Ellen advises clients on a variety of federal tax matters that should be top of mind for businesses.
This primarily includes tax accounting concerns, accounting method and period considerations, including compliance and reporting issues. With more than 25 years of tax law experience, Ellen 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 advises clients on issues involving fixed assets, inventory and research credits.
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.
Latest Insights
- legal updatesTax Bytes: Week of April 6, 2026
- legal updatesNew revenue procedure offers flexibility for business interest limitation elections
- legal updatesTax Bytes: Week of March 2, 2026
Latest News
- Challenges and Considerations in the Administrative Guidance Process, March 4, 2026, Eversheds Sutherland Developments in Tax Administration, Controversy and Enforcement (ACE) Seminar
- Clearing the Fog: Making Sense of OB3’s Changes to Federal Tax Provisions and Available Administrative Guidance, November 6, 2025, Eversheds Sutherland and TEI Philadelphia Chapter Year-End Tax and Legal Seminar
- Hot Topics in Accounting Methods, October 27, 2025, TEI 80th Annual Conference
- Breaking down the One Big Beautiful Act and its key federal tax provisions, July 31, 2025, Eversheds Sutherland OB3 Webinar Series
- Section 163(j), June 2, 2025, TEI Region 2 Tax Forum
- What to Expect in the Current Administration, June 2, 2025, TEI Region 2 Tax Forum
- Methods Madness, May 12, 2025, TEI Nashville Chapter Spring Tax Seminar
- Legislative Developments, May 12, 2025, TEI Nashville Chapter Spring Tax Seminar
- Fed Tax Turmoil: A Discussion of Anticipated Areas of Controversy and Ways to Strengthen Your Tax Toolbox During Uncertain Times, April 30, 2025, Eversheds Sutherland Developments in Tax Administration, Controversy and Enforcement (ACE) Seminar
- Accounting Methods: Current Issues and Updates, March 17, 2025, TEI 75th Midyear Conference
- Repeal, Roll-Back, or Revision: How the Second Trump Administration Will Address the Corporate AMT, Section 174, and Other Business Tax Provisions, February 26, 2025, TEI Philadelphia Chapter Tax Seminar
- Post-Election Tax Policy Impacts and Important Recent Developments, February 19, 2025, ABA Midyear Tax Meeting
- Repeal, Roll-Back, or Revision: How the Second Trump Administration Will Address the Corporate AMT, Section 174, and Other Business Tax Provisions, February 5, 2025, Eversheds Sutherland Post-Election Webinar Series
- What’s on the horizon: A discussion of the tax implications of recent US and UK elections, February 4, 2025, Eversheds Sutherland webcast
- Should I Stay or Should I Go Now? What Taxpayers Can Expect in the First Year of the Second Trump Administration, January 22, 2025, Eversheds Sutherland Post-Election Webinar Series
- Tax Policy and the Election: Understanding the Practical Implications, November 20, 2024, Eversheds Sutherland webcast
- The Proposed CAMT Regulations and Other Developments from Washington, November 7, 2024, Eversheds Sutherland Philly Tax Day Year-End Seminar
- R&D in Uncertain Tax Times, November 4, 2024, 40th Annual TEI-SJSU High Tech Tax Institute
- The Complexities of Software Development and Section 174, October 28, 2024, TEI 79th Annual Conference
- CAMT 101: An Overview and Analysis of the CAMT Proposed Regulations and Implementation Considerations, September 25, 2024, Eversheds Sutherland US Tax Roundtable for Lloyd’s Members
- Primer on Employment Tax Controversy, May 14, 2024, TEI Nashville Chapter Spring Tax Seminar
- Uncertainty in the Future: Legislative and Regulatory Update, May 14, 2024, TEI Nashville Chapter Spring Tax Seminar
- Corporate Tax Legislative and Regulatory Update, November 2, 2023, Philly Tax Day
- Notice 2023 – 63 – Welcome Substantive Guidance to Taxpayers Seeking Clarification Regarding R&D Expenses, September 21, 2023
- Accounting Methods and Tax Accounting - Current Developments and Future Expectations for 174/41, 451, and Corporate Minimum Tax, May 17, 2023, TEI Nashville Spring Seminar
- Tax Accounting, May 5, 2023, ABA Tax Meeting
- Guess Who's Back, Back Again: An Overview and Analysis of the Inflation Reduction Act's New Corporate Minimum Tax, March 23, 2023, Federal/International Tax Day
- Transaction Costs Have Been Capitalized - Now What?, February 10, 2023, ABA Midyear Tax Meeting
- Guess Who’s Back, Back Again: An Overview and Analysis of the Inflation Reduction Act’s New Corporate Minimum Tax, November 16, 2022, Philly Tax Day
- Tax Accounting Issues In Mergers and Acquisitions, October 27, 2022, PLI
- The New Federal Corporate Alternative Minimum Tax, October 25, 2022, COST's 53rd Annual Meeting
- IRS Appeals - Reflections on Two Years of COVID, May 13, 2022, ABA 2022 May Tax Meeting
