Emma Smith

Emma Smith is a tax litigator with a strong technical background and a deep understanding of Internal Revenue Service procedural matters. She joins Comiter Singer after a 14-year career with the IRS Office of Chief Counsel, where she advised Internal Revenue Agents on matters related to domestic and international taxation and represented the IRS before the United States Tax Court.

Emma began her career with the Office of Chief Counsel as a trial attorney, where she represented the IRS in all stages of tax controversy, including IRS examinations, appeals, and litigation. Emma litigated cases both as a first-chair attorney and as a member of several large trial teams responsible for complex international tax litigation.

After several years as a trial attorney, Emma was appointed to serve as a principal member of the Chief Counsel team responsible for overseeing agency responses to Congressional inquiries related to tax-exempt organizations. She supervised the review and production of documents responsive to Congressional requests and related civil litigation. She was tasked with certain special projects, including internal investigations and pre-release review of Congressional reports. Emma received the Commissioner’s Award, the highest honor the IRS Commissioner can give, for her work on the team.

Later in her career, Emma was appointed Associate Area Counsel for the Large Business & International Division.  In this role, Emma managed a team of attorneys. She provided technical guidance to Internal Revenue Agents in handling procedural and substantive issues encountered during examinations of high-net-worth individuals, large partnerships, and multinational entities. Notably, Emma advised the IRS on the tax consequences of complex mergers and acquisitions, micro-captive insurance, partnership audit procedures, and international tax. She also served as the LB&I point of contact for energy and renewable energy tax credits.

In addition to her substantive work at the IRS, Emma served as detailee to the United States House of Representatives, Committee on Ways and Means. As Tax Counsel, Emma provided legal advice to Committee members and their staff designees on tax legislation, Treasury regulations, and domestic and international tax policy. She was the tax staff lead on small business and passthrough entity taxation, with primary responsibility for matters related to the section 199A passthrough business deduction. 

Emma received her LL.M in Taxation from Georgetown University Law Center, where she earned Dean’s List honors and graduated with Distinction. Her practice focuses on U.S. federal income tax, including the taxation of partnerships, limited liability companies, and S-corporations; income and estate planning; and federal tax controversy.