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The Tax Cuts and Jobs Act: Navigating the New Landscape


Speaker(s): Aaron H. Junge, Brenda L. Zent, Dana L. Trier, Daniel M. McCall, David H. Schnabel, Eric B. Sloan, Jennifer S. Acuña, John E. Harrell, José E. Murillo, L.G. "Chip" Harter, Manal S. Corwin, Marjorie A. Rollinson, Mark A. Prater, Neil J. Barr
Recorded on: Feb. 2, 2018
PLI Program #: 237677

L.G. "Chip" Harter is a senior policy advisor to PwC.

He served the Department of the Treasury as Deputy Assistant Secretary of Tax Policy for International Tax Affairs from September 2017 through November 2020.

As Deputy Assistant Secretary for International Tax Affairs, Mr. Harter was responsible for all international tax matters at Treasury. He played a central role in representing the Treasury in the legislative process for the Tax Cuts and Jobs Act (TCJA), which was signed into law in December 2017. Mr. Harter then led the development and issuance of an integrated set of regulations to implement the new international provisions of the TCJA, including regulations to implement the Global Intangible Low Tax Income (GILTI) regime, the Base Erosion Anti-Avoidance Tax (BEAT), and the Foreign Derived Intangible Income (FDII) regime.

Mr. Harter also represented the United States in tax negotiations at the Organisation for Economic Cooperation and Development (OECD). At the OECD, he led the efforts to revise long-standing international tax rules that provide for the allocation of taxing rights over multinational businesses, representing the United States in negotiations over the designs of the Pillar 1 and Pillar 2 proposals.

In recognition of these services, Mr. Harter was awarded the Treasury Medal.

Prior to joining the Treasury, Mr. Harter served for 18 years as a principal in the Washington National Tax Service of PwC. Prior to joining PwC, Mr. Harter served 18 years, first as an associate and then as a partner, with the international law firm of Baker& McKenzie. He is a member of the District of Columbia Bar.


Brenda Zent is a Special Advisor to the International Tax Counsel in the Office of Tax Policy. Brenda joined the Treasury Department in September 2010 and during this time has played a lead role in guidance related to cross border mergers and acquisitions involving corporations and partnerships. Prior to joining Treasury, Brenda was a Managing Director in the Washington National Tax office of a “Big 4” accounting firm where she specialized in cross-border M&A.


Dana Trier is a retired tax partner of Davis Polk & Wardwell, who currently serves as senior counsel in Davis Polk’s Tax Department in New York City.  His practice focuses on domestic and international tax planning for corporate mergers, acquisitions, joint ventures, spinoffs and private equity investments.  He also has a substantial amount of experience in financial transactions such as convertible debt instruments, equity derivatives, securitization and project finance, and historically has done a significant amount of work involving executive compensation, employee benefits and insurance products.  In addition to his tax planning practice, he has represented clients on ruling and legislative matters and in tax controversies.

Mr. Trier rejoined Davis Polk after serving as Deputy Assistant Secretary for Tax Policy in the U.S. Treasury Department in the Trump administration, where he oversaw the Office of the Tax Legislative Counsel, assisted in establishing and implementing the legislative goals of the Office of Tax Policy, and coordinated the administrative guidance projects of the Office.  He previously served as the Department’s Acting Deputy Assistant Secretary for Tax Policy, Tax Legislative Counsel and Deputy Tax Legislative Counsel from 1988 to 1989 during the administrations of Presidents Ronald Reagan and George H.W. Bush.

Mr. Trier has been listed as a leading tax lawyer in several legal industry publications, including Chambers Global; Chambers USA; Practical Law Company’s Cross-Border Tax on Corporate Transactions Handbook; Law Business Research’s Who’s Who Legal – International Who’s Who of Business Lawyers; Euromoney’s Expert Guide to the World's Leading Lawyers – Best of the Best U.S.; Tax Directors Handbook; and American Lawyer Media’s Corporate Counsel: Best Lawyers Annual Guide to Tax Law.  He was formerly Chair, Corporate Tax Committee, ABA Section of Taxation, and also served on the Executive Committee of the Taxation Section of the New York State Bar Association and on the Planning Committee for the University of Chicago Tax Conference.  Mr. Trier has also taught a variety of tax courses at Georgetown University Law Center, Columbia University Law School and University of Miami Law School, including corporate and partnership taxation, consolidated returns, taxation of property transactions and international taxation.


Daniel McCall is the Deputy Associate Chief Counsel (International - Technical).  Mr. McCall oversees the international component of the published guidance program and also assists the Associate in providing legal advisory services on all international and foreign tax matters.

