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Basics of International Taxation 2021


Speaker(s): Arielle M. Borsos, Bradford E. LaBonte, Caren S. Shein, Catherine G. Schultz, Chadwick P. Rowland, Colleen O'Neill, Corey M. Goodman, D. Peter Merkel, Danielle E. Rolfes, Dr. Zach Pouga Tinhaga, Elizabeth J. Stevens, Elizabeth Nelson, Gary Scanlon, Greg A. Texley, James S.H. Null, Jeffrey P. Cowan, Jeremy Naylor, Joel S. Deuth, John D. Bates, John L. Harrington, John P. Warner, Kimberly T. Majure, Kristina Lynn Novak, Layla J. Asali, Marjorie A. Rollinson, Michael A. DiFronzo, Michele J. Alexander, Natalie Punchak, Ronald M. Gootzeit, Sarah E. Stein, Steven C. Wrappe, Tianlin (Laura) Shi
Recorded on: Jul. 20, 2021
PLI Program #: 304669

Danielle co-leads the international tax group within KPMG’s Washington National Tax office. She joined KPMG in 2017, following her tenure as the international tax counsel at the U.S. Department of the Treasury.

Danielle advises clients on U.S. international tax planning, policy, and controversy matters. In particular, she has extensive experience advising on issues related to international tax policy, tax treaties, the character and source of income, subpart F, foreign tax credits, and the regimes for  Global Intangible Low-Taxed Income, the Foreign-Derived Intangible Income, and the Base Erosion Anti-Abuse Tax.

Prior to joining KPMG, Danielle served as an executive in the Treasury Department’s office of tax policy. She joined Treasury as Deputy International Tax Counsel in 2011 and served as the International Tax Counsel from September 2012 through February 2017. As International Tax Counsel, Danielle led Treasury’s international tax legal staff, and was the principal legal adviser to the Assistant Secretary (Tax Policy) and the Deputy Assistant Secretary (International Tax Affairs) on all aspects of international tax policy, including the development and review of proposals for U.S. tax reform, the promulgation of regulations and administrative guidance regarding the U.S. taxation of cross-border income, the negotiation of tax treaties, and representing the United States in international organizations such as the organization of economic cooperation and development.

Danielle is a frequent speaker and writer on a variety of international tax topics. In addition to numerous articles, she is the author of An Analysis of FIN 48 – Accounting for Uncertain Income Tax Positions (Matthew Bender, 3d ed. 2009).


Tax attorney Michele Alexander employs her extensive knowledge and experience to help clients navigate complex tax issues that affect their bottom line. With a focus on private equity and hedge funds and similar investment vehicles, Michele is able to take her clients' multifaceted fund and tax matters, determine the best options and explain the process in an easy-to-understand manner.

Over the course of 25 years, Michele has firmly established herself as an effective and efficient transactional tax lawyer who advises on a wide range of transactions, including mergers and acquisitions, fund formations, capital markets, and securities offerings, financings, joint ventures, and restructurings, with a dedicated focus on their tax implications. 

Michele also advises on real estate investment trusts, including guiding many international clients on inbound U.S. real estate investments. She is a frequent author on tax and other topics of interest to investors.

Clients count on Michele for her meticulousness and responsiveness. Michele's ultimate goal is to propose practical solutions that will help solve her clients' issues.

She has been recognized for her work by being named to the New York Super Lawyers list (2019-2020), in the Euromoney Institutional Investor PLC, the IFLR1000 Financial & Corporate Guide (2019-2020), The Legal 500 United States (2017-2019), and as a Go-To Thought Leader in Tax Law by the National Law Review (2018).

A cum laude graduate of Georgetown University Law Center and a magna cum laude graduate of The College of New Jersey, Michele is admitted to practice in New York and New Jersey.

Michele has served as president of the New York City Tax Club and is a member of the New York State Bar Association Tax Section.


Arielle Borsos is an Attorney in Branch 4 of the IRS, Office of Associate Chief Counsel (International).  Prior to joining the IRS, she was an associate at Caplin & Drysdale, Chartered in Washington, D.C.  Arielle earned her J.D. and LL.M. from New York University and her B.A. from Washington University in St. Louis.


Bradford E. LaBonte is a tax partner in the New York office of McDermott Will & Emery LLP.  His practice focuses on cross-border mergers and acquisitions, dispositions, and internal restructurings, as well as matters relating to international tax issues, including the foreign tax credit, subpart F income and global intangible low-taxed income, and tax treaties.  He also regularly advises on financings and capital markets transactions. 

