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Basics of International Taxation 2017 San Francisco

Speaker(s): Andrea Sharetta, Candace B. Ewell, Corey M. Goodman, David L. Forst, E. Ray Beeman, Ethan A. Atticks, Frank (Chip) W. Dunham III, James S.H. Null, Janice A. Mays, Jeremy Naylor, John D. Bates, John L. Harrington, José E. Murillo, Josh O. Ungerman, Justin E. Jesse, Karen J. Cate, Linda E. Carlisle, Matthew M. Chen, Melody H. Leung, Narendra Acharya, Neal M. Kochman, Philip B. Wright, Robert M. Temin
Recorded on: Sep. 18, 2017
PLI Program #: 186537

Ethan Atticks is an International Tax Services Managing Director in the Washington National Tax Services office of PwC where he specializes in outbound international tax issues with a focus on the U.S. anti-deferral regimes of subpart F and PFIC.  Before joining PwC, Mr. Atticks was an attorney and a Senior Technical Reviewer in Branch 2 of the Associate Chief Counsel (International) ("ACCI"), which has subject matter jurisdiction over the subpart F and PFIC regimes.  While serving as Senior Technical Reviewer of Branch 2, Mr. Atticks was the primary subject matter specialist and reviewer in ACCI on PFIC matters as well as the principal drafter or reviewer of a number of significant subpart F guidance projects. 

During his tenure in Branch 2, Mr. Atticks participated in the issuance of a number of pieces of PFIC guidance, such as TAM 200733024 (applying section 1298(b)(5) to trust beneficiaries); PLRs 200604020, 200813036, and 200943004 (addressing look-through issues under sections 1297(c) and 1298(b)(3)); PLR 200838003 (addressing the application of the PFIC rules to a multi-tiered structure); and PLR 200943004 (applying section 1297(d) CFC/PFIC overlap to partners in a domestic partnership). 

In addition, Mr. Atticks served as the principal drafter of significant pieces of subpart F guidance including final, temporary, and proposed regulations addressing foreign base company sales income ("FBCSI"); Notice 2007-13 addressing foreign base company services income; and proposed regulations addressing previously taxed income under sections 959 and 961.  He also participated in the issuance of the three FBCSI tax rate disparity PLRs (PLRs 200942034, 200945036, and 201002024).

Prior to joining ACCI, Mr. Atticks was a tax associate in the Washington, D.C. office of Dow, Lohnes & Albertson PLLC.  Mr. Atticks received an LL.M. in taxation from Georgetown University Law Center, a J.D. from the University of Virginia School of Law, and a B.A. in philosophy from the College of William and Mary.

Bob Temin is a partner in the Atlanta tax practice of Rödl Langford de Kock LP, the US affiliate of Rödl & Partner, the sixth largest accounting firm in Germany, based in Nuremberg.  Mr. Temin’s practice focuses on international tax planning and compliance for individuals and entities engaged in outbound and inbound investments, including Subpart F, E&P determinations, and international IRS controversies.  Mr. Temin represents and supports several large, closely held multinational enterprises and their owners in their U.S. and international tax compliance efforts.

Prior to joining Rödl Langford de Kock LP, Mr. Temin led the international tax practice in the Atlanta office of a major international accounting firm.  Mr. Temin was the lead tax and accounting consultant to the U.S. government’s Resolution Trust Corporation (“RTC”) in the RTC’s renegotiation of the largest assistance agreements then existing between the former FSLIC and two major thrift holding companies.  Mr. Temin also led a team of professionals assisting the RTC and the FBI in the forensic investigation of a large Denver-based thrift institution.

Mr. Temin received a Master of Accountancy with a Tax Emphasis degree from the University of Georgia and a Bachelor of Science in Business Administration from the University of North Carolina – Chapel Hill.

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.

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. 

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.



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


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.

José Murillo assumed his position as Deputy Assistant Secretary, International Tax Affairs, in the U.S. Treasury Department’s Office of Tax Policy on March 1, 2021. In his role as DAS, International Tax Affairs, José provides advice and counsel to the Assistant Secretary (Tax Policy) related to international tax policy and tax treaties.

