Michelle A. Spiegel

Counsel
Norton Rose Fulbright US LLP

Houston
United States
T:+1 713 651 5164
Houston
United States
T:+1 713 651 5164
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Michelle A. Spiegel

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Biography

Michelle represents clients in all types of tax disputes with taxing authorities on federal and state levels. She advises taxpayers on various tax issues during tax examinations, in administrative appeals, and as an advocate in trial. Her trial experience is broad, including the preparation of pleadings, motions and briefs; work on most aspects of expert testimony, including the review of expert reports and the preparation of experts for testimony; and the examination of fact witnesses during trial. She also advises foreign and domestic corporations, partnerships, LLCs, estates, non-profits, and individuals seeking tax advice in connection with various types of transactions, including 1031 exchanges, mergers and acquisitions, restructurings, and other planning matters.

Michelle is admitted to practice in the US Tax Court and the Southern District of Texas.


Professional experience

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JD, Duke University School of Law, 2010
AB, Political Science, The University of Chicago, 2006

While in law school, Michelle was a Senior Staff Editor for the Duke Journal of Constitutional Law & Public Policy. While at The University of Chicago, she was a member of the Gilbert and Sullivan Society and a goalkeeper for the school's field hockey team.

Michelle was admitted to practice law in the State of Texas in 2010.

  • Texas State Bar
  • Represented corporate taxpayer regarding deferred like-kind exchange of power plants sold and replacement plants acquired under leases.
  • Represented intervenor in TEFRA tax proceeding regarding profits vs. capital interest partnership issues.
  • Represented corporate taxpayer regarding Section 45C tax credits.
  • Represented corporate taxpayer regarding abatement of penalties and interest.
  • Represented corporate taxpayer regarding proposed adjustment to foreign tax credits.
  • Represented estate in examination regarding valuations of certain properties.
  • Represented foreign corporate taxpayers regarding proposed adjustments related to IRS Outer Continental Shelf Initiatives.
  • Advised corporate taxpayer on bad debt issues regarding inter-company advances.
  • Represented corporate taxpayer regarding depreciation of line fill in oil refineries.
  • Advised corporate taxpayer regarding intercompany loans and potential substantial modification issues.
  • Represented various international taxpayers regarding IRS Voluntary Offshore Disclosure Program.
  • Represented corporate client in acquisition of newspaper company.
  • Represented corporate client regarding complex employment tax matters during sale of taxpayer.
  • Represented various clients to establish non-profit entities under Section 501 of the Internal Revenue Code.
  • Co-author, "Noncompensatory Options Regulations May Adversely Affect Holders, Buyers, and Historic Partners," Fulbright Briefing, February 14, 2013
  • Co-author, "Between Obamacare and the Bush Tax Cuts, Taxes Will Increase in 2013, But How Much? Can Planning Help?," Fulbright Briefing, August 27, 2012
  • "Tax Due Diligence: Checklist on Acquisitions," BNA Bloomberg U.S. Taxation of Mergers & Acquisitions Seminar, December 14, 2015 and December 1, 2014
  • "When and How to Escalate an Issue," Tax Executive Institute's 2015 IRS Audits & Appeals Seminar, May 20, 2015
  • "R&D Claims, Opportunities, Cases, IRS Announcements," Tax Executives Institute, May 7, 2015
  • State Bar of Texas, Tax Section-- Appointed Council Member; Editor of the Texas Tax Lawyer publication
  • State Bar of Texas, Tax Section Leadership Academy, Class of 2013-2014
  • Houston Young Lawyers Association Leadership Academy, Class of 2011