Bradford received his B.A. from New York University, his J.D. from the University of California – Berkeley School of Law, and his LL.M (Taxation) from the New York University School of Law.


Caren Shein is a managing director in Deloitte’s Washington National Tax Office with over 30 years of international tax experience. Caren advises clients on outbound and inbound international tax planning and compliance issues, including foreign tax credit, subpart F, expense allocation, and permanent establishment.  Her particular areas of expertise are the foreign tax credit and expense allocation, and she regularly writes, speaks and teaches in these areas.

Caren joined Deloitte from the National Office of another Big Four accounting firm, where she worked for 19 years.  Prior to that, Caren was an attorney in the IRS Office of Associate Chief Counsel (International).  Caren began her career as an attorney advisor to the Honorable B. John Williams, Jr. of the United States Tax Court.

Caren holds a B.A. from Yale University, J.D. from the American University, Washington College of Law, and M.L.T. from Georgetown University Law Center.  She is a member of the American Bar Association and the District of Columbia Bar Association.

 


Catherine Schultz is Vice President, Tax and Fiscal Affairs for the Business Roundtable, where she is responsible for tax and advocacy efforts that promote U.S. economic growth, competitiveness and job creation.

Before joining the Business Roundtable, Catherine was the Vice President for Tax Policy at the National Foreign Trade Council for almost 15 years.   She was deeply involved in the OECD work on the Base Erosion and Profit Shifting (BEPS) Project, and the work on the taxation of the digital economy.   She is a U.S. representative to the OECD on the WP9 Technical Advisory Group on the taxation of cross-border services under the VAT.   She was also involved in EU and UN tax committee issues that would directly affect the competitiveness of U.S. companies, including the taxation of digital services, withholding taxes based on companies’ gross receipts, and leading the opposition to the public release of country-by-country reporting information.  Schultz was responsible for working with the U.S. Treasury Department and the IRS on regulatory and tax treaty issues. 

Prior to joining the National Foreign Trade Council, Schultz was a principle at Capitol Strategies Group where she represented clients on a variety of tax issues including FSC/ETI issues and the JOBS Act passed by Congress in 2004. 

Earlier in her career, Catherine was a Tax Director at WorldCom and was the lead federal tax advocate for the company’s priorities including the extension of the R&D tax credit, income sourcing rules and tax reform.    Schultz also was an advocate for state tax changes that would benefit the telecommunications industry.   Schultz was also part of the Tax Policy team at the law firm of Miller & Chevalier for 11 years, including work on the Tax Reform Act of 1986.

Schultz is a mentor in the Political Science Department at the Pennsylvania State University and is an active member and past Chair of the Tax Coalition.

A native of Pittsburgh, Pennsylvania, Catherine earned her bachelor’s degree from the Pennsylvania State University, studied economics at the University of Exeter, England, and attended graduate school at the University of Pennsylvania. 


Chadwick Rowland is an Attorney in the Office of Associate Chief Counsel (International), Branch 4.  He specializes in issues generally related to cross-border acquisitions and other restructurings, certain cross-border transactions involving partnerships, and repatriations.  He has been an attorney with Branch 4 since 2018 and served as a summer intern with Branch 4 in 2017. 

Mr. Rowland received his Juris Doctor, magna cum laude, from Georgia State University College of Law and his Bachelor of Arts degree in finance from the University of Alabama.  Mr. Rowland is admitted to the State Bar of Georgia.


Colleen is a 25 year veteran of EY and the Director of EY’s National Tax Department International Tax and Transaction Services practice. She leads a group of world class professionals who advise on tax-efficient global structures and US taxation of cross-border transactions, including financing, acquisition, disposition, reorganization, integration, repatriation, supply chain matters, and foreign tax credit planning.

Colleen holds a Bachelor of Arts in Accounting and a Master of Business Administration in Taxation. She received a Juris Doctor, with honors, from the Georgetown University Law Center. She is a certified public accountant licensed in the state of New York and a member of the New York State Bar Association. She is a frequent speaker on international tax developments at various conferences.

Colleen is on the board of the International Tax Institute and is on the International Fiscal Association New York Region Steering Committee.

 

Representative Publications

Co-author of “Biden’s Offshoring Tax Penalty: Why Take Your Best Players Off the Field?”

