Roseann M. Cutrone
U.S. Taxation of Intellectual Property Transactions and Research and Experimentation Tax Credit
Roseann M. Cutrone’s practice involves controversy, planning, policy and legislative work focusing on a variety of issues, including the U.S. tax treatment of intellectual property (IP) transactions. In particular, she has considerable experience advising clients in the area of joint venture IP licensing transactions and in the area of the R&E tax credit, including the representation of numerous clients in making R&E credit claims, as well as defending such claims at the audit and appeals stages before the Internal Revenue Service.
In addition, Ms. Cutrone counsels clients on the various U.S. and international information reporting and withholding requirements. She has experience undertaking compliance reviews and remediation efforts and in setting up best practices procedures. She recently has been named to the international reporting and withholding subgroup of the Information Reporting Program Advisory Committee (IRPAC), a federal advisory committee that provides a forum for discussion of tax administration issues with the IRS.
Ms. Cutrone has co-authored several articles, including two published in Tax Notes, one on tax deferral and one on the export source rule.
J.D., Harvard Law School, 1986 (cum laude)
B.A., Bucknell University, 1983 (summa cum laude)
Lecturer for Tax Executives Institute