- A Pot of Gold or a Pot of Rules?, March 17, 2022, TEI Silicon Valley Federal Tax Days
- Current Developments, March 4, 2022, FBA Tax Law Conference
- Capital Recovery Leasing - What is Real Property, February 2, 2022, ABA Virtual 2022 Mid-Year Tax Meeting
- Resolving Uncertainty with IRS Administrative Procedures, November 18, 2021, TEI Northeastern Wisconsin Chapter
- Pencils Down and Looking Ahead: Accounting Methods Considerations, November 3, 2021, TEI Chicago
- What is Real Property? Developments involving Sections 1031 and 1033, ABA Tax Section, February 2, 2022
- Research Credit Developments in FAA 20214101F, 46th Annual FBA Tax Law Conference, March 7, 2022
- Addressing Risk from Uncertain Tax Positions, TEI MidYear Meeting, March 21, 2022
- Tax Accounting Issues: Methods, Periods and Hot Topics, April 25, 2022, 2022 Federal Tax Course Level I
- Tax Strategies for Corporate Acquisitions, Dispositions, Spin-Offs, Joint Ventures, Financings, Reorganizations & Restructurings, October 21, 2021
- Titan Up: An Accounting Methods Update to Maximize Your Return Filing Positions, September 28, 2021, TEI Nashville webcast series
- Climbing the Rocky Top to Infrastructure: A Legislative Update on the Uphill Challenge to Enact Both the Bipartisan Infrastructure Bill and Budget Reconciliation, September 28, 2021, TEI Nashville webcast series
- Accounting Method Changes to Consider for 2020, July 21, 2021, Back to Basics Accounting series
- Expense Recognition, July 19, 2021, Back to Basics Accounting series
- Income Recognition, July 15, 2021, Back to Basics Accounting series
- Accounting Methods & Periods, July 13, 2021, Back to Basics Accounting series
- Federal Legislative Developments, June 29, 2021, TEI
- The Fundamentals of Federal Income Tax Accounting, June 15, 2021, TEI Federal Tax Fundamentals
- The Made in America Tax Plan, One Month Later: Where do we stand and how to prepare for an ever-changing legislative environment, May 26, 2021, Eversheds Sutherland
- The Made in America Tax Plan Series, April 21, 22 and 28, 2021
- An Overview of the Legislation Highlighting Key Federal Tax Provisions, April 21, 2021, The Made in America Tax Plan series
- Federal Tax Considerations in M&A Transactions, March 18, 2021, TEI Silicon Valley
- Significant Developments in the Final TCJA Regulations, March 17, 2021, TEI Silicon Valley
- The Georgia Races have been decided; what does that mean for the Federal Tax Landscape?, January 14, 2021, Eversheds Sutherland January Outlook webcast series
- 2021 Tax Outlook Webcast series, January 5-15, 2021
- Penalty Deduction Provisions, June 1, 2020, Eversheds Sutherland
- Choose your own adventure – implementing bonus depreciation for qualified improvement property, April 27, 2020
- No stone left unturned – optimizing the federal tax provisions of the CARES Act, April 13, 2020
- Tax Accounting Revenue Recognition and Current Developments, March 5, 2020, FBA Tax Law Conference
- Impact of reforms on commercial transactions, November 21, 2019, Philly CPE Day
- Brexit and emerging trends in the EU, November 21, 2019, Philly CPE Day
- Methods to the Madness, October 30, 2019, TEI Philadelphia
- Tax Accounting Session, October 29, 2019, 30th Annual Philadelphia Tax Conference
- Tax Accounting Issues in Mergers and Acquisitions, October 17, 2019, PLI’s Tax Strategies for Corporate Acquisitions, Dispositions, Spin-Offs, Joint Ventures, Financings, Reorganizations & Restructurings 2019
- The challenges and considerations of applying the Opportunity Zone provisions, June 19, 2019, FBA Breakfast hosted by Eversheds Sutherland
- TCJA One-Year Later: Addressing Federal Tax Issues with Minimal Guidance, May 14, 2019, Nashville TEI Spring Seminar
- International Tax Accounting Items, May 10, 2019, ABA May Tax Meeting
- Tax Accounting Issues: Methods, Periods and Hot Topics, April 23, 2019, 2019 Federal Tax Course Level I
- Bonus Depreciation After the TCJA – Legal and Practical Considerations, April 1, 2019, 2019 TEI Mid-Year
- Recognized by The Legal 500 United States in the area of U.S. taxes: non-contentious (2016, 2024-2025)
- Council Director, American Bar Association Tax Section, Council (2024-2027)
- Member, American Bar Association; DC Bar Association; Colorado Bar Association
- Income Tax & Accounting Chair, Federal Bar Association, Section on Taxation Tax Law Conference
- Fellow, American College of Tax Counsel
- Nominating Committee, Committee on Government Submissions, American Bar Association Tax Section
- Past Chair, American Bar Association Tax Section, Tax Accounting Committee
- Past Chair, American Bar Association Tax Section, Capitalization Subcommittee
- Colorado
- District of Columbia
- LL.M., Georgetown University Law Center
- J.D., University of Denver College of Law,
General Editor, Law Review
- B.B.A., Emory University