Mary E. Monahan

Mary E. Monahan: Attorney with Eversheds Sutherland (US) LLP
  • Partner at Eversheds Sutherland (US) LLP
  • 700 Sixth Street NW, Suite 700, Washington, DC 20001-3980
    View Mary E. Monahan's office location
  • Mary Monahan
  • Peer Reviews

    No Reviews
  • Profile Visibility [ i ]
    • #947 in weekly profile views out of 55,144 Attorneys in Washington, DC
    • #42,536 in weekly profile views out of 1,822,458 total attorneys Overall

Biography

Mary Monahan represents insurance companies and other corporations in audits, litigation and appeals involving the IRS. Mary represents taxpayers before IRS Exam and Appeals and participates in litigation in multiple federal forums, including the US Tax Court, the US Court of Federal Claims, district courts, courts of appeal and the US Supreme Court.

Drawing on 20 years’ experience litigating complex and technical federal tax issues, Mary advises multinational corporations with respect to a wide range of tax matters, including international tax and tax planning for corporate acquisitions and restructurings (focusing particularly on tax accounting and income recognition issues), permanent establishment issues, insurance company issues, interest matters, information reporting and withholding matters, employment tax matters and eligibility for the research tax credit.

Selected Experience

Secured partial summary judgment in research tax credit case.
Represented a Fortune 100 insurance company in a case involving two questions of first impression.
Represented GE in litigation in the U.S. Court of Federal Claims.

Awards and Rankings

Dean’s fellow, George Washington University National Law Center

Winner, Tenth Annual Student Writing Contest of the American College of Tax Counsel (1991)

News

In the News

Insurers Get More R&D Tax Benefits as IRS Softens Stance (June 3, 2016)
Bloomberg BNA - Daily Tax Report
Sutherland Partner Mary Monahan is quoted in this Bloomberg BNA article regarding the Internal Revenue Service taking a softer stance on insurance companies that are conducting research and ...

Treasury Delays Embedded Loan Rule Change by More Than a Year (October 13, 2015)
Tax Notes Today
Partner Mary Monahan is quoted in a Tax Notes Today article regarding the U.S. Department of the Treasury changing the effective date with its embedded loan rule change by more than a year. Regarding ...

2016 Budget Tax Proposals Target Insurance Companies (March/April 2015)
FC&S Legal
Sutherland’s legal alert, “FY 2016 Budget Tax Proposals Target Insurance Companies,” is featured in FC&S Legal.

2014 Federal Tax Litigation in Review (December 19, 2014)
Law360
Partner Mary Monahan is quoted in a Law360 article regarding a U.S. Court of Appeals for the Eleventh Circuit decision in United States v. Clarke, which ruled that taxpayers are allowed to examine ...

Weekly Tax Roundup (October 3, 2014)
TaxProf Blog
Sutherland’s legal alert, “The Tax Court Approves the Use of Predictive Coding,” is featured in the TaxProf Blog, “Weekly Tax Roundup.”

The Tax Court Approves the Use of Predictive Coding (September 29, 2014)
AboveTheLaw.com
Sutherland’s legal alert, “The Tax Court Approves the Use of Predictive Coding,” was featured in AboveTheLaw.com.

Substantiation in a Cloud Environment (October 22, 2013)
Tax Notes
In the latest Tax Matters column for Tax Notes, “Substantiation in a Cloud Environment,” Sutherland Partners Karl Zeswitz and Mary Monahan analyze cloud computing and software as a service, IRS ...

Press Releases

Sutherland Publishes New Column with Tax Analysts (September 30, 2013)
WASHINGTON DC, September 30, 2013 -Sutherland Asbill & Brennan LLP today announced the launch of a new regular column, Sutherland: Tax Matters published by Tax Analysts, the nonprofit provider of ...

Publications

“It’s important to focus on the overall picture as well as the technical tax provisions.”

Legal Alerts

Legal Alert: The season of giving - proposed regulations ease FATCA reporting burdens (December 20, 2018)
On December 13, 2018, proposed regulations (Proposed Regulations) were issued that reduce certain compliance obligations under Sections 1471-1474 (the Foreign Account Tax Compliance Act (FATCA)) of ...

