Jennifer Lindy

People

Jennifer Lindy focuses her practice on cross-border and international tax issues in disputes with the IRS during all phases of the tax controversy and litigation process for individual, partnership/pass-through, and multinational corporate taxpayers.

She has over 18 years of diverse experience in advising individuals, multinational entities, accountants, and other tax service providers with complex international tax matters, including U.S. inbound and outbound tax issues, various voluntary disclosure programs and methods, and dispute-resolution with the IRS and other tax agencies, related to cross-border transactions, U.S. withholding tax, foreign income and asset disclosure, payroll tax, and overall international tax compliance and reporting.

Notable Work

Tax Litigation:

Jennifer has participated in several cases before the Tax Court, including, but not limited to, the following cases:

Ladny v. Commissioner, Tax Court Docket No. 16952-24
Estate of Lapp v. Commissioner, Tax Court Docket No. 14509-24
Astroturf Construction Corporation v. Commissioner, Tax Court Docket No. 17630-23
Sehorsch v. Commissioner, Tax Court Docket No. 18612-22
Estate of Beckers v. Commissioner, Tax Court Docket No. 3123-22
Estate of Mularoni v. Commissioner, Tax Court Docket No. 17822-21
Estate of Mularoni v. Commissioner, Tax Court Docket No. 18613-21
United States v. Bucari, Case No. 1:21-CV-2199 (N.D. Ga.)
Thomas v. Commissioner, Tax Court Docket No. 13479-17
Woods v. Commissioner, Tax Court Docket No. 12230-15
Hargrave v. Commissioner, Tax Court Docket No. 24316-14
Bauer v. Commissioner, Tax Court Docket No. 27968-14

IRS Administrative Rulings:

Private Letter Ruling 100923-24 (ruling regarding an Electing Small Business Trust election necessitated by inadvertent termination of S corporation status)
Private Letter Ruling 100924-24 (ruling regarding an Electing Small Business Trust election necessitated by inadvertent termination of S corporation status)
Private Letter Ruling 100925-24 (ruling regarding an Electing Small Business Trust election necessitated by inadvertent termination of S corporation status)
IRS Private Letter Ruling 107742-23: Ruling regarding reclassification of domestic entity from C corporation to Subchapter S corporation)
IRS Private Letter Ruling 117191-20: Ruling regarding late entity-classification election on Form 8832 and late subchapter S corporation election on Form 2553)
IRS Private Letter Ruling 119920-19: Ruling regarding reclassification of domestic entity from subchapter S corporation to partnership
IRS Private Letter Ruling 107272-17: Ruling regarding late Section 754 election and tiered-partnership structure
IRS Private Letter Ruling 107273-17: Ruling regarding late Section 754 election and tiered-partnership structure
IRS Private Letter Ruling 101616-17: Ruling regarding expatriation issues under Section 877A and the Offshore Voluntary Disclosure Program

Other Administrative Remedies with IRS:

In situations where obtaining a private letter ruling from the IRS National Office is unnecessary or unavailable, Jennifer has achieved tax results for clients through other administrative procedures, including the following:

Request pursuant to/under I.R.M. for late request for issuance of withholding certificates and relief from tax withholding with respect to U.S. real property interest distributions
Request pursuant to Rev. Proc. 2008-27 for relief from tax withholding obligation on the disposition of a U.S. real property interest under Treas. Reg. §1.445-2(d)(2)
Request to file late Forms 1040-NR (enclosing Forms 8833) on a penalty-free basis, claiming all deductions and credits, pursuant to special wavier procedures under Treas. Reg. § 1.874-1(b)(2)
Request to file late Forms 1120-F (enclosing Form 5472, Forms 8833, and other international information returns) on a penalty-free basis, claiming all deductions and credits, pursuant to special wavier procedures under Reg. §l.882-4(a)(3)(ii)
Request to make a foreign earned income exclusion election under Section 911 pursuant to Treas. Reg. § 1.911-7
Request to nullify previous election under Section 6013(g) to have non-resident alien spouse treated as U.S. person
Request for relief to file a late Gain Recognition Agreement under Section 367 and Treas. Reg. § 1.367(a)-8(p) in connection with a foreign-to-foreign reorganization
Request for elimination of expatriation/exit tax under Section 877A pursuant to the Relief Procedures for Certain Former Citizens
Request to make late election under Section 871 pursuant to Treas. Reg. §1.871-10(d)(1)(ii) to treat U.S. real property income as effectively connected with a U.S. trade or business
Request to file late Forms 940, 941, W-2, and W-3 to resolve outstanding employment tax matters
Request for closing agreement on individua and entity payroll tax matters under the Voluntary Closing Agreement Process for Employment Tax (VCAP-ET)
Request for penalty waivers related to tax returns and various international information returns pursuant to Notice 2022-36 and others

Show all

Bloomberg Law, Co-Author, “Has the IRS Found the Next Swiss Bank Program?” April 21, 2025
Bloomberg Tax, Co-Author, “Supreme Court Ruling Leaves Door Cracked for Future Wealth Tax,” June 26, 2024
2023 IRS Nationwide Tax Forum, Speaker, "Tax Issues Applicable to Recent Immigrants” and “Challenging Information Returns”, July 2023
2022 ATA Annual Tax Conference, Speaker, “Tax Controversy from the Trenches,” December 2022
57th Annual Southern Federal Tax Institute, Speaker, "Tax Controversy from the Trenches," October 2022
Tennessee Federal Tax Conference, Speaker, "Active IRS International Enforcement Campaigns and U.S. Tax Reporting of Foreign Assets and Penalties for Noncompliance," November 2021
Tennessee Federal Tax Conference, Speaker, "Current U.S. International Tax Updates and Active IRS International Enforcement Campaigns," November 2021
Russell Bedford International, International Tax Conference, Speaker, "Current IRS International Enforcement Campaigns and Remedies to Correct U.S. Tax Reporting," June 2021
International Tax Compliance, Enforcement and Disputes: “The Most Pressing Issues in 2017 and Beyond,” International Wealth Planning, September 2017
Tax Executives Institute 2014 International Tax Course, Speaker, "Documentation and Information Reporting from Foreign Affiliates: Forms 5471, 5472, 8858, and 8886," August 2014
Ernst & Young’s Jacksonville Tax Breakfast Series, Speaker, "US Reporting and Withholding on Payments to Non-U.S. Persons: Section 1441, FATCA and FBAR," May 2014

Law360, Tax Authority International Editorial Board, 2025
State Bar of Georgia, Tax Section, Member
State Bar of Florida, Tax Section, Member
American Bar Association, Law Practice Division and Tax Section, Member
DW/EN, Member
Atlanta International Tax Study Group, President
Atlanta Women in Tax, Founding Member

Jennifer Duval Lindy

Notable Work

Published Work and Lectures

Affiliations

Areas of Experience

Education

Admissions

Bars

Courts

Languages

Related Content

Welcome to our new site