Elizabeth Julia Smith

Elizabeth Julia Smith

Counsel, Tax; Tax Controversy and Litigation
Elizabeth Julia Smith represents clients in administrative tax disputes and litigation. She advises multinational corporations, private investment firms and individuals in connection with IRS and state audits and administrative proceedings, trial and appellate litigation in federal and state courts, and proceedings brought by non-U.S. taxing authorities.

Bio

Ms. Smith has represented clients in a variety of industries, including health care, energy, telecommunications, private investments, transportation and technology. Her experience encompasses a wide range of complex tax issues involving income, sales, self-employment, withholding and property taxes. In recognition of her work, she has been named to The Best Lawyers in America.

Ms. Smith’s representative matters prior to joining Skadden include:

  • obtaining a full IRS concession on a statute of limitations defense on behalf of a hedge fund client in U.S. Tax Court proceedings defending the statutory limited partner exception to self-employment (SECA) tax in the Internal Revenue Code, in Ivory Investment Management, LP v. Commissioner;
  • achieving a complete victory in two multimillion-dollar disputes over local taxes for a multinational energy company involving the definitions of manufacturing and machinery, one of which was argued before the Massachusetts Supreme Judicial Court, in Veolia Energy Boston, Inc. v. Board of Assessors of Boston;
  • advising a large data company in sales and income tax disputes with the Massachusetts Department of Revenue;
  • reaching a highly favorable settlement on behalf of a multinational utility company in connection with a state income tax dispute involving the addback of related party interest;
  • representing the purchaser of a company in litigation regarding its right to retain tax refunds and credits arising out of net operating loss carrybacks made possible by the CARES Act;
  • representing multiple private equity firms and hedge funds in disputes with the IRS involving the application of SECA tax to income received by limited partners;
  • advising several private equity firm portfolio companies in connection with IRS and state audits of management fees paid to sponsors;
  • obtaining a favorable settlement on behalf of individuals in a dispute with the Massachusetts Department of Revenue regarding responsible person liability;
  • counseling an individual in connection with a state court indemnification dispute arising out of a potential tax liability and related IRS audit;
  • advising multiple clients regarding state sales tax, income tax and procurement tax obligations in connection with actual and anticipated disputes with state regulators;
  • advising a private equity firm and its portfolio company in an internal investigation related to potential tax liabilities.

Ms. Smith is active in the Boston Bar Association, and serves as co-chair of the Federal Tax and Business Transactions Committee of the Tax section.

Prior to joining Skadden, Ms. Smith was a counsel in the tax controversy practice of another leading law firm.

Credentials

Education

  • J.D., Yale Law School, 2009
  • B.A., Bates College, 2003 (summa cum laude)

Admissions

  • Massachusetts
  • New York

Elizabeth Julia Smith

Counsel, Tax; Tax Controversy and Litigation
elizabeth.smith@skadden.com