Prior to assuming his current role, José was a partner and the leader of the international tax and transaction services practice in Ernst & Young LLP’s (EY) National Tax Department based in Washington, D.C.  José’s practice focused primarily on cross-border acquisitions, dispositions, and restructurings, and most recently he led EY’s initiatives around the 2017 Tax Cut and Jobs Act.

Prior to rejoining EY in August 2010, José spent approximately three years with the US Treasury Department’s Office of the International Tax Counsel, where he assisted in the development of international tax policy, Treasury regulations, and in negotiating income tax treaties.

Prior to joining the U.S. Treasury Department in 2007, José was a member of EY international tax services practices in Houston and Washington, DC.

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.

Melody Leung is a Principal with EY’s Transfer Pricing practice with a background in transfer pricing and corporate finance. Melody is the Southern California Transfer Pricing Market Leader and West Region Operating Model Effectiveness Co-Leader. Melody’s technical training is in the tax areas of transfer pricing, valuations and economic impact studies. Her transfer pricing experience includes planning, intellectual property migration, global documentation, litigation support, Accounting Standards Codification 740, transactions due diligence and Advance Pricing Agreements (APAs).

Melody brings a well-rounded portfolio of work, having served clients in the logistics, mining and processing, metals, electronic component, media & entertainment, and technology industries.

Melody’s clients include US and foreign multinationals, several of which are Fortune 100 companies. Melody is a frequent speaker on transfer pricing issues, most recently as part of the Practicing Law Institute’s Basics of International Taxation series.

•  Prior to joining EY, Melody worked in the Financial Planning & Analysis group at General Electric’s Healthcare division in Beijing, China. She is proficient in Mandarin and Cantonese Chinese.

•  Melody received her MBA degree from University of California, Los Angeles, with academic distinction and her BA degree from the University of California, Berkeley, with honors.

Narendra Acharya is a partner in the Chicago office of Baker & McKenzie LLP and a member of the Firm's Global Equity Services group.  He focuses his practice on matters relating to US and international employee benefits and executive compensation — including global stock plans and pensions, as well as matters pertaining to pensions, executive compensation and employment issues in mergers and acquisitions. Mr. Acharya has particular expertise dealing with cross-border compensation issues, including issues raised in corporate reorganizations and inversion transactions.  Mr. Acharya has been selected as a BTI Client Service All Star, which recognizes “innovative attorneys who are leveraging market changes to stand out with corporate counsel and deliver superior client service.”

Mr. Acharya assists US and non-US companies – both publicly traded and private – in the design and implementation of employee stock plans. He has extensive experience advising clients on income tax, social security, payroll withholding and reporting, local corporate tax deduction, employment law, securities and other regulatory issues applicable to equity awards in numerous jurisdictions. Mr. Acharya advises companies on the application of deferred compensation rules under Code Sections 409A and 457A, as well as a broad range of tax and compensation issues related to international mobile employees.

Mr. Acharya is a graduate of Cornell Law School and is licensed to practice in the States of New York and Illinois.  In addition, Mr. Acharya is also a Chartered Accountant (Province of Ontario, Canada).

Philip B. Wright is a Partner in the law firm of Bryan Cave Leighton Paisner LLP and is a member and co-leader of the Tax Advice and Controversy Practice 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 has taught Partnership Taxation and Mergers and Acquisitions Taxation.  He has served as an adjunct professor in the Masters Tax Program at Washington University School of Law.  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.

Ray Beeman is co-leader of EY’s Washington Council Ernst & Young practice, where he provides clients with strategic advice and representation on issues and developments involving tax and budget policy.

Prior to joining EY, Ray was Tax Counsel and Special Advisor for Tax Reform with the US House Committee on Ways and Means, where he helped guide the development of the Tax Reform Act of 2014, a comprehensive tax reform plan proposed by Chairman Dave Camp (R-MI).  Ray also has served Congress as Legislation Counsel for the Joint Committee on Taxation, where he was involved in several tax legislative proposals that were passed by Congress and signed into law by the President, including the American Jobs Creation Act of 2004.  In addition, Ray played a significant role at JCT in the ratification of income tax treaties by the US Senate and the development of tax policy reports to Congress relating to tax simplification and the investigation of the Enron Corporation.  These reports included several tax legislative recommendations that later were enacted into law.

