Ellen McElroy is a partner with Pepper Hamilton LLP, resident in the Washington D.C. office. She focuses on a broad variety of corporate tax issues, primarily accounting method considerations. She regularly advises clients on the proper tax treatment of costs associated with tangible property, (including the treatment of repair costs), intangible property (including acquisition costs and recovery), and corporate transaction costs. With respect to corporate transaction costs, she advises clients regarding various corporate transactions, including both acquisitive and divisive transactions, both strategic and private equity transactions. She further advises clients on income recognition matters as well as inventory issues.
Ms. McElroy regularly represents clients before IRS, including representation at the IRS National Office with private letter rulings and technical advice. She also has represented a number of clients in controversy matters, including IRS Exam, Appeals, including matters involving Pre-Filing Agreements, Fast Track Appeals, and the Compliance Audit Program.
Before joining Pepper, Ms. McElroy was a partner with Ernst & Young LLP, where she led the firm’s transaction cost review practice and worked on accounting methods and inventory matters for Fortune 500 companies as part of her role in the firm’s National Tax Department.
Prior to Ernst & Young LLP, Ms. McElroy was legislation counsel for the IRS Office of Special Counsel (Legislation), where she developed and drafted legislative proposals, supervised congressional investigations, and GAO audits involving IRS. She also was a senior attorney with the Income Tax and Accounting Division. In this position, Ms. McElroy was principal author of final regulations under the uniform capitalization rules and temporary regulations involving the deductibility of lobbying expenses. She also wrote revenue rulings, technical advice memoranda, and private letter rulings involving income tax accounting issues including, deductibility of severance payments, environmental cleanup, advance payments and the tax treatment of takeover costs.
Ms. McElroy is past chair of the ABA Tax Accounting Committee and she has served as chair of the Tax Accounting Committee’s Capitalization Sub Committee. She served as the tax accounting chair for the 2013 Federal Bar Association’s Section on Taxation Tax Law Conference. She is an adjunct professor at Georgetown University Law Center. She speaks regularly before corporate groups, including Tax Executive Institute, Philadelphia Tax Conference, Federal Bar and ABA meetings.
Ms. McElroy received her B.B.A. from Emory University. She received her J.D. from the University of Denver College of Law, where she was Law Review general editor. Ms. McElroy received her LL.M. from Georgetown University Law Center. She is a member of the Colorado and American Bar Associations. Ms. McElroy is admitted to practice in the District of Columbia and Colorado.