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Basics of International Taxation 2018 San Francisco


Speaker(s): Andrea Sharetta, Carol P. Tello, Catherine G. Schultz, Christopher J. Bello, Corey M. Goodman, Danielle E. Rolfes, Frank Y. Ng, Greg A. Texley, James S.H. Null, Janice A. Mays, Jeremy M. Naylor, John D. Bates, John L. Harrington, John P. Warner, Justin E. Jesse, Kimberly T. Majure, Kristine A. Crabtree, Larissa Neumann, Lisa M. Zarlenga, Michele J. Alexander, Sadler Nelson, Steven C. Wrappe
Recorded on: Sep. 27, 2018
PLI Program #: 218876

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.”


 


Frank Y. Ng is a member of Ernst & Young LLP’s Tax Controversy and Risk Management Services group in Washington, DC. Frank assists clients focused on working effectively with the Internal Revenue Service and tax administrators around the world to achieve tax certainty by developing tax audit management strategies to resolve domestic and international tax disputes and mitigate future controversy.  He also assists global clients with the development of their tax controversy and risk management framework that enhances capabilities to manage global tax audits and risks.

From 2007-2009 Frank served as Commissioner of the Large and Mid-size Business (LMSB) Division at the Internal Revenue Service with tax administration responsibility for 235,000 corporate and large business taxpayers. Prior to his appointment as LMSB Commissioner, Frank was appointed as the first Deputy Commissioner (International) in LMSB, serving as the United States Competent Authority administering U.S. tax treaties including the resolution of transfer pricing double tax disputes, oversight of the IRS’ international compliance strategies, international enforcement programs and compliance efforts with foreign treaty partners. He also has served as, acting Deputy Commissioner (LMSB), Industry Director for Communications, Technology and Media, Director of Pre-filing and Technical Guidance and IRS Attaché in Tokyo responsible for IRS matters in the Far East. During his distinguished career at the IRS, Frank was instrumental in leading the Compliance Assurance Process development as well as spearheading the development of other pre-filing and alternative dispute resolution processes. He represented the United States at the OECD Forum on Tax Administration working close with foreign tax executives to enhance global tax administration and has advised other governments on tax administration organizational, operational and compliance program development.

He holds a Bachelor of Science degree in accounting from Arizona State University and a Masters of Public Administration from the University of Southern California. He is a graduate of the 2000 IRS Executive Development Program and is a recipient of the 2005 Presidential Rank Award for meritorious service. He is a current member of the AICPA IRS Tax Advocacy & Relations Committee.


Lisa Zarlenga represents public and private companies on federal income taxation issues, with a focus on tax policy issues with respect to tax legislation and Treasury guidance as well as on corporate transactional and planning matters. Lisa serves as co-chair of Steptoe’s Tax Group and leads the firm’s tax policy practice. Drawing on her experience as Tax Legislative Counsel at the US Treasury Department’s Office of Tax Policy, Lisa marries substantive tax knowledge with strong relationships at Treasury and 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 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.

Lisa has combined her policy and transactional backgrounds to advise clients on tax issues relating to blockchain and digital currency. She advises clients on conducting digital currency transactions and conversions, token offerings, and different investment and entity structures. Her experience includes advising a coalition of the leading companies in the blockchain space that was engaging directly with the IRS and policymakers to develop workable policies at an industry-wide level.

As Tax Legislative Counsel at the Treasury Department, Lisa advised Treasury’s Assistant Secretary for Tax Policy on a broad range of domestic tax policy issues, including corporate, partnership, healthcare, tax-exempt organizations, energy, income tax accounting, estate and gift, and procedure and administration. She oversaw preparation of regulations and other administrative guidance implementing the Internal Revenue Code and the president’s annual revenue proposals in these areas.

Clerkship

• Hon. Robert P. Ruwe, US Tax Court

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

The Best Lawyers in America, Tax Law (2018)

Super Lawyers, Washington, DC, Tax (2017)

• Treasury Exceptional Service Award (2015), Special Act Award (2011)

• Washingtonian magazine, "Best Lawyers," Tax (2015, 2017)

Legal 500 US, Finance: Not-for-Profit, Nonprofit and Tax Exempt Organizations; Government: Government Relations; Tax: International Tax; Tax: US Taxes, Contentious; Tax: US Taxes, Non-Contentious (2016); Domestic Tax, East Coast (2009-2010)


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.


