND COMMUNITY INVOLVEMENT

• US Russia Foundation, Legal Adviser
• International Tax and Investment Center, Lecturer and Program Adviser

PUBLICATIONS AND SPEECHES

Speaking Engagements

• “Challenging the Law Firm Monopoly: New Entrants in the Market for Legal Services,” Thomson Reuters 13th Annual Law Firm COO & CFO Forum, NY, NY (October 2014).
• “Game Changers, Trends and Prophecies: Envisioning the Client of the Future,” Thomson Reuters/NYC Bar Association Conference, NY, NY (June 2014).
• “Beyond Big Law: A New Model Option for Entrepreneurial Lawyers,” Harvard Law School, Program on the Legal Profession (November 2013).
• “The Significance of Distinguishing a Tax and a Fee,” International Tax Conference, Moscow, Russia (April 2013).
• “Assessing the Authoritative Weight of Judicial Decisions in the United States,” International Tax Conference, Moscow, Russia (April 2012).
• “The Recovery of Taxpayer Costs Incurred in a Federal Tax Controversy,” International Conference on Tax Disputes: Experience of Russia and Other Countries, Moscow, Russia, (October 2011).
• “Three Judicial Doctrines Frequently Considered in the U.S. Tax Court: Presumption of Correctness, Res Judicata, and Collateral Estoppel,” International Tax Conference, Moscow, Russia (April 2010).
• “The Deductibility of Business Expenses,” International Conference of Tax Disputes: Experience of Russia and Other Countries, Moscow, Russia (November 2009).
• “The Burden of Proof in U.S. Tax Cases,” Tax Conference of The Supreme Commercial Court of the Russian Federation, Moscow, Russia (November 2009).

Publications

• “Taxpayer Actions for Damages and Recovery of Litigation Costs,” Nalogoved (January 2011).
• “The Role of Judicial Precedent in U.S. Tax Cases,” Taxes and Finance, 9(34) (September 2010).
• “The Judicial Doctrines of Res Judicata and Collateral Estoppel in Tax Cases,” Tax Disputes, No. 7 (2010).
• “Administrative Resolution of Tax Disputes in the U.S.,” Nalogoved, No. 3 (March 2010).
• “Deductibility of Business Expenses: Approaches in Russia and the U.S.,”Tax Notes International (May 11, 2009).

LANGUAGES

• Russian