Co-author of “Final Section 909 Regulations: Modifications, Clarifications and Open Questions”

Co-author of “Headed for the Brexit: How to Keep Calm and Carry on with US Treaty Benefits”


Corey Goodman 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, spin-offs, bankruptcy reorganizations, refinancings, cross-border and internal restructurings, and securitization transactions.


D. Peter Merkel is the Branch Chief for Branch 5 of the IRS, Office of Associate Chief Counsel (International).  Prior to joining Branch 5, he was an associate at Cadwalader, Wickersham & Taft in Washington, DC, where he focused on cross-border financial products and the tax aspects of investment funds.  Peter earned his B.A. in public policy from Hamilton College, J.D. from American University, and LL.M. from New York University.  After attending NYU, Peter served as law clerk to the Honorable Robert P. Ruwe at the United States Tax Court. 


Elizabeth Nelson is a Partner in International Tax Services in the Washington National Tax Services office of PricewaterhouseCoopers LLP. 

Elizabeth primarily specializes in outbound international taxation. 

Elizabeth has a broad background in international tax, however, her areas of expertise include dual consolidated losses, foreign tax credit (FTC) limitation matters and other FTC matters, and gain recognition agreements. 

Elizabeth is a C.P.A. and has a Masters in Taxation from the University of Texas at Austin.


Elizabeth Stevens is a Member at Caplin & Drysdale, where her practice centers on transfer pricing and international tax planning and advocacy for corporate clients. In addition to advising on transfer pricing planning, documentation, and compliance, Ms. Stevens regularly represents companies in the negotiation of Advance Pricing Agreements and in Mutual Agreement Procedure cases. In the broader international tax context, Ms. Stevens assists clients in the structuring of U.S. inbound and outbound investment and business activities and cross-border transactions. She also frequently advises on income tax treaty issues.

A recent focus of Ms. Stevens’ practice has been advice on the implications for particular business models of particular elements of the 2017 U.S. tax reform, including the base erosion and anti-abuse tax (BEAT), the global intangible low-taxed income (GILTI) regime, changes to the foreign tax credit, and the foreign-derived intangible income (FDII) regime.


Gary is a Principal in the International Tax Group within KPMG’s Washington National Tax office.  Gary joined KPMG in August 2019, following his tenure as an attorney-advisor in the Office of the International Tax Counsel at the U.S. Department of the Treasury.

Gary advises clients on U.S. international tax matters, including tax planning with respect to their structures, operations, and transactions.  In particular, he has extensive experience advising on issues relating to disposition and acquisition planning.  More recently, he has focused on helping clients navigate U.S. tax reform, in particular the regimes for Global Intangible Low-Taxed Income (GILTI) and Foreign-Derived Intangible Income (FDII).  In addition to his work at KPMG, Gary teaches a course on Advanced International Taxation for the Graduate Tax Program at Georgetown University.

Prior to joining KPMG, Gary served as an attorney-advisor in the Treasury Department’s Office of Tax Policy from June 2016 until August 2019.  At Treasury, Gary developed and drafted regulations under section 385, regulations implementing the exception for qualified foreign pension funds under the Foreign Investment Real Property Act (FIRPTA), and the notice addressing “Killer B” transactions.  After enactment of the Tax Cuts and Jobs Act (TCJA), Gary also developed and drafted several regulations implementing U.S. tax reform, including regulations implementing the Transition Tax, GILTI, and FDII.  He also represented the United States at the OECD Forum on Harmful Tax Practices (FHTP), including defending the FDII regime at the FHTP.

Prior to joining Treasury, Gary was a senior manager at Ernst & Young, where he advised multinational corporations on international tax planning, with an emphasis on cross-border M&A, repatriation, inversions, post-merger integration, cross-border spins, acquisitions and dispositions, and attribute planning.


Greg Texley is an International Tax Law Specialist for the Treaty Assistance and Interpretation Team (“TAIT”), which is part of the Advance Pricing and Mutual Agreement Program (“APMA”).  These functions are part of the U.S. competent authority office at the IRS.  

Greg’s current responsibilities include advising IRS and other U.S. agency personnel in litigation and administrative proceedings, such as cases arising under U.S. income tax treaties; counseling TAIT and others within APMA, and other IRS management and executives, on technical and strategic issues; and working cross-divisionally within the IRS to implement compliance initiatives.