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.


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.


Background
Danielle co-leads the International Tax Group within KPMG’s Washington National Tax office.  Danielle joined KPMG in June 2017, following her tenure as the International Tax Counsel at the U.S. Department of the Treasury.

Professional and industry experience
Danielle advises clients on U.S. international tax matters, including tax planning with respect to their structures, operations, and transactions.  In particular, she has extensive experience advising on issues relating to international tax policy, tax treaties, foreign currency, the source of income rules, subpart F, and foreign tax credits.  More recently, she has focused on helping clients navigate U.S. tax reform, including the new Base Erosion Anti-Abuse Tax, the regimes for Global Intangible Low-Taxed Income and Foreign-Derived Intangible Income, and the new limitations on the foreign tax credit.

Prior to joining KPMG, Danielle served as an executive in the Treasury Department’s Office of Tax Policy.  She joined Treasury in 2011 as Deputy International Tax Counsel, 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 Organisation of Economic Cooperation and Development.  

Prior to joining Treasury, Danielle was a partner at Ivins, Phillips & Barker, where she advised multinational corporations on international tax planning, controversy, and compliance matters, as well as on tax accounting methods.  Before law school, Danielle was an accountant at Procter & Gamble. 

Education, licenses, and certifications
Member of the District of Columbia Bar Association 
CPA, District of Columbia
J.D., magna cum laude, Harvard Law School; Editor, HARVARD LAW REVIEW
LL.M., with distinction, Georgetown University Law Center
B.S. Accountancy, summa cum laude, Wright State University

Publications and speaking engagements
Danielle is a frequent speaker and writer on a variety of international tax topics.  In addition to numerous articles, Danielle is the author of AN ANALYSIS OF FIN 48 – ACCOUNTING FOR UNCERTAIN INCOME TAX POSITIONS (Matthew Bender, 3d ed. 2009).

 


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. 

 


Chris Bello is the branch chief for Branch 6 of the Office of the Associate Chief Counsel (International), IRS.  Branch 6 is responsible for international transfer pricing as well as a number of other practice areas.  Chris was a drafter and reviewer of the proposed, temporary, and final cost sharing regulations and was the reviewer of the final services regulations.  He has been a member of the U.S. delegation to OECD Working Party No. 6 on the Taxation of Multinational Enterprises for 10 years, working on matters including the revision of Chapters I through III of the Transfer Pricing Guidelines and the addition of Chapter IX, the project on intangibles, and the base erosion and profit shifting project.  Chris obtained an undergraduate degree from Princeton University, a law degree from the University of Virginia School of Law, and an LL.M. in taxation from the University of Florida School of Law Graduate Tax Program.  He is a member of the Florida Bar.


Greg Texley is an International Tax Law Specialist for the Treaty Assistance and Interpretation Team (“TAIT”), which, along with the Advance Pricing and Mutual Agreement Program (“APMA”), compose 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, 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 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.

 


Jeremy Naylor is a partner in the Tax Department and a member of the Private Funds Group. Jeremy works with private investment fund sponsors and their investors in all tax aspects of structuring venture capital, private equity, real estate and hedge funds. He 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. 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 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.

 


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. 

 


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.

 


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.

 


Larissa Neumann focuses her practice on U.S. tax planning and tax controversy with an emphasis on international transactions.  She has broad experience advising clients on mergers and acquisitions, restructurings and has extensive transfer pricing experience. 

Keen analytical skills coupled with a focus on providing clients practical solutions to complex tax issues have earned Larissa a reputation as a leading tax advisor both in the Silicon Valley and nationwide.  She appears in Euromoney’s World’s Leading Tax Advisers and International Tax Review's World's Tax Controversy Leaders.  Euromoney’s Women in Business Law named Larissa America’s Best Transfer Pricing Lawyer in 2017 and 2018.  She also is consistently named by Euromoney as one of the World’s Leading Transfer Pricing Advisors. 

