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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

Dana Trier is a retired tax partner of Davis Polk & Wardwell, who currently serves as 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.

Mr. Trier graduated from Indiana University, where he majored in history and economics and graduated Phi Beta Kappa.  He did graduate work in history and international affairs at Princeton University, and received his law degree from the University of Michigan Law School, where he was note editor of the law review.  More recently, he did graduate work in applied economics at Johns Hopkins University where he received an M.A. in applied economics.


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 D.C. offices of Gibson, Dunn & Crutcher and a member of the Firm’s Tax Practice Group.  With nearly 30 years of broad transactional and structuring experience, Mr. Sloan is a recognized expert in partnership taxation, private equity, and "UP-C" IPOs.  

Mr. Sloan is a Fellow of the American College of Tax Counsel.  He currently serves 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 Harvard Law School.  

Mr. Sloan received his Juris Doctor from the University of Chicago and his LL.M. with distinction in taxation from Georgetown University Law Center. 


Marjorie Rollinson is the Deputy Director of the National Tax Department.

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.  Before becoming the Associate Chief Counsel, Marjorie served as Deputy Associate Chief Counsel (International – Technical) overseeing the international published guidance program and served as a technical resource for all legal positions taken with respect to international taxes by the Office of Chief Counsel.  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.  She concentrated on international tax planning for US multinational corporations, specializing particularly in the foreign tax credit area and issues regarding controlled foreign corporations.  Throughout her career, Marjorie has also been a frequent contributor to international tax publications and spoken regularly on international tax matters.

Marjorie holds a B.A. from Wellesley College and a J.D. from the University of Maryland.


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.  


José is the leader of the International Tax Services (ITS) practice, Washington, DC at Ernst & Young LLP, the US EY member firm. He also serves as the National Director of Technical Services for ITS. José practices primarily in the area of cross-border acquisitions, dispositions and restructurings.

Prior to his current role, José was a member of the Treasury Department’s Office of Tax Policy, where he assisted in the development of international tax policy, Treasury regulations and other guidance and in negotiating income tax treaties.

Before serving with the Treasury Department, he was a member of Ernst & Young LLP’s International Tax Services practices in Houston and Washington, DC.

José is a frequent contributor to tax publications and a presenter at internal and external international tax seminars and conferences.

 


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.


Chip Harter is the Deputy Assistant Secretary for International Tax Affairs in the Office of Tax Policy at the US Department of the Treasury. In this capacity, he is responsible, on behalf of the Assistant Secretary, for the conduct of legal and economic aspects of tax policy relative to the representation of the United States in bilateral and multilateral relations with other countries, as well as advising the legal and economic staffs within the Office of Tax Policy, other offices of the Treasury Department and other government agencies as to policy analysis and interpretation for domestic legislation and administrative guidance in all matters involving cross border taxation. Mr. Harter serves as the U.S. delegate to the Committee on Fiscal Affairs (CFA) in the Organization for Economic Cooperation and Development (the OECD). In addition, Mr. Harter oversees the Office of Tax Policy’s participation in the various working bodies of the CFA and sits on the CFA Bureau (the CFA’s governing body). Mr. Harter also serves as the U.S. delegate to the Global Forum on Transparency.

Prior to joining Treasury, Mr. Harter was a principal in the Washington National Tax Practice of PricewaterhouseCoopers LLP. During his 18 years with PwC, he engaged in a broad international tax practice advising a numerous clients on a range of issues, including structuring both inbound and outbound ventures, the establishment of efficient international structures, the formation of joint ventures and private equity funds and international mergers and acquisitions. He served as a national technical resource of PwC on tax issues relating to international financial transactions. During the 18 years prior to his joining PwC, Mr. Harter was first an associate and then a partner with the law firm of Baker & McKenzie, practicing first in its Chicago and then in its Washington D.C. office. His practice with Baker & McKenzie included both tax litigation and a broad international transactional practice.

He is a member of the American Bar Association Tax Section, the District of Columbia Bar Association Tax Section, and the International Fiscal Association. Mr. Harter has published numerous articles on international tax topics and has regularly spoken on panels on international tax issues at leading tax conferences. He graduated from Harvard College in 1977 and the University of Chicago Law School in 1980, where he was comments and articles editor on the managing board of The University of Chicago Law Review. After graduating, he clerked for the Honorable Thomas McMillen of the United States District Court for the Northern District of Illinois.


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.


Brenda 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 KPMG’s Washington National Tax office where she specialized in cross-border M&A.


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


Mr. Barr is head of Davis Polk’s Tax Department. He frequently advises clients on federal income tax matters, including domestic and cross-border mergers, acquisitions and dispositions, joint ventures, spinoffs and splitoffs. He also regularly advises with respect to group structuring, including as to the application of the consolidated return regulations. In addition, he has advised clients as to the tax consequences of bankruptcy, workouts and other restructuring matters.