Ellen McElroy

Ellen McElroy: Attorney with Eversheds Sutherland (US) LLP
  • Partner at Eversheds Sutherland (US) LLP (436 Attorneys)
  • 700 Sixth Street NW, Suite 700, Washington, DC 20001-3980
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Biography

Ellen has more than 25 years of experience advising clients on federal tax matters for businesses, primarily tax accounting concerns, accounting method considerations, and compliance and reporting issues. She regularly counsels clients on the proper tax treatment of costs associated with tangible property (including the treatment of repair costs), intangible property (including acquisition costs and recovery) and corporate transaction costs.

Ellen regularly represents clients before the Internal Revenue Service (IRS), including representation at the IRS National Office with private letter rulings and technical advice. She also represents a number of clients in controversy matters before the Examination and Appeals divisions, including matters involving Pre-Filing Agreements, Fast Track Appeals and the Compliance Audit Program.

Prior to entering private practice, Ellen led the transaction cost review practice for a Big Four accounting firm, where she worked on accounting methods and inventory matters for Fortune 500 companies. She also worked for the IRS Office of Chief Counsel where, over an eight-year government career, she developed and drafted legislative and regulatory proposals, supervised congressional investigations and administered Government Accountability Office audits involving the IRS.

An adjunct professor at Georgetown University Law Center, Ellen taught courses in tax accounting for several years. She frequently speaks before Tax Executives Institute (TEI) and federal and state bar groups on topics such as capitalization, inventory and accounting methods, and tax developments affecting health care organizations.

Client Tools

•Opportunity Zones

Awards and Rankings

Recognized by The Legal 500 United States in the area of U.S. taxes: non-contentious (2016)

Publications

Legal Alerts

Legal Alert: Miracle on Constitution Avenue-IRS releases anticipated method change guidance regarding new income recognition standards under section 451(b) (December 10, 2018)
On November 29, 2018, the Internal Revenue Service (IRS) issued Rev. Proc. 2018-60, which provides automatic accounting method change procedures for taxpayers seeking to comply with section 451(b), ...

Legal Alert: Proposed 163(j) regulations provide needed guidance to utilities (December 7, 2018)
On November 26, 2018, the Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) issued much-anticipated proposed regulations (Proposed Regulations) under section 163(j) of the ...

Legal Alert: IRS and Treasury issue final regulations on negative adjustments under UNICAP (December 5, 2018)
On November 19, 2018, the Internal Revenue Service (IRS) and the Treasury Department (Treasury) issued final regulations (T.D. 9843) that address taxpayers’ use of negative amounts in calculating ...

Legal Alert: House bill proposes tax credit extensions for renewable energy, biodiesel and alternative fuels and other energy tax provisions (November 30, 2018)
On November 26, the House of Representatives released a tax bill (Extenders Bill) that, if enacted, would extend certain tax credits for the renewable energy and alternative fuels industries and ...

Legal Alert: IRS tells utility not to count its (deferred tax) chickens before they hatch (October 24, 2018)
The affiliated group of which a taxpayer-utility was a wholly owned subsidiary filed tax returns on which it did not claim bonus depreciation since the availability of bonus depreciation had ...

Legal Alert: What you need to know about investing in opportunity zones (October 24, 2018)
As part of the Tax Cuts and Jobs Act of 2017, Congress enacted sections 1400Z-1 and 1400Z-2 of the Internal Revenue Code, which were intended to promote investments in low-income communities ...

Legal Alert: Having your business meal and deducting it too-IRS issues guidance on the deductibility of business meals (October 4, 2018)
On October 3, the Internal Revenue Service (IRS) issued Notice 2018-76 (the Notice) to address the deductibility of business meals under section 274(a) of the Internal Revenue Code. The Tax Cuts and ...

Legal Alert: The more things change the more things remain the same-temporary guidance regarding bonus depreciation rules under section 168(k) (August 8, 2018)
Last year, the federal government enacted the most substantial tax reform legislation since 1986 in Public Law 115-97, commonly referred to as the Tax Cuts and Jobs Act of 2017 (TCJA). Of the many ...