He has participated in treaty negotiations with U.S. treaty partners, and policy deliberations and technical discussions related to the 2016 U.S. model income tax treaty.  He has also acted as an expert witness in a federal district court case (D.C. Circuit) concerning a foreign company’s purported eligibility for U.S. treaty benefits.

His current areas of expertise include determining whether U.S. and foreign taxpayers are entitled to U.S. tax treaty benefits by analyzing limitation on benefits, residency questions, and beneficial ownership issues, and determining the effects such determinations have on taxpayer compliance obligations, such as treaty disclosures reported on Forms W-8BEN, 8833, and 1120-F. 

In addition to treaty matters, Greg has extensive experience in many other areas of international tax, such as the U.S. foreign tax credit, income derived from U.S. real property, entity classification and fiscal transparency rules, and Subpart F income.  He also focuses on select areas of tax practice and procedure, including the filing and review of protective claims and compliance issues related to implementation of U.S. competent authority determinations. 

Before joining the government in 2009, Greg worked in public accounting at both Big Four and middle market CPA firms.  Greg is a CPA (inactive), and has a Bachelor of Science degree in Accountancy from Oakland University in 2000; a Juris Doctorate degree from University of Detroit Mercy School of Law in 2006; and a Master of Laws in Taxation from Wayne State University Law School in 2008. 


James “Jamie” Null is a leading tax lawyer with nearly fifteen years of experience advising on U.S. federal tax matters, including transactional tax issues associated with U.S. inbound and outbound investments, as well as domestic and international tax planning for individual, corporate and partnership transactions. He also advises on private equity investments and structures, and on domestic and cross-border mergers and acquisitions.

Jamie’s diverse practice spans a range of industries, including real estate, entertainment, media, biotechnology, alternative energy, hospitality, transportation and technology. In particular, he has substantial experience with regard to real estate-related transactions, including sophisticated like-kind exchanges involving domestic and foreign interest holders. Jamie also works frequently in the media and entertainment sector, advising U.S. and non-U.S. entertainment clients on the production and talent side on U.S. and international entertainment investments and joint ventures, productions and events. 


Jeffrey Cowan is an attorney in Branch 3 of the Office of the Associate Chief Counsel (International), Internal Revenue Service.  Before joining the Office of Chief Counsel in 2006, he worked in the international tax department at the national office of an accounting firm for five years. 


Jeremy Naylor is a partner in the Tax Department and a member of the Private Funds Group. Jeremy works with fund sponsors across asset classes, and their investors, in all tax aspects private investment fund matters.

In addition, Jeremy works with his fund sponsor clients in designing and implementing carried interest plans and other compensation arrangements for the general partners of private funds.

Jeremy also advises U.S. and non-U.S. institutional investors, governmental investors, pension trusts and other tax-exempt organizations in their investments in private funds and joint ventures.

He also frequently represents secondary fund managers in connection with the tax aspects of their business, including fund formation, secondary transactions (including restructurings and private tender offers), primary investments and co- investments.

Jeremy has significant experience structuring inbound investment in U.S. real estate by non-U.S. investors. In addition, Jeremy has significant experience in structuring domestic and cross-border mergers and acquisitions, advising on capital markets transactions and equity compensation arrangements.

Jeremy is a frequent speaker at industry conferences related to private investment funds, including the Merrill Lynch Private Equity and Venture Capital CFO Conference and the Practising Law Institute's series on international tax. In addition, Jeremy frequently participates in webinars and provides other thought leadership in print media related to changes in the tax laws and their impact on private fund managers.

 

Education

Northeastern University School of Law, J.D., 1999 Boston University, B.A., 1994

 

Admissions & Qualifications

New York

 

Awards & Recognition

The Legal 500 United States: Securities: Tax: International Tax 2019

The Legal 500 United States: Securities: Tax: U.S. Taxes: Non-Contentious 2019

 


Joel Deuth is the Assistant to the Branch Chief for Branch 5 of the IRS, Office of Associate Chief Counsel (International).  Prior to joining Branch 5, he was an associate at Arnold & Porter in Washington, DC.  Joel earned his JD from Catholic University in Washington, DC, during which he also worked at the Washington National Tax Office of Deloitte Tax LLP.


John Bates is a Principal in the in the Washington National Tax office and a member of the International Tax Services group. 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.

Mr. Bates is a member of the Illinois Bar Association and the Washington, DC Bar Association.