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: 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 and Treasury issue proposed regulations on discounting unpaid losses (November 15, 2018)
On November 6, 2018, the Internal Revenue Service (IRS) and the Treasury Department (Treasury) issued proposed regulations that address amendments to the rules for discounting unpaid losses under ...

Legal Alert: Deemed participation better than no participation? Proposed regulations expand tax-free treatment to section 956 inclusions of certain shareholders (November 6, 2018)
On October 31, 2018, the Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) issued proposed regulations (Proposed Regulations) modifying the application of section 956 of ...

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: IRS provides IRC 817(h) diversification guidance on a new form of mortgage-backed security to be issued by Fannie Mae and Freddie Mac (October 24, 2018)
On October 16, 2018, the Internal Revenue Service (IRS) released Rev. Proc. 2018-54,1 which addresses the treatment of a new mortgage-backed security under the diversification rules of IRC 817(h). ...

Legal Alert: IRS issues key audit directive for life insurers (September 13, 2018)
The Internal Revenue Service (IRS) Large Business and International (LB&I) division recently released an Industry Director’s Directive (IDD) that provides key guidance for life insurers.1 The IDD is ...

Legal Alert: Results-disoriented-Ninth Circuit withdraws its Altera decision (August 8, 2018)
On August 7, 2018, the US Court of Appeals for the Ninth Circuit withdrew its opinion in Altera Corporation v. Commissioner, just 15 days after the initial release of the opinion. The court in Altera ...

Legal Alert: Share and share alike-the Ninth Circuit upholds regulations on stock-based compensation costs in cost-sharing arrangements (August 1, 2018)
On July 24, 2018, the US Court of Appeals for the Ninth Circuit in Altera Corporation v. Commissioner overturned a unanimous decision by the Tax Court invalidating Treas. Reg. 1.482-7A(d)(2), which ...

Articles

Are You An Inadvertent US Shareholder In A Foreign Corp? (October 19, 2018)
Law360
Prior to the Tax Cuts and Jobs Act, US companies typically structured their minority investments in non-US corporations to limit the risk that the controlled foreign corporation, or CFC, rules would ...

A Federal Tax Perspective On Judge Kavanaugh (July 16, 2018)
Law360
Judge Brett Kavanaugh’s nomination to the US Supreme Court has prompted a collective deep dive into his nearly 300 opinions for the US Court of Appeals for the District of Columbia Circuit, in search ...

Anti-Inversion Rule Down, But Not Out, With Texas Ruling (October 17, 2017)
Law360
A Texas federal court recently struck down the temporary anti-inversion regulation issued under Section 7874, which has been charged with preventing the planned merger between two US corporations as ...

Tax Court Reverses Course After ‘BMC Software’ Win in Fifth Circuit: Rev. Proc. 99-32 Accounts Receivable Do Not Constitute Related-Party Indebtedness for Purposes of 965 (April 2017)
Bloomberg BNA - Tax Management International Journal and Tax Management Memorandum
In their article for Bloomberg BNA, Eversheds Sutherland (US) attorneys Mary Monahan, Daniel Nicholas and Krystal McKay analyze the United States Tax Court’s opinion in Analog Devices, Inc. v. ...

Tax Court Holds Rev. Proc. 99-32 Accounts Receivable Constitute Related-Party Indebtedness for Purposes Of 965 (December 13, 2013)
Tax Management International Journal
The United States Tax Court concluded that the taxpayer’s accounts receivable in BMC Software Inc. v. Commissioner, established between itself and its controlled foreign corporation pursuant to Rev. ...

Schedule UTP: Another Taxpayer Transparency Requirement (Winter 2010)
Partnering Perspectives

Tax Bites Investment Advice (Summer 2005)
Reprinted with permission from 24 ABA Tax Section News Quarterly 24

New IRS ‘TEAM’ Initiative Could Prove Helpful to Some Taxpayers (April 28, 2003)
Reprinted with permission from 99 Tax Notes 545

Maximizing Opportunities Under the New Research and Experimentation Regulations (1995)
Reprinted with permission from 47 Tax Executive 102

Unfair Competition or Fundraising?: A Proposal to Modify the Regularly Carried on Test of the Unrelated Business Income Tax (1992)
Reprinted with permission from 10 American Journal of Tax Policy 73

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 ...

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

Presentations

“We focus on the client’s business and their overall objectives.”

