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Basics of International Taxation 2018 San Francisco


Speaker(s): Andrea Sharetta, 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 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

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.


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. 


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.


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.


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. 


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

 


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.

 


Lisa Zarlenga represents public and private companies on federal income taxation issues, with a focus on corporate transactional and planning matters as well as on tax policy issues with respect to tax legislation and Treasury guidance. Lisa also advises clients on structuring tax-free and taxable acquisitions and dispositions, tax-free spin-offs, and internal restructurings, including providing opinion letters and seeking advance rulings from the IRS. She also assists clients in restructuring financially troubled businesses and advises on the special rules governing consolidated groups.

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

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

 

Clerkship & Government Experience

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

Education

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

Awards

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

 


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)


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.

 


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.


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.


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.

 


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.

 


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.