The list of corporations that have benefited from Neumann's decision to not drop out of law school after her first year is considerable: Facebook, Dropbox, Canadian restaurant giant Tim Hortons and French pharmaceutical giant Aventis Agriculture SA, to name a few.
"I actually was considering dropping out of law school, to be honest," Neumann said, after first not finding her calling in medicine or public health. "Then I took my first tax law class and loved it. It was analytical, and when I gave advice, people actually listened."
She was a summer associate at Fenwick & West and since being hired full time has become a go-to attorney for many tech companies and multinational companies needing tax advice during international mergers and acquisitions. Neumann's expertise is in transfer pricing, or setting the prices for goods and services among related companies.
Neumann has represented Dropbox in every acquisition the company has completed, including CloudOn in 2015 and MobileSpan, Zulip and Hackpad the year before.
She advised Facebook on its $2 billion acquisition of virtual reality headset maker Oculus VR and three other tech companies: Nascent Objects in 2016 and, two years earlier, LiveRail and PrivateCore. She gave tax guidance to Shanghai Giant when it purchased digital game maker Playtika for $4.4 billion in 2016. Neumann was also special tax counsel to Tim Hortons in its $11.4 billion inversion transaction with Burger King in 2015.
She recently wrote an amicus brief on behalf of Xilinx Inc. in the 9th Circuit Court of Appeals for Altera v. Commissioner, Case Nos. 16-70496 and 16-70497 (9th Cir., filed Feb. 23, 2016), in which the IRS is appealing the U.S. Tax Court's 2015 decision that invalidated part of the regulations under Internal Revenue Code Section 482. In 2010, the 9th Circuit, ruling that the section's arm's length standard trumped the Internal Revenue Service's new regulations, had decided a similar case in favor of Xilinx.
Neumann said maintaining the Section 482 standard on transfer pricing is important to her clients. "Taxpayers are just trying to follow the law the way it's written," she said. "If you want to change the law, you have to go through a procedure to do it."
In addition to writing articles on national and international tax law, Neumann said she mentors new tax associates at Fenwick and students at UC Berkeley School of Law, where she lectures. She also donates 100 to 200 hours a year in pro bono work for the Animal Legal Defense Fund and other nonprofits.
"When I decided to work for a firm, I told myself I'd only do it if I could give back, and I've been true to that commitment," she said.
- James Getz
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