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Basics of International Taxation 2018 New York


Speaker(s): Andrea Sharetta, Angela E. Holland, Carol P. Tello, Caroline H. Ngo, Catherine G. Schultz, Corey M. Goodman, David L. Forst, James S.H. Null, Janice A. Mays, John D. Bates, John L. Harrington, John P. Warner, José E. Murillo, Kristine A. Crabtree, Linda E. Carlisle, Lisa M. Zarlenga, Michele J. Alexander, Nicole L. Welch, Patrick A. Jackman, Philip B. Wright, S. Eric Wang, Steven C. Wrappe, William J. Corcoran
Recorded on: Jul. 24, 2018
PLI Program #: 218872

Bill Corcoran advises on the federal and state income tax consequences of corporate and partnership mergers and divisions. He also represents leveraged buyout, venture capital, mezzanine and other alternative investment vehicles on formation and investment issues. Bill's practice includes assisting non-US investors in alternative investment vehicles formed to invest in equity, debt, real estate and infrastructure projects. He has extensive expertise in advising foreign sovereigns investing in the US. Bill also represents multinational corporations on financing, tax treaty planning, and other cross-border tax issues. He also has experience representing public and private companies involved in developing the exchangeable share structure and advises US investors investing in Canada through alternative investment vehicles.

Bill’s representative matters include:

  • Portfolio investment by a US investor in a Canadian corporation using exchangeable shares and designed to preserve Canadian controlled private corporation (CCPC) status
  • Acquisition of the stock and assets of a divisional business of a public corporation involving tax issues in the US, Canada and China
  • $300 million acquisition of the stock of a domestic Subchapter S corporation, together with the filing of a Section 338(h)(10) election to step-up the inside tax basis of the target corporation’s assets
  • Leveraged buyout of a US corporation by a Canadian buyout fund
  • Purchase of a publicly-traded corporation by another publicly-traded corporation involving US golden parachute tax rules and recently enacted deferred compensation tax rules

Education

  • University of ChicagoJD
  • Brandeis UniversityBA

Bar Admissions

  • New York
  • Massachusetts


Linda E. Carlisle is the Chief Operating Officer & General Counsel of Unicom Capital LLC in Denver. She was a member of Miller & Chevalier in Washington, D.C. before joining Unicom where she practiced international and domestic tax law, concentrating on corporate and partnership tax issues and on the taxation of cross-border investments. She also advised clients on legislative, regulatory and administrative tax matters. Before joining Miller & Chevalier Linda was a Tax partner in the Washington, D.C. office of White & Case and was the Special Assistant to the Assistant Secretary (Tax Policy) during the enactment of the 1986 Tax Reform Act.


Lisa Zarlenga represents public and private companies on federal income taxation issues, with a focus on corporate transactional and planning matters as well as on tax policy issues with respect to tax legislation and Treasury guidance. Lisa also 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.

Drawing on her experience as Tax Legislative Counsel at the US Treasury Department’s Office of Tax Policy, Lisa marries substantive tax knowledge with first-hand insights on the guidance and other processes at Treasury. She helps clients advocate for and resolve tax policy issues before the Treasury Department and IRS involving proposed and pending regulations and other administrative guidance, and before Congress involving legislation.

Lisa has combined her policy and transactional backgrounds to advise clients on certain specialized tax issues, such as blockchain and digital currency and qualified opportunity zones.  She advises clients on conducting digital currency transactions and conversions, token offerings, and different investment and entity structures.  With respect to qualified opportunity zones, Lisa has advised investors and funds on the intricate tax rules that govern the investments and structured those investments.  She has also assisted clients during the rulemaking process, including preparing comment letters and meeting with policymakers.

 

Clerkship & Government Experience

  • Hon. Robert P. Ruwe, US Tax Court
  • Tax Legislative Counsel, Department of the Treasury, Office of Tax Policy

Education

  • LL.M., Georgetown University Law Center, with honors, Taxation
  • J.D., Ohio State University Moritz College of Law, Order of the Coif; Associate Editor, Ohio State Law Journal
  • B.S., Ohio State University, summa cum laude, Beta Gamma Sigma, Accounting