Legal Alert: IRS appears to walk back disregard of certain accounting method changes in proposed section 965 regulations-does it make a difference? (August 6, 2018)
On August 1, 2018, the Department of Treasury and the Internal Revenue Service (IRS) issued proposed regulations implementing section 965 of the Internal Revenue Code (Code) (referred to as the ...

Legal Alert: Think twice before deducting success-based fees-new Chief Counsel Advice denies deduction of success-based fee due to lack of documentation (August 1, 2018)
On June 21, 2018, the Internal Revenue Service (IRS) issued Chief Counsel Advice (CCA) 2018-30-011, which disallowed a taxpayer’s deduction of a portion of a success-based fee incurred in a corporate ...

Articles

Unpacking The New Temporary Rules For Bonus Depreciation (September 12, 2018)
Law360
Last year, the federal government enacted the most substantial tax reform legislation since 1986, commonly referred to as the Tax Cuts and Jobs Act of 2017. Of the many business-friendly changes, the ...

Heads IRS Wins, Tails Taxpayers Lose In Section 965 Notice (July 2, 2018)
Law360
In their article for Law360, Eversheds Sutherland attorneys Ellen McElroy, Michael Resnick and Danielle Lowe breakdown the US Department of the Treasury and the Internal Revenue Service recently ...

Tax Planning in the Age of Tax Reform: Part 3 (March 16, 2018)
Law360
The Tax Cuts and Jobs Act (TCJA) presents both challenges and opportunities. Companies face immediate hurdles implementing the law without administrative guidance. But the combination of expiring ...

Tax Planning in the Age of Tax Reform: Part 2 (March 15, 2018)
Law360
The Tax Cuts and Jobs Act (TCJA) presents both challenges and opportunities. Companies face immediate hurdles implementing the law without administrative guidance. But the combination of expiring ...

Tax Planning in the Age of Tax Reform: Part 1 (March 14, 2018)
Law360
The Tax Cuts and Jobs Act (TCJA) presents both challenges and opportunities. Companies face immediate hurdles implementing the law without administrative guidance. But the combination of expiring ...

IRS Again Lends a Hand in Navigating the Murky Waters of Bonus Depreciation (May 11, 2017)
AccountingWEB
In a new private letter ruling (PLR 201709007), the IRS gave a company additional time to claim bonus depreciation, which allows a business to take an immediate first-year deduction of 50 percent on ...

Construction is Complete on Much of the Repair Regulations (September 26, 2013)
BNA Tax and Accounting Center

Does a Target or Acquiring Corporation Claim Significant Transaction Related Deductions? IRS Wades into Murky Waters (April 22, 2013)
BNA Tax Management Memorandum, Vol. 54, No. 8

Newsletters

Eversheds Sutherland Global Tax Brief (December 2017)
The Eversheds Sutherland Global Tax Brief is a collection of tax developments from our attorneys across the globe. We hope you enjoy this issue of the Brief and look forward to sharing more updates ...

Eversheds Sutherland Global Tax Brief (May 2017)
The Eversheds Sutherland Global Tax Brief is a collection of tax developments from our attorneys across the globe. We hope you enjoy this issue of the Brief and look forward to sharing more updates ...

Presentations

Bonus Depreciation After the TCJA - Legal and Practical Considerations (April 1, 2019)
2019 TEI Mid-Year
Eversheds Sutherland (US) Partner Ellen McElroy presents Bonus Depreciation After the TCJA - Legal and Practical Considerations at the 2019 TEI Mid-Year on April 1, 2019, in Washington, DC.

Eversheds Sutherland Year-End Tax Seminar - Navigating the Changing World of Tax (November 14, 2018)
Eversheds Sutherland (US) attorneys present at the Eversheds Sutherland Year-End Tax Seminar - Navigating the Changing World of Tax on November 14, 2018, in Philadelphia, Pennsylvania. Presentations ...

FBA Presentation on Proposed Bonus Depreciation Regulations under Section 168(k) (August 21, 2018)
Join lawyers from Eversheds Sutherland and the IRS and Treasury staff responsible for the recently released guidance on bonus depreciation rules under section 168(k). The discussion will include a ...

Federal Tax Day (June 26, 2018)
Tax Executives Institute (TEI)
Eversheds Sutherland (US) Partners Randy Buchanan, Robb Chase, Ellen McElroy and Aaron Payne present “FDII Sense” and “Practical Impacts of the TCJA on Existing Domestic Operations” at TEI Silicon ...