Previously, Mr. McCall served in other capacities in IRS Chief Counsel International, focusing on international mergers and acquisitions. He has also worked in private practice on a wide range of international and corporate tax matters.  

Mr. McCall received his J.D. from the Georgetown University Law Center in 2005 and a Bachelor’s degree from Georgetown University’s Walsh School of Foreign Service, cum laude, in 2001.


Eric Sloan is a partner in the New York and Washington DC offices of Gibson, Dunn & Crutcher and a Co-Chair of the Firm’s tax practice. With more than 30 years of broad transactional and structuring experience, Mr. Sloan is a nationally recognized expert in private equity and on the use of partnerships and limited liability companies in domestic and cross-border mergers and acquisitions, financing transactions, and restructurings. He advised on the first passthrough portfolio company investments made by four of the largest U.S.-based private equity firms. Mr. Sloan has substantial experience in the formation of domestic and cross-border joint ventures and acquisitions and dispositions of businesses and interests in joint ventures, including the largest joint venture in the United States and a complex multi-billion dollar cross-border commodities joint venture. In addition, Mr. Sloan is deeply experienced in obtaining private letter rulings and closing agreements from the Internal Revenue Service on novel and difficult issues on an expedited basis.

Mr. Sloan is ranked as a leading tax lawyer by Chambers USA: America’s Leading Lawyers for Business.  Chambers notes he is as “a world-class partnership lawyer,” an “excellent technician,” “a fountain of knowledge on partnership matters,” “articulate and extremely fast,” “thinks about all angles and practical solutions” and stands out for his “experience, depth of knowledge and very strong ability to communicate complex subjects.”  Who’s Who Legal also recognizes Mr. Sloan as an “Expert” in the area of Corporate Tax.

Mr. Sloan is a Fellow of the American College of Tax Counsel. He is the immediate past Vice Chair, Government Relations, of the American Bar Association Section of Taxation and is a past Chair of the tax section’s Committee on Partnerships and LLCs. He is also a member of the Executive Committee of the New York State Bar Association Tax Section and a past Co-Chair of that tax section’s Committee on Partnerships. He is also Conference Co-Chair of Practising Law Institute’s Tax Planning for Domestic & Foreign Partnerships, LLCs, Joint Ventures & Other Strategic Alliances conference, and serves on planning committees for The University of Chicago Federal Tax Conference, the NYU Institute on Tax Institute, USC’s Gould School of Law’s Tax Institute, the Texas Federal Tax Institute, and Bloomberg BNA’s Pass-Through Entities Advisory Board. In addition, for more than a decade he was an adjunct professor at Georgetown University Law Center, and he has been a guest lecturer at the Wharton School of the University of Pennsylvania and the Harvard Law School.

Mr. Sloan started his legal career as an associate with Irell & Manella in Los Angeles and practiced law in Washington, D.C. before joining Deloitte as a principal, where he was asked to establish and lead Deloitte's National Office Partnership Taxation group in 1997. He received his Juris Doctor from the University of Chicago in 1990 and an LL.M. with distinction in taxation from Georgetown University Law Center in 1994. Mr. Sloan is a member of the District of Columbia bar and the New York bar.


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.

 


Marjorie Rollinson is the National Tax Deputy Leader.

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

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

 


Mr. Barr is the Managing Partner of Davis Polk and a senior member of the Tax Department.

Twice named a “Tax MVP of the Year” by Law360, Mr. Barr is recognized as a leading tax lawyer in numerous industry publications.  His practice focuses on advising companies and their boards on complex transactions with emphasis on federal income tax matters, including domestic and cross-border mergers, acquisitions and dispositions, joint ventures, spinoffs and splitoffs, and group structuring.

Before his election as Managing Partner in 2019, Mr. Barr spent five years as head of the firm’s Tax Department.


Mr. Schnabel is the chair of Davis Polk’s Tax Department. He advises clients on a full range of transactions, including M&A, spinoffs, financing, PIPEs, partnerships and S corporations, joint ventures, fund formation and inversions. He is a former Chair of the Tax Section of the New York State Bar Association, a member of the Planning Committee of the University of Chicago Law School Tax Conference, a Fellow of the American College of Tax Counsel and a frequent speaker and writer on the tax aspects of M&A and private equity and various tax issues.  