Ray began his Washington career with the National Tax Department of Ernst & Young, where he was a member of the Financial Services Industry practice group.  Ray has taught the taxation of debt instruments as an adjunct member of the faculty at the Georgetown University Law Center.

Ray is a graduate of the University of California at Berkeley and received a J.D. from the Pepperdine University School of Law, as well as an LL.M. in taxation from the Boston University School of Law.  Ray is a member of the State Bar of California and the DC Bar.

Candace is a Principal with PwC's Washington National Tax Services Practice, where she leads a group of information reporting and withholding specialists.  Since joining the firm in 2007, Candace has worked with financial and nonfinancial sector clients to remediate information reporting and withholding compliance failures.  Currently, Candace is a key member of PwC's global FATCA team and is engaged on several large projects.

Candace has been a frequent speaker on information reporting matters and is the primary author of thought leadership pieces that cover a range of information reporting topics which include the Foreign Account Tax Compliance Act (FATCA), as well as other current issues.  Candace has worked with several clients to ensure accurate information reporting compliance and the remediation of various compliance failures.  In addition to traditional information reporting Candace advises and is currently engaged to assist clients on foreign bank account reporting (FBAR). She is a former member of the IRS Information Reporting Program Advisory Committee (IRPAC).  Candace has worked with the IRS through IRPAC to resolve regulatory issues related to the FATCA, 6050W and other information reporting requirements.

Prior to joining PwC, Candace served two years as Assistant Chief Counsel for tax matters at the U.S. Small Business Administration (SBA). In that role, Candace worked extensively with IRS and Treasury personnel, trade associations, and congressional staff to ensure that the views of small businesses where considered in the regulatory and legislative process.  Prior to joining the SBA, Candace spent four years as an Attorney Advisor in the IRS Office of Associate Chief Counsel (Corporate), focused on corporate tax issues.

Mr. Kochman's practice focuses on international tax planning, taxation of settlements, and bankruptcy tax matters. His experience covers a broad range of international, domestic, and state tax issues associated with transfer pricing, foreign tax credit planning, corporate restructurings, qualified settlement funds, and withholding and reporting.

Mr. Kochman regularly advises clients on tax controversy matters, providing assistance during tax audits and representation in IRS Appeals proceedings, as well as in technical advice and ruling requests to the IRS National Office. He has represented U.S. multinational companies and U.S. subsidiaries of Belgian, German, Swedish and other foreign parents in advance pricing agreement and competent authority negotiations. Representative engagements include:

  • Achieving a favorable Appeals settlement for a foreign auto manufacturer in a multi-year transfer pricing case
  • Successfully representing 300 plus individuals in refund claims related to taxation of settlement fund distributions
  • Developing a transfer pricing policy and negotiating an APA for a foreign financial services company
  • Advising a U.S. multinational on intangible valuation, transfer, and cost sharing issues in conjunction with a corporate restructuring
  • Representing a settlement fund established in an age discrimination suit with respect to allocation and withholding issues

Prior to joining Caplin & Drysdale, Mr. Kochman spent over 20 years performing quantitative and policy analyses for federal government agencies, which included: conducting econometric and statistical studies and developed cost allocation and pricing models, developing renewable energy research and development plans, and conducting defense acquisition policy studies.

Mr. Kochman has written, been a guest lecturer at Georgetown University Law Center, and spoken at professional meetings on a variety of international and general tax topics, including foreign tax credits, transfer pricing, and the research credit.