Awards

  • Fellow, American College of Tax Counsel
  • Chambers USA, Tax, DC (2018-2019)
  • The Best Lawyers in America, Tax Law (2018-2019)
  • Super Lawyers, Washington, DC, Tax (2017-2019)
  • Treasury Exceptional Service Award (2015), Special Act Award (2011)
  • Washingtonian magazine, "Best Lawyers," Tax (2015, 2017-2018)
  • Legal 500 US, Finance: Not-for-Profit, Nonprofit and Tax Exempt Organizations; Government: Government Relations; Tax: International Tax; Tax: US Taxes, Contentious (2017-2018); Tax: US Taxes, Non-Contentious (2016-2018); Domestic Tax, East Coast (2009-2010)

 


Philip B. Wright is a Partner in the law firm of Bryan Cave Leighton Paisner LLP and is a member of the Tax Advice and Controversy Client Service Group.  His practice is concentrated primarily on advising clients in respect of the domestic and international tax aspects of inbound and outbound investment including acquisition structuring and related financing in all industries including real estate.  He regularly advises clients regarding the federal income tax aspects of the formation and operation of business entities.

Phil received his B.A. degree in Accounting from the University of Missouri, magna cum laude (1979), J.D. degree from Georgetown University, cum laude (1982), and his LL.M. from New York University (1985).  He serves as an adjunct professor in the School of Accountancy Master's program at the University of Missouri – Columbia where he teaches Partnership Taxation.  He frequently writes and speaks on tax issues involved in cross border merger and acquisition.  His prior professional experience includes practice as a tax specialist and CPA with a Big Four accounting firm.

Phil is a member of the Tax Section of the American Bar Association and New York State Bar Association. Phil also serves as a Member of Bloomberg BNA's Corporate Taxation Advisory Board.  He is a Fellow of the American College of Tax Counsel and is listed in The Best Lawyers In America.  He is admitted to practice in Missouri, New York and the District of Columbia.


Steven C. Wrappe is KPMG’s Deputy Head of Global Transfer Pricing Dispute Resolution.   Steve has over 25 years of client and government experience in transfer pricing. Prior to joining KPMG, he led the APA practice of two other Big Four Firms and was a partner with a global law firm. Before that, Steve was a Senior Attorney with the IRS APA Program. Steve’s transfer pricing controversy experience includes examination, appeals, alternative dispute resolutions, advance pricing agreement (APAs), mutual agreement procedures (MAP) and Customs agreements.

He is one of the most experienced APA or MAP negotiators at any firm, with a combined experience of well over 150 cases. He has negotiated APAs and MAP agreements in the following industries: automotive, automotive parts, aero engines, beverages, chemicals, construction equipment, data processing, electronics, electronic games, fast moving consumer goods, food, food service, health products, motorcycles, musical instruments, pharmaceuticals, and photographic equipment.  Steve has spoken at many leading global tax forums for the following groups: Organization for Economic Cooperation and Development, United Nations, International Fiscal Association, George Washington/IRS Tax Conference, Tax Executives national and regional meetings, World Customs Organization, American Bar Association, NYU Institute, and Practicing Law Institute.

Steve has been an adjunct faculty member at New York University School of Law, Georgetown University Law Center, and the University of Florida School of Law. He has also taught transfer pricing and transfer pricing controversy at the IRS, U.S. Customs and several other tax authorities.

Steve has served as Chair of the Transfer Pricing Committee of the American Bar Association’s Tax Section. He serves on the Board of Advisors of New York University School of Law’s International Tax Program and BNA Tax Management (Transfer Pricing).  Steve has consistently been recognized in Euromoney’s Guide to the World’s Leading Transfer Pricing Advisors.


José is the leader of the International Tax Services (ITS) practice, Washington, DC at Ernst & Young LLP, the US EY member firm. He also serves as the National Director of Technical Services for ITS. José practices primarily in the area of cross-border acquisitions, dispositions and restructurings.

Prior to his current role, José was a member of the Treasury Department’s Office of Tax Policy, where he assisted in the development of international tax policy, Treasury regulations and other guidance and in negotiating income tax treaties.

Before serving with the Treasury Department, he was a member of Ernst & Young LLP’s International Tax Services practices in Houston and Washington, DC.

José is a frequent contributor to tax publications and a presenter at internal and external international tax seminars and conferences.

 


With a career that spans both government and private practice, Carol Tello helps multinational companies and individuals navigate the complex and rigorous realm of international taxation. Her practice includes a broad range of cross-border tax planning and Internal Revenue Service (IRS) controversy matters, including compliance with the Foreign Account Tax Compliance Act (FATCA).

