Practices
Education
- LL.M. (Taxation)Georgetown University Law Centerwith distinction1999
- J.D.The George Washington University Law Schoolwith honors, Order of the Coif1993
- B.S.University of Delawarecum laude1988
Maria Jones serves on the Miller & Chevalier Executive Committee and is Chair of the Diversity and Inclusion Committee. She practices in the area of federal income taxation with a focus on tax controversy matters, including Internal Revenue Service (IRS) audits, IRS Appeals and tax litigation in the U.S. Tax Court, the Court of Federal Claims and Federal district courts. She has significant experience in matters involving the taxation of insurance companies, including deductibility of ceding commissions and reserves, deductibility of policyholder dividends, conversion of nonprofit insurance companies, captive insurance company issues, including IRC section 831(b) captives, and the provisions applicable to Blue Cross and Blue Shield plans.
Ms. Jones also advises clients on a wide range of other tax issues, including matters involving the Affordable Care Act, the valuation of intangible assets, charitable contributions of conservation easements, excise tax matters, and tax accounting matters. She has experience with IRS issue resolution procedures, including Pre-Filing Agreements, Fast Track Settlement and the Industry Issue Resolution (IIR) program. Ms. Jones is a member of the Board of Directors of the Insurance Tax Conference and is a frequent speaker on insurance tax and federal tax controversy issues. Ms. Jones is the President of the Miller & Chevalier Charitable Foundation.
- Lodge Holdings, LLC v. Commissioner, No. 11919-16 (Tax Court).
- Flat Rock Property Holdings, LLC v. Commissioner, No. 11719-16 (Tax Court).
- Railroad Holdings, LLC v. Commissioner, No. 11838-16 (Tax Court).
- Highmark Inc. v. United States, No. 1:17cv-00898-LKG (Fed. Cl.)
- Washington Mutual, Inc. et al. v. United States, 891 F. 3d 1016 (Fed. Cir. 2018).
- Washington Mutual, Inc. et al. v. United States, 856 F. 3d 711 (9th Cir. 2017).
- Blue Cross and Blue Shield of Kansas v. Commissioner, No. 8088-08 (Tax Ct.) (settled).
- Washington Mutual, Inc. v. United States, 636 F. 3d 1207 (9th Cir. 2011).
- Louisiana Health Serv. & Indem. Co. v. United States, 104 A.F.T.R. 2d 2009-5194 (M.D. La. 2009).
- Hosp. Serv. Ass'n of Northeastern Pennsylvania v. United States, 78 Fed. Cl. 434 (2007).
- Capital Blue Cross v. Commissioner, 431 F.3d 117 (3d Cir 2005) (represented amicus curiae Blue Cross Blue Shield Association).
- Blue Cross & Blue Shield of Wyo. v. United States, No. 04-01791T (Fed. Cl.) (settled).
- Blue Cross & Blue Shield of Tenn. v. Commissioner, No. 10178-98 (Tax Ct.) (settled).
- Legal 500: Tax: U.S. Taxes: Contentious, 2017, 2020 - 2021
- The Best Lawyers in America®: Tax Law, 2018 - 2021
- International Tax Review: Women in Tax Leaders, 2015 - 2017
- International Tax Review: Tax Controversy Leaders (U.S.), 2014 - 2017
- DC Bar Capital Pro Bono Honor Roll, 2018 - 2020
- Advisory Board Member, Catholic Charities Legal Network of the Archdiocese of Washington
Bar Admissions
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District of Columbia
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Virginia (inactive)
Washington, DC, June 11, 2021 – Miller & Chevalier Chartered announced today that the firm received numerous practice and individual rankings in the 2021 edition of Legal 5
James Gadwood and Maria O'Toole Jones will present "Income Recognition under Section 451 and Section 162(f) after the TCJA," to the Tax Executives Institute's (TEI's) Carolinas Chapter on April 30,
Steven Dixon, Maria O'Toole Jones, and Lisandra Ortiz will present "Ethical Considerations in Tax Practice," to the Tax Executives Institute's (TEI's) New England Chapter on April 9, 2021.
Washington, DC, April 5, 2021 – Miller & Chevalier is pleased to announce that 47 firm lawyers were named to the 2020 Capital Pro Bono Honor Roll, with 25 firm lawyers providin
Maria O'Toole Jones will speak at the Blue Cross Blue Shield Association's 2020 National Tax Conference on December 2-3, 2020.
On June 18, 2017, the Tax Court issued its opinion in Reserve Mechanical Corp. v. Comm'r, a case involving a microcaptive insurance company.
On August 21, 2017, the Tax Court issued its opinion in Avrahami v. Comm'r, a case of first impression relating to the taxpayers' use of a microcaptive insurance company.
The Internal Revenue Service (IRS) Large Business & International Division (LB&I) is transitioning to a centralized compliance and examination process that focuses on issue-based campaigns.
Over the past decade, the U.S.
On April 23, 2015, the Treasury Department (Treasury) and Internal Revenue Service (IRS) issued proposed regulations on the application of the passive foreign investment company (PFIC) rules of Int