Heather Maloy, the commissioner in charge of the IRS’s Large Business & International Division, plans to join Ernst & Young’s National Tax Department as tax controversy leader.

She will be starting work at EY in September. As LB&I commissioner at the IRS, Maloy has been responsible for the IRS’s Industry Issue Resolution Program, which works with business taxpayers, industry associations, taxpayer representatives, and other interested parties to identify frequently disputed tax issues common to a significant number of business taxpayers and to resolve those issues through published or administrative guidance.

Maloy also made the IRS’s Compliance Assurance Program for large corporate taxpayers permanent after an initial six-year pilot testing period. Under CAP, participating taxpayers work collaboratively with an IRS team to identify and resolve potential tax issues before the tax return is filed each year. With the major potential tax issues largely settled before filing, taxpayers are generally subject to shorter and narrower post-filing examinations. Maloy’s division also provides IRS examiners with guidance on important technical topics involving large businesses and international taxpayers.

Maloy previously worked in the IRS’s Office of Chief Counsel as the leader of the Income Tax & Accounting and the Passthroughs & Special Industries divisions. She also has experience in the private sector, most recently at the law firm Skadden, Arps, Slate, Meagher & Flom, where she represented clients in both examinations and appeals on IRS tax controversy matters with regard to complex issues of corporate, partnership, S corporation, individual and international income taxation.

“Tax controversy continues to grow in importance as U.S. and foreign tax administrators focus on the activities of US companies,” said Michael Mundaca, co-leader of the National Tax Department of Ernst & Young LLP, who rejoined the firm in 2011 after serving as Assistant Secretary of Tax Policy at the U.S Treasury Department. “Heather’s background and experience, both at the IRS and in the private sector, will enable her to advise clients to ensure they are able to proactively anticipate and address both the procedural and technical aspects of tax issues.”

Maloy earned her BBA in Accounting from Emory University, her JD from Cornell University Law School, and her LLM in Taxation from the University of Florida College of Law, where she also served as a visiting assistant professor.

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