2018 TEI Region II Tax Forum (June 4-5, 2018)
Eversheds Sutherland is a proud co-sponsor of the 2018 TEI Region II Tax Forum taking place June 4-5, 2018, at the Borgata Hotel in Atlantic City, New Jersey. The Tax Forum will include four plenary ...

Tax Executives Institute (TEI) 68th Midyear Conference (March 25-28, 2018)
Eversheds Sutherland is a proud Platinum Sponsor of the Tax Executives Institute (TEI) 68th Midyear Conference on March 25-28, 2018, in Washington, DC. The conference is held at the Grand Hyatt ...

Tax Accounting and Accounting Method Issues Affected by Tax Reform (March 9, 2018)
Federal Bar Association
Eversheds Sutherland (US) Partner Ellen McElroy moderates, “Tax Accounting and Accounting Method Issues Affected by Tax Reform,” at the Federal Bar Association 42nd Annual Tax Law Conference on March ...

March Madness: Accounting Methods after Tax Reform and ASC 606 (February 28, 2018)
Tax Executives Institute (TEI) Nashville Chapter
Eversheds Sutherland (US) Partner Ellen McElroy presents, “March Madness: Accounting Methods after Tax Reform and ASC 606,” at the TEI Nashville Chapter Meeting on February 28, 2018, in Nashville, ...

Eversheds Sutherland Year-End Tax Seminar (November 10, 2017)
Eversheds Sutherland hosts and leads a Year-End Tax Seminar on November 10, 2017, in Malvern, Pennsylvania. Topics include: “The ‘Avrahami’ Case and Its Potential Impact on Non-Micro ...

Revenue Recognition (November 8, 2017)
Tax Executives Institute (TEI)
Eversheds Sutherland (US) Partner Ellen McElroy presents, “Revenue Recognition,” at the New Orleans Chapter Federal Tax Seminar on November 8, 2017, in New Orleans, Louisiana.

News

In the News

199A Planning Focus Shifts to Business Separation (February 12, 2019)
Tax Notes
Eversheds Sutherland Partner Ellen McElroy is quoted in this Tax Notes article discussing the IRS and Treasury’s recently released final rules (T.D. 9487) and how practitioners are now focused ...

JCT Opposes Revenue Recognition Cost of Goods Sold Offset Proposal (January 18, 2019)
Tax Notes
Eversheds Sutherland Partner Ellen McElroy is quoted in this Tax Notes article discussing the Joint Committee on Taxation’s recent interpretation of section 451. Ellen said the continuing import of ...

Manufacturers Need Interest Cap Depreciation Rule Resolved (October 30, 2018)
Tax Notes
Eversheds Sutherland Partner Ellen McElroy is quoted in this Tax Notes article discussing the interest cap rule in Section 163(j) that is causing significant difficulties for certain businesses. ...

TCJA Triggers Removal of Advance Payment Income Deferral Rule (October 15, 2018)
Tax Notes
Eversheds Sutherland Partner Ellen McElroy is quoted in this Tax Notes article discussing the modification of section 451 income inclusion rules, including the removal of regulations previously ...

IRS Advice Denying Success-Based Fee Deduction Causes Concern (August 27, 2018)
Tax Notes
Eversheds Sutherland Partner Ellen McElroy is quoted in this Tax Notes article discussing recent Internal Revenue Service (IRS) advice that an allocation letter and slide presentation that did not ...

Regulators Anticipate Legislative Changes to Bonus Depreciation (August 22, 2018)
Tax Notes
Eversheds Sutherland Partners Ellen McElroy and Bradley Seltzer are quoted in this Tax Notes article discussing the anticipated legislative changes to the proposed bonus depreciation regulations ...

GOP Taxwriters Ask Treasury to Accommodate Three Technical Corrections (August 20, 2018)
Tax Notes
Eversheds Sutherland Partner Ellen McElroy is quoted in this Tax Notes article discussing a letter sent to Treasury by the Senate Finance Committee Republicans urging it to consider congressional ...

Proposed Bonus Depreciation Regulations Contain Few Surprises (August 7, 2018)
Tax Notes
Eversheds Sutherland Partner Ellen McElroy is quoted in this Tax Notes article discussing her surprise that the preamble to the proposed bonus depreciation regulations did not directly address the ...

