Graham Magill

Partner Washington, D.C.

Biography

Graham Magill
Graham Magill is a partner in Weil’s Tax Department and is based in Washington, D.C. Graham advises clients on federal income taxation of domestic and cross-border mergers, acquisitions, spin-offs, other divestiture types and restructurings.

Prior to joining Weil, Graham was a Principal at KPMG LLP in the Washington National Tax practice.

Graham is recognized as a “Highly Regarded” lawyer for Transactional Tax in the U.S. by International Tax Review’s World Tax and as a “Bankruptcy Tax Specialist” by Turnarounds & Workouts magazine. She is recommended for Tax: Financial Products and U.S. Taxes: Non-Contentious by Legal 500 US. Graham was named a 2022 “D.C. Rising Star” by The National Law Journal. She was also named a 2021 “Rising Star” for Tax by Euromoney Legal Media Group and a 2021 and 2022 “Rising Star” for Tax by Expert Guides. Graham was shortlisted for the 2020 “Best in Tax” Award for Euromoney Legal Media Group’s Americas Rising Star Awards and shortlisted for the 2020 “Rising Star in Tax” Award for Euromoney Legal Media Group’s Americas Women in Business Law Awards.

Graham received her J.D., magna cum laude, from the University of Richmond, where she was Manuscripts Editor of the University of Richmond Law Review, her LL.M in Taxation from New York University and her B.A. from the University of Virginia. She is a member of the American Bar Association.

Latest Thinking, Speaking Engagements, Firm News & Announcements, Awards and Recognition

Latest Thinking

  • Updated Procedures for Section 355 Private Letter Rulings: Rev. Proc. 2024-24 and Notice 2024-38 Blog Post — Tax Blog — By Devon Bodoh, Graham Magill, Blake Bitter, Madeline Joerg, Grant Solomon and Adam Sternberg — May 13, 2024
    On May 1, 2024, the Treasury Department and Internal Revenue Service (the “Treasury” and “IRS,” respectively) issued Revenue Procedure (“Rev. Proc.”) 2024-24 and Notice 2024-38 (collectively, the “Guidance”). The Rev. Proc. provides procedures for requesting private letter rulings from the IRS relating to certain matters pertaining to transactions intended to qualify under Section 355 and related provisions of the Internal Revenue Code of 1986, as amended (the “Code”).[1] Notice 2024-38 describes the views and concerns of the Treasury and IRS regarding certain matters addressed in the Rev. Proc. The Guidance modifies Rev. Proc. 2017-52 and supersedes Rev. Proc. 2018-53. ...
  • Here We Go – Excise Tax Proposed Regulations Largely “NSYNC” with Notice 2023-2 Blog Post — Tax Blog — By Devon Bodoh, Graham Magill, Blake Bitter and Grant Solomon — April 23, 2024
    On April 9, 2024, the Treasury Department (the “Treasury”) and Internal Revenue Service (the “IRS”) issued two sets of proposed regulations (the “Proposed Regulations”) regarding the application of the section 4501 excise tax on repurchases of corporate stock (the “Excise Tax”) and the reporting and payment of such taxes. The Proposed Regulations generally follow the approach of Notice 2023-2 (the “Notice”), which was issued on Dec. 27, 2022, with some clarifications and modifications. For a further discussion of the Notice, see “Notice 2023-2: Proposed Guidance on the Stock Buyback Excise Tax” posted on December 29, 2022. ...
  • IP Phone Home – IRS Issues New Proposed Rules on the Repatriation of Intangible Property Blog Post — Tax Blog — By Devon Bodoh, Greg Featherman, Graham Magill and Grant Solomon — May 04, 2023
    Section 367(d) of the Internal Revenue Code (the “Code”) provides rules for outbound transfers of intangible property (e.g., intellectual property) by a U.S. person (a “U.S. transferor”) to a foreign corporation. Under these rules, when a U.S. transferor transfers intangible property to a foreign corporation in an otherwise tax-free exchange under Sections[1] 351 or 361, the U.S. transferor is treated as having sold the intangible property in exchange for annual royalty payments (an “annual inclusion”) over the useful life of the intangible property (or a lump sum payment in the case of a disposition of the intangible property following the initial outbound transfer). The U.S. transferor treats the annual inclusion and lump sum as ordinary income and royalties for purposes of determining source and the foreign tax credit limitation category. Final regulations under Section 367(d) were published on December 16, 2016 (the “367 Regulations”). ...

Speaking Engagements

Firm News & Announcements

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Awards and Recognition

  • Graham Magill Recognized as a “Highly Regarded” Lawyer for Transactional Tax in the U.S. Award Brief — International Tax Review’s World Tax
  • Graham Magill Named a 2022 “D.C. Rising Star” Award Brief — The National Law Journal
  • Graham Magill Named a 2021 “Rising Star” for Tax Award Brief — Euromoney Legal Media Group
  • Graham Magill Named a 2021 and 2022 “Rising Star” for Tax Award Brief — Expert Guides
  • Graham Magill Recommended for Tax: Financial Products and U.S. Taxes: Non-Contentious Award Brief — Legal 500 US
  • Graham Magill Named a “Bankruptcy Tax Specialist” Award Brief — Turnarounds & Workouts

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