 

 


John L. Harrington is a co-leader of Dentons’ US and global 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 Warner is a shareholder of Buchanan Ingersoll & Rooney, P.C., where he has served as Chair of its Advisory Committee and Co-Managing Shareholder of its Washington, D.C. office. He is a graduate of the University of California, Berkeley School of Law, where he was the Articles Editor of the Industrial Relations Law Journal.  John has more than 40 years of experience in domestic and international federal income tax and business planning, including transfer pricing, the structuring of business formations, joint ventures and mergers and other domestic and cross-border business acquisitions and dispositions. He has represented numerous clients in tax controversy matters, including IRS Appeals Office cases, National Office rulings and competent authority proceedings and the resolution of transfer pricing disputes. 

John 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 authored an amicus brief in Indianapolis Power & Light Co. v. Commissioner, 493 U.S. 203 (1990).  He is a co-author and original editor of the Tax Management Transfer Pricing Portfolio Series, and author of numerous articles, including “Income and Indirect Tax Consequences of Cash Pooling Arrangements,” 37 Tax Mgmt. Intl. Forum 91 (2016), “Income and Indirect Tax Consequences of Inbound Cloud Computing Transactions,” 35 Tax Mgmt. Intl. Forum 120 (2014), "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). John served as Vice Chair of the Transfer Pricing Committee of the American Bar Association Section on Taxation from 2004-2008 and Chair of the Committee in 2008-2010.

 


Kristina Novak is an attorney in Branch 6 of the Office of the Associate Chief Counsel (International) at the IRS.  Branch 6 has primary jurisdiction over international transfer pricing matters as well as a number of other practice areas.  Prior to joining the Office of the Associate Chief Counsel (International), Ms. Novak was in the Dallas office of McDermott Will & Emery where she worked on a wide range of tax planning and tax controversy matters.  Ms. Novak holds an LL.M. in Taxation from New York University School of Law and obtained her law degree from George Mason University School of Law.


Laura Shi is an Attorney in the IRS Office of Associate Chief Counsel (International) (ACCI), Branch 3, where she works on guidance and provides advice in audit and litigation matters involving foreign tax credit issues. She was one of the principal drafters of the proposed regulations relating to the foreign tax credit published in November 2020. She previously worked in Branch 1 of ACCI and has experience in matters involving treaty interpretation, expatriation, foreign trusts, and the anti-hybrid provisions.   

Ms. Shi received her J.D., with a specialization in taxation, from the University of California, Los Angeles School of Law and her B.A. from the University of California, Berkeley.


Layla J. Asali practices in a broad range of federal income tax matters, with an emphasis on the taxation of cross-border transactions and business activities. She advises U.S.-based and foreign-based multinational clients on international tax issues, including mergers and acquisitions, intellectual property transactions, supply chain planning, and financings.

Since the passage of the Tax Cuts and Jobs Act of 2017 (TCJA), a significant portion of Layla's practice has involved advising clients on the new international tax provisions of the tax reform legislation, including the base erosion and anti-abuse tax (BEAT), the section 965 transition tax, the global intangible low-taxed income (GILTI) regime, foreign tax credits, and the deduction for foreign-derived intangible income (FDII).

In addition to her consulting practice, Layla has experience representing clients before the Internal Revenue Service (IRS) National Office in obtaining favorable private letter rulings and resolving federal income tax controversies at the audit level and at IRS Appeals. She has also represented clients before the U.S. Department of the Treasury on regulatory and policy matters.

Layla is a frequently sought speaker on international tax matters and is an emerging authority on the international tax provisions of the Tax Cuts and Jobs Act. She has published articles in journals, including BNA Tax Management International Journal, BNA Tax Management Memorandum, the CCH International Tax Journal, and Tax Notes International. Layla is the former Chair of the DC Bar Taxation Community and she currently serves as a Member of the Taxation Community's Steering Committee. She has twice been named one of International Tax Review's Women in Tax (2016-2017).

 


Marjorie Rollinson is the National Tax Deputy Leader.

Prior to re-joining Ernst & Young LLP in 2019, Marjorie served as the Associate Chief Counsel (International) at the Internal Revenue Service.  As Associate Chief Counsel (International), Marjorie oversaw an office of more than 90 attorneys and other professionals responsible for legal advice, guidance, and support to the IRS, Treasury, IRS Appeals, the Department of Justice, and the public on international tax issues in all procedural postures.  Upon leaving the Office of Chief Counsel, she received the Chief Counsel Distinguished Service Award, the Office of the Chief Counsel’s highest honor.

