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Morgan Lewis

Jennifer Breen

Partner

Washington, DC Phone +1.202.739.5577 Fax +1.202.739.3001

1111 Pennsylvania Ave. NW//Washington, DC 20004-2541//United States

Jennifer Breen concentrates her practice on tax controversy and planning matters, with an emphasis on audits and controversies and Internal Revenue Service (IRS) administrative proceedings. Jennifer routinely handles matters involving US federal income tax, foreign tax, state and local corporate and business tax, and sales and use tax. She has experience representing major corporations, partnerships, S corporations, and individuals in resolving domestic and international compliance and controversy issues before the IRS.

Prior to joining Morgan Lewis, Jennifer served as director of tax controversy at Mattel, Inc., where she developed and executed audit strategies, responded to information requests from respective tax authorities, and negotiated and resolved controversy matters. She was also responsible for accounting for income taxes under ASC 740, managing the company’s global reportable transaction compliance, and ensuring compliance under the Foreign Account Tax Compliance Act.

Jennifer also served as director of tax controversy and regulatory services at PricewaterhouseCoopers LLP for more than seven years. She began her legal career as a lawyer with the IRS Office of Chief Counsel in Washington, DC, where she represented the IRS before the US Tax Court and advised on issues relating to practice and procedure.

Awards and Affiliations

Recognized, Tax Law, Washington, DC, The Best Lawyers in America (2022)

Up-and-Coming, Tax, District of Columbia, Chambers USA (2021)

Ranked, Tax, District of Columbia, Chambers USA (2020) 

Recommended, Tax: US taxes: contentious, The Legal 500 US (2019, 2020) 

Emerging Women Leaders in Private Practice, DCA Live (2019)

Member, Practice Group of the Year, Tax, Law360 (2017)

Recommended, The Legal 500 US (2016)

Fellow, American College of Tax Counsel

Member, J. Edgar Murdock Inn of Court

Chair, Administrative Practice Committee, Section of Taxation, American Bar Association

IRS Special Act Award (2002–2005)

Director and Treasurer, Washington DC Center for Public Interest Tax Law

Admissions

  • District of Columbia
  • Texas
  • US Court of Appeals for the First Circuit
  • US Court of Federal Claims
  • US Tax Court

Education

  • University of Houston Law Center, 2001, J.D.
  • University of Texas at Austin, 1998, B.A., Political Science and Government

Sectors

Services

Regions

Events

5/25/2021 - The New Normal of IRS Virtual Appeals Conferences: Practical Tips and Best Practices
5/18/2021 - Track 4: Tax, AML, and Intellectual Property
11/12/2020 - Navigating the Next: Outlook 2021
6/17/2020 - Federal Tax Planning After the Impact of COVID-19 Webinar
6/16/2020 - US Tax Update: Legislation and Other Guidance and Controversies in a COVID-19 Environment
5/5/2020 -
2020 Advanced Topics in Hedge Fund Practices Conference
4/16/2020 - CARES Act – Tax Relief and Enhancing Liquidity for Employers During COVID-19
4/14/2020 - Retail Companies and COVID-19 Impact
4/1/2020 - Tax Developments Affecting Automotive and Mobility Companies
2/27/2020 - The Tax Executives Institute (TEI) Los Angeles Chapter: Tax Controversy Seminar
6/11/2019 - 2019 Morgan Lewis Advanced Topics in Hedge Fund Practices Conference: Manager and Investor Perspectives
2/7/2019 - Final Partnership Audit Rules, IRS Implementation, and Impact on Partnerships
6/28/2018 - A Closer Look: State Tax and Practical Implications of the US Supreme Court’s Decision in South Dakota v. Wayfair – Part II: Practical Implications for Retailers
6/26/2018 - A Closer Look: State Tax and Practical Implications of the US Supreme Court’s Decision in South Dakota v. Wayfair – Part I: Overview of Decision and State Tax Implications
3/20/2018 - Association of Corporate Counsel’s Corporate Law Forum: Navigating US Tax Reform—What You Need to Know
11/15/2017 - The Tax Executives Institute (TEI) Los Angeles Chapter: Full-Day International Tax Seminar
5/23/2017 - Understanding LB&I Campaigns: A Webinar Presented by the IRS Large Business & International Division
6/1/2016 - "Implementing the LB&I Division Reorganization and Enactment of the Streamlined Partnership Audit Rules: What Should Taxpayers be Thinking About Now?"
3/4/2016 - FBA’s 40th Annual Tax law Conference
1/14/2016 - The New Streamlined Partnership Procedures: Revenue Raiser or Not?
12/8/2015 - New Legislation Makes Sweeping Changes Affecting All Partnerships
9/30/2015 - A New Era of IRS Examinations – Doing More with Less?
6/23/2015 - D.C. Bar’s First Tax Academy Focuses on Business Entities