Balancing the concurrent goals of minimizing tax consequences and complying with the law, Carol brings experience in cross-border restructuring transactions, inbound corporate transactions, withholding matters and treaty interpretation issues, as well as cross-border taxation of corporate executives and the U.S. taxation of non-U.S. citizens. She also advises clients on tax issues involving intellectual property transactions.

Before joining Eversheds Sutherland (US), Carol worked in the IRS Office of Associate Chief Counsel (International) and as a Special Assistant to the Assistant Commissioner (International). She participated in a number of income tax treaty negotiations, was the IRS National Office adviser in several U.S. Tax Court cases, and worked on various regulations and other guidance, including significant participation in developing regulations concerning the taxation of software transactions. Carol is the author of the BNA Treatise “Payments Directed Outside the United States – Withholding and Reporting Provisions Under Chapters 3 and 4.”


Caroline H. Ngo works principally with Fortune 500 companies and is a go-to advisor for some of their most complex tax issues.  She specializes in global tax planning, cross-border mergers and acquisitions, and international tax matters.  Caroline is Co-Leader of McDermott’s International Tax practice.

Caroline is nationally recognized for her deep knowledge of her field and is regularly invited to speak at significant forums on corporate and international tax issues. In her commitment to the development of others, Caroline has served or is currently serving as a mentor for nearly all of the associates in the McDermott Washington Tax Group.


Corey M. Goodman is a tax partner in the New York office of Cleary Gottlieb Steen & Hamilton LLP.  He advises clients on federal income tax matters including the structuring, documentation, and negotiation of a variety of domestic and international transactions, including mergers and acquisitions, joint ventures, spinoffs, bankruptcy reorganizations, refinancings, and cross-border and internal restructurings.

Mr. Goodman joined Cleary Gottlieb in 2007 and became a partner in 2016. He received an LL.M. degree in taxation from New York University School of Law in 2010, and a J.D. degree, magna cum laude, Order of the Coif, from New York University School of Law in 2007. He received his undergraduate degree (a Bachelor of Science in Computer Science) from Cornell University in 2000. Mr. Goodman has spoken on industry panels and in Practicing Law Institute conferences on the topic of international taxation, and was recognized in 2015 by Law360 as a “Rising Star” in tax.


David Forst focuses on international corporate taxation. David is included in Legal Media Group's Guide to the World's Leading Tax Advisers. He is also in Law and Business Research’s International Who’s Who of Corporate and Tax Lawyers (for the last eight years). David is listed in Legal 500 Hall of Fame, Chambers USA America's Leading Lawyers for Business (2011-2017), and has been named a Northern California Super Lawyer in Tax by San Francisco Magazine.

David is a lecturer at Stanford Law School and UC Berkeley Law School where he focuses on international taxation.  He is an editor of and regular contributor to the Journal of Taxation, where his publications have included articles on international joint ventures, international tax aspects of mergers and acquisitions, the dual consolidated loss regulations, and foreign currency issues. He is a regular contributor to the Journal of Passthrough Entities, where he writes a column on international issues. David is a frequent chair and speaker at tax conferences, including the NYU Tax Institute, the Tax Executives Institute, and the International Fiscal Association.

David graduated with an A.B., cum laude, Phi Beta Kappa, from Princeton University’s Woodrow Wilson School of Public and International Affairs, and received his J.D., with distinction, from Stanford Law School.

 


Andrea Sharetta is a Partner in the New York office of Dentons' Tax practice.  Her practice focuses primarily on a broad range of international tax areas, including cross-border restructurings and financing, Subpart F, US tax treaties, foreign tax credit planning, the tax treatment of inbound and outbound investments, and the new international tax rules enacted with the recent passage of US tax reform.  She also has expertise in federal income tax matters, including taxable and tax-free mergers, acquisitions, dispositions and other internal restructurings; and corporate joint ventures, as well as pre-immigration and expatriation planning for high net worth individuals.


Angela Holland is an attorney in Branch 6 of the Office of Associate Chief Counsel (International).  In her 9 years at the IRS, she has worked on a range of complex international transactions focused on transfer pricing.  Before joining the IRS, Angela worked for several years in private practice in the area of structured finance tax.  She received a B.S. in Finance from Morgan State University and a J.D. and MBA from Howard University.      

 


Catherine Schultz is the Vice President for Tax Policy at the National Foreign Trade Council.  Her responsibilities include international tax policy including legislative, regulatory, non-U.S. tax policy, administration, and tax treaty activity.