Mr. Ungerman is a partner with Meadows, Collier, Reed, Cousins, Crouch & Ungerman, L.L.P.  His practice focus includes estate planning and family wealth transfers along with IRS controversy matters at all levels.  The tax and estate matters in which Mr. Ungerman is involved are typically very complex from both a factual and legal perspective.  These matters often require legal and accounting skills.  Mr. Ungerman is also a Certified Public Accountant.  He works with families on wealth preservation and transfer strategies.  A major focus is accomplishing family wealth preservation goals with an emphasis on the efficient transfer of family wealth to the next generation from a business and tax perspective.  Mr. Ungerman is also involved in defending taxpayers and issues against IRS inquiries and actions.  His IRS defense practice covers civil and criminal exams, and investigations and trials.  Many of Mr. Ungerman’s tax controversy matters include an offshore component.

Prior to joining the firm in 1994, he was a civil prosecutor for the Internal Revenue Service, Dallas District Counsel office.  He was also a Special Assistant United States Attorney for the Department of Justice in Dallas during his time as a civil prosecutor.  Prior to becoming an IRS attorney of a special assistant U.S. attorney, he served as a law clerk to the Honorable Carolyn M. Parr at the United States Tax Court in Washington, D.C.

Mr. Ungerman is a frequent speaker on tax topics including such topics as exams, IRS estate tax strategies, tax shelter defense, recent tax legislation and IRS criminal tax.  He is a member of the American College of Tax Counsel.

Mr. Ungerman is often quoted and published on tax topics included in The Wall Street Journal, The New York Times, Bloomberg, Daily Tax Report, Tax Notes, Journal of Tax Practice and Procedure and the Dallas Business Journal.

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.

Frank (“Chip”) Dunham is an attorney in Branch 6 of the Office of Associate Chief Counsel (International). He started his IRS career with the Office of Associate Chief Counsel (Income Tax & Accounting) in 2009. Before joining IRS, Chip spent several years in private practice with firms in Rockville, MD and New York, NY. He received a B.S. in Accounting and Psychology and J.D. from the University of Virginia and an LL.M. in Taxation from New York 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.


Justin Jesse has broad experience with domestic and international tax issues affecting large multi-national corporations, including income sourcing, application of bilateral income tax treaties, and transfer pricing.  Justin also advises clients on all aspects of tax disputes, including cases before the US Tax Court, US district courts, the U.S. Court of Federal Claims and the Internal Revenue Service (IRS). Such matters have included disputes relating to debt characterization of intercompany debt, captive insurance, research and development credits, transfer pricing and tax advantaged transactions. He has also represented clients before Congress relating to investigations of international tax-related matters.

Justin has experience with tax-exempt organizations, nuclear decommissioning trust funds, new markets tax credits, privilege and discovery issues, international tax restructurings, and requesting IRS private letter rulings.


Karen Cate is a Tax Law Specialist in Branch 3 of the Office of Associate Chief Counsel (International) (ACCI).  In this capacity she provides advice to the IRS, drafts guidance, and assists with litigation concerning foreign tax credit, source of income, and expense allocation and apportionment matters.  Prior to joining the Office of ACCI, Karen was a member of the IRS Treaty Assistance & Interpretation Team (Office of U.S. Competent Authority).  In this role, she worked with treaty partners to provide relief of double taxation for a variety of taxpayers.  She also represented the IRS in Treasury-led teams negotiating a treaty and served as an IRS delegate to OECD Working Party 1 (Tax Conventions and Related Questions).  Before the IRS, Karen was an international tax senior manager at Ernst & Young.

Matt Chen is a Partner in the Washington National Tax Services office of PwC. He practices international tax planning primarily for US-headquartered multinational companies, with emphasis on Subpart F, foreign tax credits, electronic commerce and software transaction issues, and international tax aspects of acquisitions, joint ventures, intangibles, and other business transactions. Matt has authored or co-authored articles and PwC thought leadership pieces on key developments in subpart F involving the contract manufacturing regulations, the branch rule, section 956 issues, cross-border stock acquisitions, the substantial assistance rule under Notice 2007-13, and checkthe-box planning strategies. Matt is a certified public accountant licensed in Illinois and Washington, DC, and is a member of AICPA. Matt is a graduate of University of Illinois, Urbana-Champaign.