Prior to joining the IRS in 2013, Marjorie was a principal in EY’s National Tax Department where she was the National Director of International Tax Services – Technical and co-chaired the International Tax Technical Committee. 

 


Michael A. DiFronzo serves as a Principal in and leader of the International Tax Services group in the Washington National Tax Office of PwC.  In that role, Michael serves as a global resource for the firm’s international tax practice.  His practice includes all aspects of international taxation, with a particular focus on international mergers, acquisitions and restructurings and the U.S. anti-deferral rules.  He also works closely with U.S. and non-U.S. based multinationals on cross-border financing, cash repatriation and other planning issues.  

Before joining PwC, Michael was a senior executive in the U.S. Treasury Department.  He worked for the Office of Chief Counsel, Internal Revenue Service as the Deputy Associate Chief Counsel (International – Technical).  In that capacity, he had primary responsibility for the oversight of published guidance related to the taxation of cross-border investment and related issues.  Michael served in that role from 2006 - 2010.

Prior to joining the Office of Chief Counsel, Internal Revenue Service, Michael served as a partner in the Tax Department of McDermott Will & Emery LLP in Chicago, Illinois.  There he served as an international tax attorney for large U.S. and non-U.S. multinational corporations.  Michael’s work experience also includes the National Tax Office of Deloitte & Touche LLP and the Washington, DC office of Weil Gotshal & Manges LLP.

Michael received an LL.M. in taxation from New York University School of Law, a J.D. from University of Montana School of Law, and a B.S. in Accounting from Montana State University.  Michael served on the Board of International Tax Advisors and as a guest lecturer for New York University School of Law’s graduate tax program from 1999 - 2010.   Michael also served on the Board of Visitors for the University of Montana School of Law from 2006 - 2011.

Michael’s professional affiliations include the tax sections of the American Bar Association and the DC Bar Association, as well as the International Fiscal Association.  He is the author of numerous articles on cross-border tax issues and a frequent speaker.  Michael is currently a member of the District of Columbia, Illinois, Montana and Nevada bar associations and is admitted to practice before the United States Tax Court.  He is also licensed as a CPA.


Natalie Punchak is a senior counsel in the Office of Associate Chief Counsel (International), Branch 2, where she works on issues relating to subpart F, GILTI, PFICs, country-by-country reporting, accounting method changes of CFCs, and section 965.  Before joining the government, Ms. Punchak was a tax associate in the Washington, D.C. office of Caplin & Drysdale, Chartered.  She holds a J.D. from the University of Pennsylvania Law School, a certificate in Business Economics from Wharton Business School, a Master of Public Policy from the University of Oxford, and a B.A. from Georgetown University.


Ronald M. Gootzeit is an Attorney in Branch 4 of the Office Associate Chief Counsel (International) at the Internal Revenue Service where he primarily works on cross-border partnership, check-the box, and information reporting issues.  He has previously worked in private practice (at an accounting and a law firm) and as an attorney advisor at the United States Tax Court, in addition to the Office of Associate Chief Counsel (Passthroughs and Special Industries).  Mr. Gootzeit earned a B.S. in Accountancy from the University of Illinois, a J.D. from the University of Illinois, and an LL.M. from Boston University. 


Sarah Stein is an Attorney with the Office of Associate Chief Counsel (International), Branch 1, located in Washington, DC. She focuses on a variety of subjects, including income tax treaty interpretation, cross-border compensation and pension issues, cross-border individual issues, expatriation, and taxation of foreign trusts and estates.  

Ms. Stein joined the Office of Chief Counsel in 2020. Prior to joining the IRS, she practiced international tax at global law firms, based both in New York and Switzerland, with a focus on inbound and outbound investment considerations, FATCA issues, and advising Swiss and other non-U.S. financial institutions on tax reporting and compliance considerations in light of the Swiss Bank Program and other DOJ enforcement actions.

Ms. Stein has an A.B. from Dartmouth College, and a J.D. and LL.M. in Taxation from New York University School of Law.


Steve is Grant Thornton’s Transfer Pricing Technical Leader in its Washington National Tax Office.

Steve is a globally-recognized transfer pricing expert, with over 25 years of experience in transfer pricing planning, compliance and controversy for large multinational clients. During that time, he has been a Senior Attorney with the IRS Advance Pricing Agreement (APA) Program, a partner with a global law firm, and the transfer pricing controversy practice leader at Big Four Firms.