Prior to joining the NFTC, she was a Principal at Capital Strategies Group, LLC, where she represented client interests on pending tax legislation and served as a legislative advocate on international taxation, research and development, depreciation and capital gains.  Ms. Schultz participates in the OECD Technical Advisory Group on the taxation of cross-border services under the VAT, and is a member of the International Fiscal Association.  She is on the faculty of the Practising Law Institute’s Basics of International Taxation program. 

 


Eric Wang is a member of Sullivan & Cromwell’s Tax Group and concentrates on U.S. tax matters. A partner since 2010, Mr. Wang advises on a broad range of planning and transactional matters for both U.S. and non-U.S. clients. He has advised extensively on cross-border acquisitions and joint ventures, including structuring a number of investments made by private equity and real estate funds worldwide. He also advises on U.S. tax issues relating to tax-sensitive financing structures and novel financial instruments, as well as debt restructurings. In addition, Mr. Wang has represented clients with respect to IRS audits and investigations. Mr. Wang has also advised clients on their response to and compliance with the Foreign Account Tax Compliance Act (“FATCA”) since its introduction in late 2009.

Mr. Wang’s recent mergers and acquisitions work has included representations of 
Altran in its $2 billion acquisition, through its subsidiary Altran US, of Aricent, from a group of investors led by KKR; BMO Financial Group in its definitive agreement to acquire KGS-Alpha Capital; and Concho Resources in its $9.5 billion acquisition of RSP Permian.

On capital markets, Mr. Wang has advised Amgen Inc. in its modified Dutch auction tender offer for up to $10 billion in value of shares of its common stock at price per share not greater than $200 nor less than $175 and The Progressive Corporation in its SEC-registered public offering of $500 million aggregate liquidation preference of 500,000 Series B fixed-to-floating rate cumulative perpetual serial preferred shares and $600 million aggregate principal amount of its 4.20% notes due 2048; the Series B preferred shares issuance was Progressive’s first preferred issuance since 1991.

Clients he has advised recently include AB In-Bev, AIG, BP, BHP Billiton, Goldman Sachs, Rhône Capital and Enbridge.

Mr. Wang has been recognized as a leading lawyer by Chambers Global, The Legal 500 United Kingdom, The Legal 500 United States and The American Lawyer. He speaks and writes frequently on the taxation of financial institutions and on international taxation.

Mr. Wang received his J.D. from Harvard Law School and his undergraduate degree from Harvard University.

 


James "Jamie" Null focuses his practice on U.S. federal tax matters, including U.S. inbound and outbound investments, domestic and international tax planning for individual, corporate and partnership transactions, as well as private equity investments and structures using U.S. and non-U.S. treaty networks. Jamie has also advised on domestic and cross border mergers and acquisition transactions. He is experienced in advising U.S. media companies on foreign and domestic investments, and non-U.S. investors on inbound media investments and joint ventures. He also advises U.S. and non-U.S. entertainment clients (from both a production and talent side) on U.S. and international entertainment transactions, productions and events. 

Jamie provides pre-immigration planning with respect to nonresident aliens emigrating to the U.S. and planning for resident aliens and U.S. citizens emigrating from the U.S.  Jamie has also advised his clients on inbound U.S. investments (including for and with respect to sovereign wealth funds), with an emphasis on structuring U.S. real estate investments. Jamie has similarly advised and structured sophisticated like-kind exchanges involving both domestic and foreign interest holders. He has likewise advised clients on alternative energy, shipping, bankruptcy and debt restructuring (including those involving non-U.S. persons) and intellectual property transactions.

Jamie received his LL.M from New York University School of Law, his J.D. from University of Miami School of Law and his B.A. from Brandeis University. 

 


Janice Mays is a Managing Director in PwC’s Washington National Tax Services (WNTS). Janice’s long background in government and her deep understanding of the factors influencing both elected and professional participants in government make her uniquely qualified to provide insight and to assist the business community in assessing and pursuing critical policy issues more effectively. 

Janice joins PwC after a 40 year career on the Hill including over 22 years as the Democratic chief counsel and staff director for the House Ways and Means Committee. During her tenure, she was closely involved with and responsible for much tax legislation, including the Tax Reform Act of 1986. In addition, the second half of her career on the Hill, Janice worked extensively on health reform and international trade legislation.

 


John L. Harrington is the chair of Dentons’ US tax practice.  He advises clients on tax planning, transactional and compliance issues; international tax legislative, regulatory, and treaty matters; and a variety of substantive and legislative domestic tax issues.  In particular, he has extensive experience in dealing with the foreign tax credit, anti-deferral regimes (including Subpart F income), cross-border activities of companies and individuals, and other international tax issues.