News

11/18/2020 - Former Government Officials Weigh In on What To Expect from Presidential Administration Shift
7/15/2020 - TEI Roundtable No. 29: The Evolving Dynamic in IRS Appeals, Tax Executive
7/13/2020 - IRS: For-Profit Providers Have to Pay Taxes on COVID-19 Relief Grants, Modern Healthcare
6/8/2020 - IRS May Want to Tweak Appeals Pilot Program if Reviving It, Law360
5/11/2020 - Coping with a Pandemic: Morgan Lewis's Jennifer Breen, Law360
4/29/2020 - Inside the Federal Response to the Coronavirus Pandemic, Accounting Today
4/13/2020 - IRS’s Ability to Quickly Process NOL Refunds Questioned, Tax Notes
4/10/2020 - IRS Opens the Floodgates on Tax Deadline Relief, Tax Notes
4/3/2020 - Desmond Lists Further Filing Relief Among Guidance Priorities, Tax Notes
3/23/2020 - AICPA Targets Specific Provisions in BEAT Regs, Tax Notes
3/13/2020 - 5 Ways Tax Pros Want IRS to Respond to COVID-19, Law360
3/13/2020 - Morgan Lewis Recommends IRS Coronavirus Responses, Tax Notes
2/12/2020 - 10 Podcast Recommendations For Tax Attorneys, Law360
9/16/2019 - Audits of Partnerships That Cease to Exist Could Have Odd Results, Tax Notes
4/22/2019 - Tax Court Considering Allowing Limited Appearances, Tax Notes
3/14/2019 - Morgan Lewis Partner Jennifer Breen Named Among Emerging Women Leaders by DCA Live
3/6/2019 - 4 Last-Minute Considerations for Partnership Representatives, Law360 Tax Authority
2/12/2019 - Shutdown Inflicted ‘Real Harm’ on Taxpayers, IRS Watchdog Says, The Wall Street Journal
2/4/2019 - It’s Not Too Early to Start Planning for the Next Shutdown, Tax Notes
1/30/2019 - Dealing With the IRS During the Shutdown? Keep the Receipts, Bloomberg Law Daily Tax Report
1/15/2019 - Scope of Final Partnership Audit Regs May Invite Lawsuits, Law360
1/14/2019 - Shutdown Cranking Up Anxiety, Uncertainty For Taxpayers, Law360
11/20/2018 - Tax Court Tries to Get Taxpayers Free Legal Help in IRS Disputes, Bloomberg Tax
3/27/2018 - Jennifer Breen Elected as a Fellow of the American College of Tax Counsel
1/13/2017 - Morgan Lewis Advises Denali Sourcing Services in Purchase by WNS (Holdings) Limited
11/7/2016 - LB&I Campaigns Including Goals And Justifications ‘Coming Soon’, Tax Analysts
9/14/2016 - Morgan Lewis Partner Testifies Before House Committee on Small Business
9/5/2016 - Practitioners Speculate LB&I Campaign Details May Come Soon, Tax Analysts
11/11/2015 - Changing Global Tax Laws: What You Need to Know

Publications

1/5/2021 - LawFlash: Spending Bill Revives Paycheck Protection Program for US Small Businesses
1/5/2021 (Updated 1/26/2021) - Spending Bill Revives Paycheck Protection Program for US Small Businesses
11/30/2020 - What to Expect from Federal Agency Leadership Changes, Law360
7/10/2020 - IRS FAQs Address Tax Treatment of CARES Act Relief Payments to Healthcare Providers
7/9/2020 - IRS Issues FAQs Addressing Taxation of CARES Act Provider Relief Fund Payments
5/7/2020 - CARES Act Relief Payments to For-Profit Medical Care Providers May Be Taxable on Receipt
5/6/2020 - Taxpayers Receiving PPP Loans: IRS Provides Important Guidance on Expense Deduction
4/20/2020 - Successfully Managing Retail Businesses During and After a Crisis
4/13/2020 - IRS Extends More Than 300 Tax Filing, Payment, and Other Deadlines
4/3/2020 - CARES Act Provides Important Relief for Retail & Hospitality Companies
3/27/2020 - $2 Trillion Stimulus Bill Brings Major Tax Changes
3/25/2020 - COVID-19: IRS Issues FAQs Addressing Filing and Payment Deadline Questions
3/22/2020 - Income Tax Deadline Update: IRS Extends Filing Deadline for 90 Days Due to COVID-19
3/19/2020 - Income Tax Deadline: IRS Provides 90-Day Relief for Taxpayers Due to COVID-19
11/12/2019 - Pro Bono Settlement Day: Give Back to Your Community and Gain Litigation Skills, After the Bar
8/12/2019 - IRS Self-Employment Campaign Heats Up, Tax Notes
6/5/2019 - Why Big Law Should Consider a Digital Declutter, Law.com
3/25/2019 - Digital Declutter: How to Live a Focused Life in a Noisy World
12/21/2018 - A Few of Their Favorite Things
10/2/2017 - Appeals Update: Exam’s Attendance and a Return to Face-to-Face Meetings
9/14/2017 - Hurricane Irma Client Alert: Tax Filing, Payment Deadlines Extended for Victims in Disaster Areas
9/1/2017 - Hurricane Harvey Client Alert: Tax Filing and Payment Deadlines Extended for Victims
April 2016 - Why Signing on the Dotted Line Is Harder Than It Seems: A Primer on Signature Authority, Taxes—The Tax Magazine
2/25/2016 - The Devil Is in the Details: The New ‘‘Streamlined’’ Partnership Procedures, BNA's Tax Management Real Estate Journal
11/2/2015 - New Legislation Makes Sweeping Changes Impacting All Partnerships
10/2/2015 - How To Bind Without Getting in One: Avoiding Controversy Over Signature Authority Issues, Tax Executives Institute