Tax Reform Adds Value to IRS Accounting Method Changes (June 19, 2018)
Law360
Eversheds Sutherland's legal alert “IRS Releases Updated Automatic Changes in Methods of Accounting List” was republished by Law360.

IRS Exploring Self-Constructed Asset Interest Capitalization (May 22, 2018)
Tax Notes
Eversheds Sutherland Partner Ellen McElroy is quoted in this Tax Notes article discussing the complex rules for self-constructed assets and the recent campaign launched by the Internal Revenue ...

Press Releases

16 Sutherland Practice Areas, 59 Attorneys Named Among Nation’s Best in 2016 Legal 500 United States (June 16, 2016)
ATLANTA and WASHINGTON-Sutherland Asbill & Brennan LLP is pleased to announce that 16 practice areas and 59 attorneys have been ranked in the 2016 edition of The Legal 500 United States. Legal 500 is ...

Sutherland Expands Tax Practice with Addition of Ellen McElroy (April 8, 2015)
WASHINGTON-Sutherland Asbill & Brennan LLP announced today that Ellen McElroy has joined the firm’s Tax Practice Group as a partner in Washington, DC, expanding the firm’s tax accounting services. ...

Multimedia

Videocast: Implications of tax reform on income recognition (April 2, 2018)
The changes made to the Internal Revenue Code by the Tax Cuts and Jobs Act (TCJA) included a number of modifications to the rules associated with income recognition. Although the TCJA codified ...

Videocast: Tax Planning in the Age of Tax Reform: Procedural Options Under Review - Best Practices for Avoiding or Minimizing Controversy (March 6, 2018)
In light of the major changes to the Internal Revenue Code (the Code) resulting from the recent enactment of the Tax Cuts and Jobs Act (TCJA), now more than ever, companies have the opportunity to ...

Videocast: Methods of Accounting: Transaction Costs (June 24, 2015)
In this Bottom Line videocast, Sutherland attorneys Ellen McElroy and Michael Resnick conclude their videocast series on tax accounting with an overview on transactions costs:What is the ...

Videocast: Methods of Accounting: Tangible Property Regulations (June 17, 2015)
In this Bottom Line videocast, Sutherland attorneys Ellen McElroy and Michael Resnick continue their videocast series on tax accounting with an overview on the new tangible property ...

Videocast: Methods of Accounting: New Procedural Guidance for Changes in Methods of Accounting (June 10, 2015)
In this Bottom Line videocast, Sutherland attorneys Ellen McElroy and Michael Resnick continue their videocast series on tax accounting with an overview on new procedural guidance for changes in ...

Videocast: Methods of Accounting: Changes in Methods of Accounting (June 3, 2015)
In this Bottom Line videocast, Sutherland attorneys Ellen McElroy and Michael Resnick continue their series on tax accounting with an overview on changes in methods of accounting:What is a ...

Videocast: Methods of Accounting: A Brief Overview (May 27, 2015)
In this Bottom Line videocast, Sutherland attorneys Ellen McElroy and Michael Resnick launch their series on tax accounting with an overview on methods of accounting:What “is” and “is not” a ...

Areas of Practice (2)

  • Tax
  • Federal Tax

Education & Credentials

Contact Information:
202.383.0948  Phone
www.eversheds-sutherland.com
University Attended:
Emory University, B.B.A.
Law School Attended:
University of Denver College of Law, J.D., General Editor, Law Review; Georgetown University Law Center, LL.M.
Year of First Admission:
1988
Admission:
1988, Colorado; 2008, District of Columbia
Memberships:

Professional Activities

Member, American Bar Association
Income Tax & Accounting Chair, Federal Bar Association, Section on Taxation Tax Law Conference
fellow, American College of Tax Counsel
Past Chair, American Bar Association, Tax Accounting Committee
Past Chair, American Bar Association, Capitalization Sub Committee

ISLN:
904990483

Peer Reviews

This lawyer does not have peer reviews.

*Peer Reviews provided before April 15, 2008 are not displayed.

Documents (32)

Documents by this lawyer on Martindale.com

Washington, District of Columbia

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