Larissa has successfully represented clients in federal tax controversies at the audit level and in appeals, Tax Court and other federal courts. She was counsel in the recent important taxpayer victory for Analog Devices, Inc. v. Commissioner, 147 T.C. No. 15 (2016), and the successful resolution for Sanofi in Aventis, S.A. v. United States, US Court of Federal Claims Dkt. No. 11 647T.  She currently is counsel for VF Corporation/Timberland in TBL Licensing LLC v. Commissioner, Tax Court Dkt. No. 21146-15.

For Tax Notes International, Larissa coauthors a monthly column on all recent development in U.S. international tax.  She is also on the executive committee of the International Fiscal Association (IFA) and serves as the Chair of the Technology Committee.  

Larissa appears in Euromoney’s Women in Business Law (a short list of the top women tax lawyers in the world) and ITR’s Women in Tax Leaders.  She has also been shortlisted for Euromoney’s Women in Business Law America’s Best Lawyer in Tax Dispute Resolution. Larissa was named to the Daily Journal’s 2017 list of Top Women Lawyers in California and was honored with the Women of Influence award by the Silicon Valley Business Journal in 2017.

Larissa teaches International Tax at the University of California, Berkeley, School of Law.  
Larissa frequently speaks at conferences for professional tax groups, including TEI, IFA, Pacific Rim Tax Institute, and the ABA. She is the ABA International Law Tax Liaison.

Fenwick has one of the World’s Top Tax Planning and Transactional Practices, according to ITR, and is first tier, according to World Tax. Fenwick is consistently named the San Francisco Tax Firm of the Year by ITR and has been named U.S. Tax Litigation Firm of the Year.  ITR has recognized Fenwick as the Americas M&A Tax Firm of the Year and the West Coast Transfer Pricing Firm of the Year. 

Fenwick has advised over 100 Fortune 500 companies on tax matters, and has served as counsel in more than 150 large-corporate IRS Appeals proceedings and more than 75 federal court tax cases. Larissa is a leader on Fenwick’s Pro Bono Review Committee and regularly provides pro bono services to various nonprofit organizations.  Fenwick was recognized by The National Law Journal Pro Bono Hot List and Larissa's nonprofit work is pointed to as exemplary in the profile.

 


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


Sadler Nelson is the West Coast Leader of EY’s International Tax Services practice. In this role, Sadler works with a diverse team of innovative, globally-integrated tax professionals who assist dynamic multi-national organizations build proactive and integrated global tax strategies that address the current challenging tax environment. He has 20 years experience on a wide variety of international tax matters.

He also has extensive experience in the development and implementation of cross-border restructuring. Based on San Jose, California, he has worked with some of the firm’s most dynamic clients in the technology industry. 

Sadler earned his Bachelor of Science in Accounting and a Master of Science in Accounting, with a concentration in Taxation from Brigham Young University.

 


Based in the DC office of Washington National Tax, Kim is KPMG’s Inbound Tax Leader.  In this role, she advises clients on inbound and outbound / “sandwich” international tax planning and controversy issues, including cash management and deferral planning, cross border payments and withholding, and inbound investment planning. Kim is also KPMG’s national leader on BEPS Country-by-Country (“CbyC”) reporting. She has published numerous articles on FATCA as well as BEPS CbyC Reporting, and is a regular speaker on both topics.

Kim was an adjunct professor with the Georgetown University Law Center for 11 years, teaching a mix of international tax classes for Georgetown’s L.L.M. program, including an advanced international tax seminar and a cross-border tax controversy workshop. Kim regularly writes and speaks outside of the academic setting. She is a featured speaker on cross-border information reporting, tax controversy, and cloud taxation, 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.  The current chair of the ABA Tax Section Committee on Foreign Activities of U.S. Taxpayers, Kim also leads the Tax Section’s Cloud Taxation working group. 

Prior to joining KPMG, Ms. Majure was a partner in the D.C. law firm, Miller & Chevalier, where she provided clients with foreign structuring and tax planning services as well as representation in IRS audit and appeals proceedings. 

LL.M. (Taxation), Georgetown University Law Center
J.D., Harvard Law School
B.A., University of Virginia