Presentations

The Importance of Procedure: Understanding Altera and the Significance of Transfer Pricing Litigation to Current and Future U.S. Tax Regulation (April 18, 2019)
TEI Detroit International Tax Day
Eversheds Sutherland (US) Partners Susan Seabrook and Mary Monahan present The Importance of Procedure: Understanding Altera and the Significance of Transfer Pricing Litigation to Current and Future ...

Global Controversy Update: Significant Cross Border Controversy Matters in the US and Europe and Implications for US Multinationals (April 18, 2019)
TEI Detroit International Tax Day
Eversheds Sutherland (US) Partners Susan Seabrook and Mary Monahan present Global Controversy Update: Significant Cross Border Controversy Matters in the US and Europe and Implications for US ...

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 ...

Eversheds Sutherland Seattle CPE Day - Navigating the Changing World of Tax (November 6-7, 2018)
Eversheds Sutherland (US) attorneys present at the Eversheds Sutherland Seattle CPE Day - Navigating the Changing World of Tax on November 6-7, 2018, in Seattle, Washington. Presentations can be ...

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 ...

Property and Casualty Insurance Issues (June 2, 2016)
Federal Bar Association's 28th Annual Insurance Tax Seminar
Sutherland Partner Mary Monahan presents Property and Casualty Insurance Issues at the Federal Bar Association's 28th Annual Insurance Tax Seminar on June 2, 2016, in Washington, DC.

Organizational and Operational Changes at the IRS - Seems that Everything Old is New Again (November 19, 2015)
TEI Baltimore-Washington Chapter Meeting
Sutherland attorneys Ellen McElroy, Mary Monahan and Kendall Jones present “Organizational and Operational Changes at the IRS - Seems that Everything Old is New Again” at the TEI Baltimore-Washington ...

Does Closing a Window Open Pandora’s Box? (November 19, 2015)
TEI Baltimore-Washington Chapter Meeting
Sutherland attorneys Ellen McElroy, Mary Monahan and Kendall Jones present “Does Closing a Window Open Pandora’s Box?” at the TEI Baltimore-Washington Chapter Meeting in Bethesda, Maryland on ...

Repair Regulations - What’s Next? (November 19, 2015)
TEI Baltimore-Washington Chapter Meeting
Sutherland attorneys Ellen McElroy, Mary Monahan and Kendall Jones present “Repair Regulations - What’s Next?” at the TEI Baltimore-Washington Chapter Meeting in Bethesda, Maryland on November 19.

IRS Changes to Uncertain Tax Position Reporting Webinar (October 5, 2010)
Tax Education Series
Sutherland attorneys Shelly Kay, Danny McKeithen and Mary Monahan are speaking at the Tax Education Series: IRS Changes to Uncertain Tax Position Reporting Webinar on Tuesday, October 5, 2010, at ...

Areas of Practice (7)

  • Tax
  • Tax Controversy & Litigation
  • International Tax
  • Insurance Taxation
  • Appellate
  • Insurance
  • Federal Tax

Education & Credentials

Contact Information:
202.383.0641  Phone
www.eversheds-sutherland.com
University Attended:
Georgetown University, A.B., cum laude
Law School Attended:
George Washington University National Law Center, J.D., with high honors, Articles Editor, George Washington Law Review, Order of the Coif
Year of First Admission:
1991
Admission:
1991, Maryland; 1992, District of Columbia
Memberships:

Professional Activities
Barrister member, J. Edgar Murdock American Inn of Court

ISLN:
901395977

Peer Reviews

This lawyer does not have peer reviews.

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

Documents (36)

Documents by this lawyer on Martindale.com

Washington, District of Columbia

Contact Mary E. Monahan

Required Fields

Required Fields


By clicking on the "Submit" button, you agree to the Terms of Use, Supplemental Terms and Privacy Policy. You also consent to be contacted at the phone number you provided, including by autodials, text messages and/or pre-recorded calls, from Martindale and its affiliates and from or on behalf of attorneys you request or contact through this site. Consent is not a condition of purchase.

You should not send any sensitive or confidential information through this site. Emails sent through this site do not create an attorney-client relationship and may not be treated as privileged or confidential. The lawyer or law firm you are contacting is not required to, and may choose not to, accept you as a client. The Internet is not necessarily secure and emails sent though this site could be intercepted or read by third parties.