Lisa M. Zarlenga

Lisa Zarlenga heads Steptoe’s Tax Policy Practice and combines her technical tax knowledge with her understanding of the tax policy process to solve clients’ most challenging problems. Drawing on her experience as Tax Legislative Counsel at the US Treasury Department’s Office of Tax Policy and her many years of advising domestic and multinational businesses on the federal income tax aspects of corporate and certain partnership transactions, Lisa helps clients advocate for changes in the tax law, participate in the process of implementing those changes through Treasury/IRS regulations and other administrative guidance, and structure transactions involving those changes. Lisa’s broad experience allows her to help clients develop multi-faceted strategies to achieve their ultimate goals.

As Tax Legislative Counsel at the Treasury Department, Lisa advised Treasury's Assistant Secretary for Tax Policy on a broad range of domestic tax policy issues, including corporate, partnership, healthcare, tax-exempt organizations, energy, income tax accounting, estate and gift, and procedure and administration. She oversaw preparation of regulations and other administrative guidance implementing the Internal Revenue Code and the president’s annual revenue proposals in these areas.

Transactional Structuring and Planning

Lisa advises clients on structuring tax-free and taxable acquisitions and dispositions, tax-free spin-offs, and internal restructurings, including providing opinion letters and seeking advance rulings from the IRS. She also assists clients in restructuring financially troubled businesses and advises on the special rules governing consolidated groups.

Lisa co-teaches a corporate tax class at George Washington University Law School. 

Blockchain and Digital Currency

Having worked on early tax guidance while at Treasury, Lisa has developed a specialized knowledge of tax issues involving blockchain and digital currency. She advises clients on conducting digital currency transactions and conversions, token offerings, and different investment and entity structures. Her experience includes advising coalitions of leading companies in the blockchain space engage directly with the IRS and policymakers to develop workable policies at an industry-wide level.

Lisa is a co-editor and co-author of the book, Taxation of Crypto Assets, which provides a comparative study in the taxation of crypto assets among 39 different countries.

Renewable Energy and Carbon Sequestration

Lisa has worked with clients, including a coalition of stakeholders, to advocate for regulatory and sub-regulatory guidance to implement the statutory changes to the carbon capture and sequestration credit by the Bipartisan Budget Act of 2018 and the Inflation Reduction Act. She has also assisted clients in filing the first life cycle analysis reports and structuring and negotiating sequestration projects and tax equity deals.

Lisa has also helped clients advocate for legislative changes to energy tax credits, including the credit for production from advanced nuclear power facilities. Most recently, she has been advising clients on the applicability of, and efforts to implement, the newly enacted energy tax provisions in the IRA, including the newly enacted methods to monetize these credits.

Qualified Opportunity Funds

Lisa has advised investors and funds on the intricate tax rules that govern investments in qualified opportunity funds and structured those investments. Shortly after enactment of the opportunity zone tax incentives in 2017, Lisa began working with a coalition of stakeholders to advocate for guidance to implement the new policies, including preparing comment letters and meeting with policymakers. She has also assisted funds with the ongoing compliance with the tax requirements.

Lisa co-authored the Bloomberg Tax Management Portfolio, “Investments in Qualified Opportunity Zones.”