Prior to joining Dentons, Mr. Harrington served as International Tax Counsel for the U.S. Department of Treasury.  As International Tax Counsel, he directed and supervised the staff of the Office of the International Tax Counsel which provides legal advice and analysis relating to international tax issues, including legislation, regulations, and treaties.  

At the Treasury Department, he worked closely with the Internal Revenue Service to develop regulations and other administrative guidance.  He also interacted frequently with other Executive Branch officials, especially in the State Department, the Commerce Department, the Office of the U.S. Trade Representative, and the White House. 

He represented the Treasury Department before Congress, including testifying at hearings.  He worked regularly with Congressional committees and staff on the international tax aspects of legislation, conducting briefings and participating in the development of legislative proposals. 

While at the Treasury Department, Mr. Harrington worked closely with tax officials in other countries.  He represented the United States at tax-related meetings of the Organisation for Economic Cooperation and Development (OECD) and in tax-related trade disputes before the World Trade Organization.    

Before joining the Treasury Department, Mr. Harrington was a tax counsel on the U.S. House Committee on Ways and Means.  On the committee staff, Mr. Harrington was responsible for international, pass-through entities, financial institutions and products, real estate, environment, energy, and other tax issues.

 


John P. Warner focuses his practice on international and corporate tax matters and the taxation of financial instruments and securitization transactions. He has advised foreign-based individuals and businesses with respect to U.S. investments and activities and U.S.-based individuals and businesses with respect to foreign investments and activities. John is co-chair of the Business & International Tax Practice Group and former co-office head of the firm’s Washington, D.C. office. John has been selected for inclusion in The Best Lawyers in America® list from 2015-2018. In 2017, he was also recognized on the 2017 Washington, D.C. Super Lawyers list.

He has more than 40 years of experience in domestic and international federal income tax and business planning, including the structuring of business formations, joint ventures and mergers and other domestic and cross-border business acquisitions and dispositions. He has advised a wide variety of U.S. citizens living abroad and foreign residents with U.S. activities and investments. He has helped to structure numerous foreign acquisitions, operations and investments by U.S. businesses and investors and to structure numerous U.S. acquisitions, operations and investments by foreign businesses and investors. John has experience in structuring various financial products, and providing issuers and investors advice as to the tax consequences of these products. He has represented many clients in obtaining Internal Revenue Service National Office rulings and in tax controversy matters, including IRS Appeals Office cases, competent authority proceedings, the resolution of transfer pricing disputes and voluntary disclosure of offshore financial accounts, assets and associated income.
He has litigated disputes in the United States Tax Court and the United States Claims Court, including Oak Industries, Inc. v. Commissioner, 96 T.C. 559 (1991), and Libbey v. Commissioner, 55 T.C.M. (CCH) 1052 (1988), and wrote an influential amicus brief in Indianapolis Power & Light Co. v. Commissioner, 493 U.S. 203 (1990).

John is a technical and contributing author to the Bloomberg Tax Management Transfer Pricing Portfolio Series. He is a frequent author and speaker in the United States and Europe on domestic and international tax issues. He is the author of many articles, including “Income and Indirect Tax Consequences of Inbound Cloud Computing Transactions,” 35 Tax Mgmt. Intl. Forum No. 4 (2014); “Transfer Pricing Audits,” 30 Tax Mgmt. Intl. Forum No. 4 (2009); "Centralization of Regional Management and Shared Services," 27 Tax Mgmt. Intl. Forum No. 1 (2006); "Too Much Ado About Something - The Proposed Regulations Governing Controlled Services Transactions," 33 Tax Mgmt. Intl. J. 67 (2004); "Squaring the Transfer Pricing Circle," 33 Tax Mgmt. Intl. J. 3 (2004); and "Control, Causality and Section 482," 28 Tax Mgmt. Intl. J. 403 (1999). 

Education:  University of California at Berkeley, J.D., 1977, Articles Editor for the Industrial Relations Law Journal; The George Washington University, B.A., 1971
Admissions: District of Columbia
Affiliations: Section of Taxation, American Bar Association; International Fiscal Association; State Bar of California; District of Columbia Bar; United States Supreme Court Bar Association.

 


John is a Principal in the International Tax group of Deloitte's Washington National Tax office. John has a sophisticated and broad-based international tax advisory practice. He advises clients in many industries on outbound and inbound international tax matters, focusing on planning and transactional matters. Before joining Deloitte, John was a partner in and the leader of the international tax practice of a large law firm. 

