Julia Ushakova-Stein
Biography
Julia is a partner in our Firm's North America Tax Practice Group and is based in our San Francisco office. She advises on US international tax planning (inbound and outbound) and controversy matters. She represents clients from a diverse set of geographic areas and industries, including in the technology, healthcare, and financial services sectors. She has represented a number of Fortune 500 companies in US federal income tax matters and has successfully represented clients in federal tax controversies at all levels.
Julia has a passion for resolving complex tax issues, with a practical approach that considers her client's business needs. Clients value Julia's ability to explain complex tax issues in an easy to digest manner and her dispute prevention and risk mitigation insight. Julia's creative approach and technical experience is particularly valuable during tax controversy matters.
Chambers has recognized Julia, with clients stating that she is "very professional and has strong technical skills," "extremely knowledgeable and thoughtful in her support of our company," "comes well prepared," and “provides a great service.” Clients appreciate that her "communication style is calm and clear."
Julia has been teaching international tax at UC Berkeley School of Law and in the Master’s Program at San José State University. Also, Julia has been an author of a monthly column in Tax Notes on international tax developments and regularly speaks at major tax conferences for professional tax groups, including for the International Fiscal Association, International Tax Review (ITR), Pacific Rim Tax Institute, and Euromoney. Julia is also the co-president of the Northern California region for the International Fiscal Association.
Practice Focus
Julia advises companies on US international tax planning matters (inbound and outbound) with a focus on dispute prevention and risk mitigation. Julia's extensive US international tax planning experience includes international restructurings and transfer pricing, including with respect to foreign tax credit, GILTI, subpart F, and sec. 965 matters.
Julia assists clients in the resolution of tax issues through competent authority and in obtaining Advance Pricing Agreements (APAs).
Julia represents companies at various stages of US federal tax controversies, including during IRS audit, appeals, and judicial proceedings.
Representative Legal Matters
Prior to joining the Firm, Julia handled the following matters:
- Represented Meta (fka Facebook) as special tax counsel in its USD 5.7 billion investment for a 9.99% stake in Jio Platforms, the biggest telecom operator in India and a subsidiary of multinational conglomerate Reliance Industries.
- Regularly advises multinational corporate groups with respect to US international tax planning matters, which have recently included issues relating to worthless losses, foreign minority investments, expense allocations, foreign tax creditability, GILTI, FDII, and sec. 965.
- Successfully settled numerous IRS Appeals matters, including with respect to transfer pricing matters.
- Reached a 100% client favorable resolution in IRS Competent Authority for a publicly traded corporation relating to a foreign adjustment.
- Acted as counsel in a successfully settled sec. 41 R&D tax credit case, Conversant et al. v. Commissioner, Tax Court Docket No. 030476-14 (2016), and was on the team that won Analog Devices, Inc. & Subsidiaries v. Commissioner, 147 T.C. No. 15 (2016).
Professional Honors
- Leading Lawyer in Tax in Northern California, Chambers USA, 2023 and 2024
- Tax Dispute Resolution Lawyer of the Year in 2021 and shortlisted in the Tax Lawyer of the Year category in 2022 and 2020 by International Tax Review at the Americas Women in Business Law Awards
- Rising Star for Tax by Law360, 2020
- Top 40 lawyers under 40 in the US, American Bar Association, 2018
- Appeared in Euromoney’s Expert Guides and International Tax Review’s Women in Tax Leaders
Professional Associations and Memberships
- International Fiscal Association (IFA) - Northern California Chapter Co-President
- American Bar Association Section of Taxation - Member
Admissions
- California~United States
- U.S. Tax Court~United States
Education
- University of California, Berkeley (JD)
- University of Arizona (BSBA Accounting, summa cum laude (International Business Certificate))
Languages
- English