Jennifer Breen

Jennifer’s proven skills and extensive background includes all aspects of tax controversy and litigation, including managing IRS audits, filing and presenting protests in IRS Appeals, and ultimately litigating cases before the United States Tax Court and other federal courts. Her understanding of various stakeholders’ needs enables Jennifer to craft nuanced strategies and makes her an empathetic advisor and effective advocate.

Drawing on her experience as an attorney with the IRS Office of Chief Counsel’s National Office, Jennifer marries substantive tax knowledge with strong relationships at the IRS and firsthand insights into navigating issues, seeking guidance, and understanding administrative processes and federal rulemaking at this agency. She seeks to resolve issues at the earliest stage possible, utilizing procedural techniques including pre-filing agreements, private letter ruling requests, requests for technical advice, and other informal methods. Jennifer also routinely advises clients on filing and compliance matters, voluntary disclosures, interest issues, penalty abatement actions, IRS requests and summonses, enforcement proceedings, and joint defense agreements.

Prior to joining Morgan Lewis, she distinguished herself as a trusted in-house advisor for Mattel, an American multinational toy manufacturing and entertainment company. In this capacity, Jennifer gained a keen understanding from an in-house perspective of all aspects of tax compliance and controversy. She was responsible for all matters involving US federal income tax and foreign tax controversies as well as those involving state and local corporate and business tax, sales and use tax, and escheat and unclaimed property audits. In addition, she managed the company’s global reportable transaction compliance and compliance under the Foreign Account Tax Compliance Act.

While with PwC, Jennifer represented major corporations, partnerships, S corporations, and individuals in resolving domestic and international controversy issues, counseled clients on risk management matters, and routinely advised on filing and compliance issues as well as other issues arising with accounting, audit, and internal controls.

As a director of the Washington D.C. Center for Public Interest Tax Law, a nonprofit tax clinic providing pro bono legal services to taxpayers across the United States, Jennifer oversees clinic operations including regular attendance at United States Tax Court calendar calls and the delivery of pro bono legal representation to low-income taxpayers.