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Nicole Elliott

Partner
Holland & Knight

Nicole Elliott is a tax attorney in Holland & Knight's Public Policy & Regulation Group in Washington, D.C. She is a co-leader of the group's Tax Policy Team. Ms. Elliott counsels clients on understanding and navigating the complexities of tax policy, and represents clients seeking legislative and regulatory changes to tax laws.

Ms. Elliott's practice also involves advising clients in the context of tax controversies, both at the administrative level before the IRS and in litigation. In addition, she has particular knowledge and experience in assisting tax-exempt organizations, including Native American governments. As part of Holland & Knight's Renewable and Alternative Energy Tax Team, Ms. Elliott is heavily focused on the many tax incentives included in the Inflation Reduction Act (IRA), including manufacturing credits, clean vehicle credits and energy generation credits. Ms. Elliott is a recognized authority on the Prohibited Foreign Entity (PFE) rules – commonly known as Foreign Entity of Concern (FEOC) rules – which have become increasingly relevant to clean energy tax credits following the enactment of the One Big Beautiful Bill Act (OBBB).

Prior to joining Holland & Knight, Ms. Elliott was an executive with the U.S. Department of the Treasury and member of the senior executive team with the IRS. While at the IRS, Ms. Elliott was the lead executive responsible for overseeing all aspects of the Affordable Care Act (ACA) implementation. This included working on legal guidance and on operational implementation. On numerous occasions, she was called upon to negotiate the more complex aspects of the law, not only within the IRS, but also as a key liaison with the executive branch and other government agencies. In addition, she was the IRS point of contact for Congress and frequently briefed Capitol Hill staff on the law and provided advice on legislative proposals.

Prior to her work with the IRS, Ms. Elliott was a tax litigator for the U.S. Department of Justice (DOJ), Tax Division. Ms. Elliott handled both affirmative and defensive litigation in district and bankruptcy courts throughout the United States.

Disclosure information not submitted.

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