John is an adjunct professor of international tax at Georgetown University Law Center and regularly speaks on international tax matters. He received a BA in Mathematics and Economics and a JD from the University of Virginia and an LLM from Georgetown University Law Center. He is a member of the Illinois Bar Association and the Washington, DC Bar Association. 

 


Kristine Crabtree has worked on Subpart F and PFIC issues in the Internal Revenue Service’s Office of Chief Counsel since 2009.  She is currently a Senior Technical Reviewer in the Office of the Associate Chief Counsel (International) (ACCI) and co-leader of ACCI’s GILTI working group.  

Prior to joining the IRS, Ms. Crabtree spent several years in WilmerHale’s Boston and DC offices working on a wide range of tax matters.  Before her law career, Ms. Crabtree was a French instructor at Washington University in St. Louis, an English teacher and economist intern in Venezuela, and a high-tech recruiter in Austin, Texas.  

Ms. Crabtree holds a law degree from the University of Chicago, a Masters in Business Taxation from the University of Southern California, and a bachelor’s degree in French and Economics from Washington University in St. Louis.

 


Michele is a tax lawyer who employs her training and knowledge to help clients make the best business decisions and navigate many types of complex tax issues. During her years of practice, Michele has provided counsel in a wide range of transactions, from mergers and acquisitions, capital markets and securities offerings, to financing, joint ventures, and restructurings. In recent years, Michele's practice has evolved to include a strong focus on private equity and hedge funds and similar investment vehicles. She also has experience in, and has written extensively about, real estate investment trusts, and has advised many international clients on inbound U.S. real estate investments.

Publications 

  • “The Impact of Tax Reform on Real Estate Investment Trusts,” Bloomberg Tax, April 2018
  • "Tax Reform, Hollywood and the Media,” Law 360, April 2018
  • “Tax Reform is Hurting Foreign Investors in the US,” Law 360, March 2018
  • “A View From Silicon Valley: Tax Reform and the Tech Industry,” Law 360, March 2018
  • “Opportunities Abound for Private Equity, But So Do Risks,” Oil & Gas Financial Journal, January 2016

Education
Georgetown University Law Center, J.D.
1995 – cum laude

The College of New Jersey, B.A.
1992 – magna cum laude

Noteworthy
The Legal 500 United States, US Taxes: Non-Contentious, 2017

Affiliations

New York City Tax Club
New York State Bar Association, Tax Section

Bar Admissions
New York
New Jersey


Nicole Welch is the senior manager of the IRS’s Treaty Assistance and Interpretation Team (TAIT) and U.S. Territories program, which is responsible for all non-allocation interpretive matters and double-tax cases arising under U.S. tax treaties and coordination agreements with the U.S. territories. Since joining TAIT in 2012, Nicole has participated in negotiations under the mutual agreement procedure article of U.S. tax treaties, the IRS’s engagement in Organisation for Economic Co-operation and Development and Forum on Tax Administration committees, and the activities of LB&I’s Treaty and Exchange of Information practice networks. Before joining TAIT, Nicole represented clients in tax planning and controversy matters at a law firm in Washington, DC. Nicole graduated from The University of Chicago Law School and Georgetown University.


Pat is an International Tax Partner in KPMG’s Washington National Tax Practice, based in Stamford and New York.  He has over 25 years of experience advising clients on a broad array of U.S. international tax matters, with a special focus on cross border M&A.   For example, he assists clients in developing structures that provide for tax-efficient repatriation, foreign tax credit planning, acquisition financing and post-acquisition integration of acquired operations (e.g., out from under planning). 
Previously, Pat has been an in-house head of international tax planning and an international tax partner with a major NY law firm.  In these prior positions, Pat has focused on various aspects of international tax planning, including optimizing tax-efficiency of foreign and cross-border operations, investments/acquisitions and funding, with specific focus on cross border M&A planning.

Pat is the co-author of a leading International M&A tax treatise, “U.S. Taxation of International Mergers, Acquisitions, and Joint Ventures,” and has published articles in Journal of International Tax, International Tax Journal, and Tax Notes International. He has presented at the GWU/IRS Conference on International Taxation, the Canadian Tax Foundation, IFA, TEI, International Tax Institute, Atlas, and CITE.

Pat is a member of the International Fiscal Association.

Pat holds a JD degree from the University of Virginia Law School and a BA degree in economics from Haverford College.