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Basics of International Taxation 2019 New York


Speaker(s): Andrea Sharetta, Anne G. Batter, Caroline H. Ngo, Corey M. Goodman, Danielle E. Rolfes, David L. Forst, Frank Y. Ng, Isaac Hirsch, James S.H. Null, Jeremy M. Naylor, John D. Bates, John L. Harrington, John P. Warner, José E. Murillo, Ligeia M. Donis, Lisa M. Zarlenga, Nicole L. Welch, Ninee S. Dewar, Philip B. Wright, Steven C. Wrappe, William J. Corcoran
Recorded on: Jul. 23, 2019
PLI Program #: 252161

Anne Batter is a partner in Baker & McKenzie's Tax Practice Group with over 30 years of tax experience. She focuses her practice on the tax treatment of executive compensation and fringe benefits arrangements. She has expertise is in the special rules applicable to employment taxation, including the impact of international assignments.  She also handles excise tax matters, particularly those involving the air transportation excise tax. She previously served as an attorney in the Income Tax & Accounting Division of the IRS's Office of Chief Counsel and as Attorney-Advisor with the US Tax Court. Ms. Batter has been recognized by Legal 500 as a leading lawyer in the United States for complex executive compensation matters.

Ms. Batter focuses her practice on the federal and state taxation of compensation and benefits with an emphasis on the deductibility, reporting, employment taxation and withholding, and excise taxation of all forms of compensation other than qualified retirement plans. She regularly handles matters ranging from the treatment of equity compensation in mergers and acquisitions, to the design and administration of deferred compensation arrangements, to advising on the proper tax treatment of executive perquisites such as corporate aircraft, and workforce wide benefits such as business travel expense reimbursement programs, company cafeterias, transit benefits, company cars, and employee hardship programs. She also advises on the reporting and withholding on cross border payments, both those made to employees and those made to non-employee out of the accounts payable function.  Additionally, she works with clients on excise tax issues, particularly the air transportation excise tax.

Ms. Batter served as Attorney, Office of Chief Counsel, Income Tax and Accounting Division, Internal Revenue Service, 1993 – 1994; and as Attorney-Advisor, United States Tax Court, 1985 - 1988.

Ms. Batter began her career by serving as law clerk to the Honorable Arnold Raum, senior judge of the United States Tax Court.

Ms. Batter received her J.D., Harvard Law School, 1985 and her B.A., University of Maryland, summa cum laude, Phi beta Kappa, 1982.


Bill Corcoran advises on the federal and state income tax consequences of corporate and partnership mergers and divisions. He also represents leveraged buyout, venture capital, mezzanine and other alternative investment vehicles on formation and investment issues. Bill's practice includes assisting non-US investors in alternative investment vehicles formed to invest in equity, debt, real estate and infrastructure projects. He has extensive expertise in advising foreign sovereigns investing in the US. Bill also represents multinational corporations on financing, tax treaty planning, and other cross-border tax issues. He also has experience representing public and private companies involved in developing the exchangeable share structure and advises US investors investing in Canada through alternative investment vehicles.

Bill’s representative matters include:

  • Portfolio investment by a US investor in a Canadian corporation using exchangeable shares and designed to preserve Canadian controlled private corporation (CCPC) status
  • Acquisition of the stock and assets of a divisional business of a public corporation involving tax issues in the US, Canada and China
  • $300 million acquisition of the stock of a domestic Subchapter S corporation, together with the filing of a Section 338(h)(10) election to step-up the inside tax basis of the target corporation’s assets
  • Leveraged buyout of a US corporation by a Canadian buyout fund
  • Purchase of a publicly-traded corporation by another publicly-traded corporation involving US golden parachute tax rules and recently enacted deferred compensation tax rules

Education

  • University of ChicagoJD
  • Brandeis UniversityBA

Bar Admissions

  • New York
  • Massachusetts


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.


Isaac is a Managing Director in KPMG’s International Tax practice. Isaac advises a broad range of public and private multinational clients on operational tax issues and complex cross-border transactions. He is experienced in international mergers and acquisitions, inversions, and reorganizations; post-acquisition integration; foreign tax credit planning; repatriation strategies; partnerships and joint ventures; permanent establishment and income tax treaty issues; and tax planning for changes to a company’s value chain. Prior to KPMG, Isaac was an associate in the business tax counseling and restructuring practice at a law firm. Isaac is a graduate of New York University School of Law, where he earned a J.D. and LL.M. He is a certified public accountant in New Jersey.


Ligeia is a Director in PwC’s Tax Controversy and Regulatory Services part of Washington National Tax Services in Washington, DC.  As a member of the Federal Employment Tax Team, Ligeia advises and represents clients in IRS audits and IRS Appeals, and assists clients with IRS compliance, dispute resolution, and voluntary disclosures. Ligeia specializes in Affordable Care Act and Federal employment tax matters, including worker classification, payroll tax R&D and other wage-based credits, self-employment tax, employee benefits, expense reimbursement, equity and nonqualified deferred compensation, payroll tax risk exposure analysis and due diligence, wage reporting on US and non-US citizens, tip reporting, and executive compensation.

Prior to joining PwC, Ligeia worked at Treasury’s Office of Tax Policy, Benefits Tax Counsel, and at the IRS Office of Chief Counsel for 10 years, where she helped lead various ACA and Federal employment tax initiatives and helped implement various legislative changes, including drafting and implementing ACA regulations, Federal employment tax regulations, and programs such as the Voluntary Classification Settlement Program, WOTC, and the Form 941-X program.  She managed projects dealing with accountable plans, fringe benefits, international employment tax, self-employment tax, worker classification, and interest-free adjustment and claims processes.

