15+ years of experience advising corporate clients on inbound and outbound U.S. taxation
Has served as interim VP of tax for growing international technology company
Washington, D.C.
@alvarezmarsal
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Kristina Reynolds is a Managing Director with Alvarez & Marsal Tax in Washington, D.C., advising corporate clients on both inbound and outbound international tax matters.
Ms. Reynolds has served clients across such industries as financial services, energy, manufacturing and real estate. Her experience includes international restructuring, annual reporting, acquisition and disposition planning.
Prior to joining A&M, she spent nearly six years in public accounting. Most recently, she was a manager with the international tax services group of Deloitte Tax. Previously, she was with the corporate tax practice of Arthur Andersen in Washington, D.C.
Ms. Reynolds earned a bachelor's degree in accounting from Salisbury State University and a master's degree in accounting, with a concentration in taxation, from the George Washington University. She is a Certified Public Accountant (CPA) in Maryland and Virginia, and a member of the American Institute of Certified Public Accountants and the Maryland Association of Certified Public Accounts.
On November 9, 2023, in a seemingly endless effort to address a daunting responsibility delegated to them back in 1986, Treasury and the IRS released a new set of proposed regulations (REG-132422-17) for determining taxable income or loss and foreign currency gain or loss with respect to a “qualified business unit” (QBU) with a different functional currency (FC) from that of its owner.
The government’s recent win on a motion for summary judgment against Liberty Global Inc. could further embolden the IRS’s use of a long-standing doctrine in pursuit of tax avoidance transactions.
In FedEx Corp. v. United States, the U.S. District Court for the Western District of Tennessee (the Court) addressed a subtle foreign tax credit issue, bringing into question the validity of regulations concerning the repatriation of controlled foreign corporation (CFC) earnings under the 2017 Tax Cuts and Jobs Act (the TCJA).
In the recent Tax Court case of Farhy v. Commissioner, 160 T.C. 6 (2023), the IRS “went to court and watched,“ only to learn that its long-held position on a procedural rule for certain information reporting penalties was incorrect.
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