Aaron Junge serves as a tax counsel for the Committee on Ways and Means of the United States House of Representatives.  His portfolios include international issues, energy, and certain aspects of business taxation.  Prior to joining the staff of the Ways and Means Committee, Aaron worked in the National Tax Services office of PricewaterhouseCoopers, LLP, where he specialized in international tax, and before that at a small public accounting firm in Omaha, Nebraska.  Aaron received a B.S.B.A. (accounting) from the University of Nebraska at Omaha, a J.D. from Creighton University School of Law, and an LL.M. (taxation) from Georgetown University Law Center.


Jennifer Acuña is the Senior Tax Counsel and Policy Advisor for the U.S. Senate Finance Committee in Washington, D.C. Prior to joining Senate Finance, she was Tax Counsel for the House Ways and Means Committee. Her previous experience includes time in the Competent Authority Office at the Internal Revenue Service and as an associate at White and Case, and Morgan Lewis and Bockius. She received her LL.M in Taxation from NYU School of Law and her J.D. from UCLA.


Manal Corwin is KPMG LLP’s National Service Line Leader for International Tax as well as Principal in Charge of Washington National Tax—International Tax Policy. She rejoined the firm in April of 2013 following completion of her tenure as Deputy Assistant Secretary of Tax Policy for International Affairs in the Treasury Department.

Manal advises multinational corporations on U.S. international tax aspects of their structures, operations and transactions. She specializes in consulting and advising on issues relating to international tax policy, expense allocation, source of income rules, foreign tax credits, subpart F, U.S. taxation of international transportation income, and certain special tax benefit provisions. In addition, Manal leads KPMG’s Global BEPS Network and advises clients on developments and implications of BEPS measures.

During her tenure at the U.S. Treasury Department, Manal helped shape the Administration’s views and policies in all areas of international taxation and worked closely with the IRS, members of Congress, and key tax regulators globally. In this regard, Manal worked on the international tax provisions of several of the Administration’s budget proposals as well as the development of the Administration’s framework for tax reform. Manal also served as the U.S. delegate and Vice Chair to the OECD’s committee on fiscal affairs and was actively engaged in the origination and development of the OECD BEPS initiative. She served as the U.S. delegate to the Global Forum on Tax and Transparency as well. Significantly, Manal was also responsible for leading the development and implementation of the intergovernmental approach to the Foreign Account Tax Compliance Act (FATCA), which has been endorsed as the foundation for a global standard for automatic exchange of information. In addition, Manal was head of the delegations responsible for negotiating income tax treaties with Japan, Spain, Chile, and the United Kingdom.

Prior to joining the Treasury Department (first as International Tax Counsel in the Office of Tax Policy and then as Deputy Assistant Secretary for International Tax Affairs), Manal was a principal in KPMG’s Washington National Tax practice 2001 to 2009, where she advised multinational corporations on U.S. international tax aspects of their operations and transactions and represented clients in tax controversies before the IRS.

Earlier in her career, Manal served as the Deputy and then Acting International Tax Counsel in the Office of Tax Policy at the U.S. Treasury Department. Prior to that, Manal practiced as an attorney specializing in international taxation at the law firm of Covington & Burling in Washington, D.C. Manal also served as a judicial clerk for then Chief Judge Levin Campbell on the U.S. Court of Appeals for the First Circuit.

Manal is a frequent speaker and commentator on international tax rules and policies. She is a member of the Massachusetts and the District of Columbia bar associations. She is a graduate of the Boston University School of Law, where she was editor-in-chief of the Law Review and recognized as a distinguished scholar. She earned her undergraduate degree from Harvard University.


Mark Prater graduated from Portland State University in 1981 with a B.S. in accounting.  He also obtained a J.D. from Willamette University in 1984 and an LL.M. in Taxation from the University of Florida in 1987. Mr. Prater became a member of the Oregon and Washington State bars in 1984 and a certified public accountant in Washington in 1986.  He practiced with Touche Ross from 1984 to 1986 and a Portland law firm, Dunn, Carney et al. from 1987 to 1990. From January 1990 through November 1993, Mr. Prater served as a tax counsel on the Republican staff of the U.S. Senate Finance Committee. Since November 1993, Mr. Prater has served as Chief Tax Counsel on the Republican staff of the Senate Finance Committee and since January 2007, has also served as Deputy Staff Director of the Republican staff.

In September of 2011, Mr. Prater was selected as Staff Director for the Joint Select Committee on Deficit Reduction, (“JSCDR”) i.e. the Super Committee.  

Mark and his wife Lori live with their son James near Capitol Hill. When Mark isn’t working, he enjoys watching the Washington Capitals.


John Harrell is the Global Tax Director at General Electric Capital in Stamford, CT.