Ligeia received the 2014 Commissioner’s Award as part of ACA Program team and the Abraham N.M. Shashy National Customer Service Award for 2009.  She is also a frequent speaker at professional association meetings, including the American Bar Association.

Ligeia received her JD from the Catholic University of America’s Columbus School of Law and her BA from Duke University.


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)

 


Philip B. Wright is a Partner in the law firm of Bryan Cave Leighton Paisner LLP and is a member of the Tax Advice and Controversy Client Service Group.  His practice is concentrated primarily on advising clients in respect of the domestic and international tax aspects of inbound and outbound investment including acquisition structuring and related financing in all industries including real estate.  He regularly advises clients regarding the federal income tax aspects of the formation and operation of business entities.

Phil received his B.A. degree in Accounting from the University of Missouri, magna cum laude (1979), J.D. degree from Georgetown University, cum laude (1982), and his LL.M. from New York University (1985).  He serves as an adjunct professor in the School of Accountancy Master's program at the University of Missouri – Columbia where he teaches Partnership Taxation.  He frequently writes and speaks on tax issues involved in cross border merger and acquisition.  His prior professional experience includes practice as a tax specialist and CPA with a Big Four accounting firm.

Phil is a member of the Tax Section of the American Bar Association and New York State Bar Association. Phil also serves as a Member of Bloomberg BNA's Corporate Taxation Advisory Board.  He is a Fellow of the American College of Tax Counsel and is listed in The Best Lawyers In America.  He is admitted to practice in Missouri, New York and the District of Columbia.


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.


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.

 


Ninee is a Principal in the International Tax Services group at PwC based in New York with over 15 years of experience in a variety of U.S. international tax matters.  Ninee has worked extensively with major U.S. multinational corporations in technology, pharma, industrial products and financial services industries advising and assisting on U.S. tax issues on structuring of cross-border transactions.  She has worked on numerous projects involving tax efficient acquisition, integration and divestitures, establishment and operation of foreign holding company structures, intercompany financing, foreign cash repatriation, tax attributes management and global structuring alignment. 

Ninee has an S.J.D. (Doctor of the Science of Law) and an LL.M. (Master of Law) from the University of Michigan Law School.  She is a member of the New York bar.  Ninee earned her LL.B. (Bachelor of Law) and B.A. in Accounting from Thailand with first class honors and was awarded the King of Thailand Gold Medal.  After receiving her LL.B and B.A. she worked in the tax practice of PwC Thailand for 2 years.


Caroline H. Ngo works principally with Fortune 500 companies and is a go-to advisor for some of their most complex tax issues.  She specializes in global tax planning, cross-border mergers and acquisitions, and international tax matters.  Caroline is Co-Leader of McDermott’s International Tax practice.

Caroline is nationally recognized for her deep knowledge of her field and is regularly invited to speak at significant forums on corporate and international tax issues. In her commitment to the development of others, Caroline has served or is currently serving as a mentor for nearly all of the associates in the McDermott Washington Tax Group.


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.


David Forst focuses on international corporate taxation. David is included in Legal Media Group's Guide to the World's Leading Tax Advisers. He is also in Law and Business Research’s International Who’s Who of Corporate and Tax Lawyers (for the last eight years). David is listed in Legal 500 Hall of Fame, Chambers USA America's Leading Lawyers for Business (2011-2017), and has been named a Northern California Super Lawyer in Tax by San Francisco Magazine.

David is a lecturer at Stanford Law School and UC Berkeley Law School where he focuses on international taxation.  He is an editor of and regular contributor to the Journal of Taxation, where his publications have included articles on international joint ventures, international tax aspects of mergers and acquisitions, the dual consolidated loss regulations, and foreign currency issues. He is a regular contributor to the Journal of Passthrough Entities, where he writes a column on international issues. David is a frequent chair and speaker at tax conferences, including the NYU Tax Institute, the Tax Executives Institute, and the International Fiscal Association.

David graduated with an A.B., cum laude, Phi Beta Kappa, from Princeton University’s Woodrow Wilson School of Public and International Affairs, and received his J.D., with distinction, from Stanford Law School.

 


Andrea Sharetta is a Partner in the New York office of Dentons' Tax practice.  Her practice focuses primarily on a broad range of international tax areas, including cross-border restructurings and financing, Subpart F, US tax treaties, foreign tax credit planning, the tax treatment of inbound and outbound investments, and the new international tax rules enacted with the recent passage of US tax reform.  She also has expertise in federal income tax matters, including taxable and tax-free mergers, acquisitions, dispositions and other internal restructurings; and corporate joint ventures, as well as pre-immigration and expatriation planning for high net worth individuals.


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).

 


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. 

 


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. 

 


Nicole Welch is the senior manager of the IRS’s Treaty Assistance and Interpretation Team (TAIT) and U.S. Territories program, which is responsible for all non-allocation interpretive matters and double-tax cases arising under U.S. tax treaties and coordination agreements with the U.S. territories. Since joining TAIT in 2012, Nicole has participated in negotiations under the mutual agreement procedure article of U.S. tax treaties, the IRS’s engagement in Organisation for Economic Co-operation and Development and Forum on Tax Administration committees, and the activities of LB&I’s Treaty and Exchange of Information practice networks. Before joining TAIT, Nicole represented clients in tax planning and controversy matters at a law firm in Washington, DC. Nicole graduated from The University of Chicago Law School and Georgetown University.