Steve’s extensive transfer pricing controversy experience covers examinations, Appeals, and alternative dispute resolution, but his main focus has been APAs and the mutual agreement procedure (MAP). With experience in well over 200 APAs and MAP, Steve is the most experienced negotiator of transfer pricing issues at any firm. He has negotiated APAs and MAP agreements across all industries and involving over fifteen countries. Steve also negotiated the first coordinated Customs ruling/bilateral APA.

 

Presentations & publications

Based upon his extensive client experience, Steve has written the leading U.S. transfer pricing treatise withMarc Levey (Baker McKenzie): Transfer Pricing: Rules, Compliance and Controversy, Wolters Kluwer/CCH (5th Ed., 2019); this treatise is used in multiple tax programs.

Steve has written over 100 articles on various transfer pricing topics, including:

  • How Tariffs Affect Transfer Pricing And What Companies Are Doing, 164 Tax Notes Federal 1701 (9/9/19) (with co-author).
  • U.S.-Japan APAs Remain Valuable to Japan-based Multinationals, 27 Transfer Pricing Report, 9/20/18 (with co-authors).
  • It’s the End of the World as We Know it—OECD Looks at Taxing Digital Profits, DTR:Intl. 9/3/2019.
  • It Ain’t Over Till It’s Over: Federal Tax Implications of Implementing a Sustained Transfer Pricing Adjustment, 23 Tax Mgt. Transfer Pricing Special Report, 872, 10/29/14 (with co-authors).

 

Education

New York University School of Law, LL.M.

University of Texas School of Law, J.D.

University of Notre Dame, B.B.A. (Accounting)


Zach has been ranked in the prestigious Top 40 Under 40 list of the American Bar Association, and has been recognized as Nation's Best Advocates, Top 40 Under 40 by the National Bar Association.

As Principal at EY, Zach’s practice focuses on the international aspects of United States taxation. He regularly advises clients on tax aspects of their cross-border transactions, both outbound and inbound into the United States. He has deep experience in various areas including principally mergers and acquisitions, financial services, financial markets and financial products, and expanding into new markets globally. Zach has served as an expert for capacity building trainings organized by the African Union, throughout the continent, on the most pressing and complex issues in the international tax field.

Zach holds a Doctorate in international tax policy from the University of Michigan; an international tax LL.M. from Michigan law school; a corporate and finance LL.M. from Wayne State University law school; and a LL.B. and Master of laws from the University of Douala. Prior to joining EY, Zach was part of the New York based international tax group of an international law firm.

 


Based in the DC office of Washington National Tax, Kim served as KPMG’s Inbound Tax Leader for 4 years and is the Tax Industry Lead for US International Corridors. In this role, she advises clients on inbound and outbound / “sandwich” international tax planning and controversy issues, including BEAT and other Tax Reform issues, cross border payments and withholding, information reporting and transparency issues, and inbound investment planning. Kim has also served as KPMG’s national leader on FATCA for Non-Financial Industries, BEPS Country-by-Country reporting, and Mandatory Disclosure Regimes. Kim currently serves as the Tax Lead for KPMG’s Legal Operations Transformation Services practice in the United States.

Kim was an adjunct professor with the Georgetown University Law Center for 11 years, teaching a mix of international tax classes for Georgetown’s LL.M. program, including an advanced international tax seminar and a cross-border tax controversy workshop. Kim is an instructor for the Practising Law Institute, teaching regular sessions on inbound taxation and BEAT. Kim regularly writes and speaks outside of the academic setting. She is a featured speaker on Tax Reform, Inbound issues, and cross-border information reporting, at the Tax Executives Institute Audit & Appeals Seminar, Annual Conference, Mid-Year Conference, and European workshops (2011 through present). 

Kim is the lead author on an annual periodical, “Select U.S. Federal Income Tax Consequences in European Joint Venture,” for PLI’s Tax Planning for Domestic & Foreign Partnerships, LLCs, Joint Ventures, & Other Strategic Alliances (2006-present).  Kim serves on the GW-IRS International Tax Conference Advisory Board and is a regular moderator and panelist for conference sessions.  A former chair of the ABA Tax Section Committee on Foreign Activities of U.S. Taxpayers, Kim led the Tax Section’s working groups on BEAT, FDII, and Cloud Taxation.