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Basics of International Taxation 2019 San Francisco


Speaker(s): Andrea Sharetta, Corey M. Goodman, Danielle E. Rolfes, David L. Forst, Frank Y. Ng, Greg A. Texley, James S.H. Null, Jason R. Vollbracht, Jason Robertson, Jeremy Naylor, John L. Harrington, Justin E. Jesse, Kimberly T. Majure, Lisa M. Zarlenga, Megan E. Marlin, Narendra Acharya, Philip B. Wright, Prae Kriengwatana, Stephen R.A. Bates, Steven C. Wrappe, Steven J. Sideris
Recorded on: Sep. 9, 2019
PLI Program #: 252165

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).


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. 


Jason advises U.S. and foreign-based multinationals on a broad range of international tax matters. Prior to joining Deloitte, Jason was a Director of International Tax at a large toy manufacturer, where he focused on planning, implementing, reporting and defending various cross-border transactions, as well as a Senior Manager in the Tax Planning group of a large biotech firm, where he focused on supporting the company's Puerto Rican manufacturing and worldwide treasury operation.

Jason is part of Deloitte’s National Office in Washington, DC (International Tax group). He specializes in cross-border mergers and acquisitions, section 385, and various provisions under the 2017 Tax Cuts and Jobs Act.

Jason received a BA from the University of Michigan, and a JD and Master of Business Taxation from the University of Southern California.


Jason Vollbracht is a partner in Goodwin’s Tax group. His practice focuses on federal income taxation, with an emphasis on mergers and acquisitions, formation of investment funds, partnerships and other joint ventures, and real estate transactions. Prior to joining Goodwin in 2017, Mr. Vollbracht was counsel at Simpson Thacher.


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 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.


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)

 


Megan is a Director in PwC’s Tax Controversy and Regulatory Services group, where she specializes in federal employment taxes. She advises for-profit and tax-exempt organizations regarding domestic and international compliance and controversy issues before the IRS. Megan has significant experience counselling employers on travel expense reimbursements, fringe benefits, worker classification, equity compensation, third party payroll arrangements, U.S. employment taxes for inbound and outbound employees, and employment tax consequences of change of control events. Megan also represents taxpayers before the IRS to negotiate settlement agreements and navigate IRS examinations and appeals. For ten years, Megan has assisted taxpayers to determine U.S. withholding, depositing, and reporting obligations, navigate correction procedures, promote business efficiencies in meeting those obligations, and reduce tax and penalty exposure by enhancing compliance.

Prior to joining PwC, Megan was an attorney specializing in tax controversy and employment taxes at a mid-sized law firm in Baltimore, Maryland. She assisted companies with the negotiation of installment agreements and offers in compromise with the IRS as well as advised clients on general employment tax compliance matters. She was also the co-author of materials on worker classification during that period.

Megan earned her B.A. in International Relations from the College of William and Mary, a J.D. from Suffolk University Law School, and an LL.M. in Taxation with a Certificate in Employee Benefits from Georgetown University Law Center. Megan is also former Chair of the Employment Tax committee of the American Bar Association (ABA) Section of Taxation and frequent panellist. She is a member of the bar in Maryland and United States Tax Court. 


Narendra Acharya is a partner in the Chicago office of Baker & McKenzie LLP and a member of the Firm's Global Equity Services group.  He focuses his practice on matters relating to US and international employee benefits and executive compensation — including global stock plans and pensions, as well as matters pertaining to pensions, executive compensation and employment issues in mergers and acquisitions. Mr. Acharya has particular expertise dealing with cross-border compensation issues, including issues raised in corporate reorganizations and inversion transactions.  Mr. Acharya has been selected as a BTI Client Service All Star, which recognizes “innovative attorneys who are leveraging market changes to stand out with corporate counsel and deliver superior client service.”

Mr. Acharya assists US and non-US companies – both publicly traded and private – in the design and implementation of employee stock plans. He has extensive experience advising clients on income tax, social security, payroll withholding and reporting, local corporate tax deduction, employment law, securities and other regulatory issues applicable to equity awards in numerous jurisdictions. Mr. Acharya advises companies on the application of deferred compensation rules under Code Sections 409A and 457A, as well as a broad range of tax and compensation issues related to international mobile employees.

Mr. Acharya is a graduate of Cornell Law School and is licensed to practice in the States of New York and Illinois.  In addition, Mr. Acharya is also a Chartered Accountant (Province of Ontario, Canada).


Philip B. Wright is a Partner in the law firm of Bryan Cave Leighton Paisner LLP and is a member and co-leader of the Tax Advice and Controversy Practice 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 has taught Partnership Taxation and Mergers and Acquisitions Taxation.  He has served as an adjunct professor in the Masters Tax Program at Washington University School of Law.  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.


Prae Kriengwatana is a Director with PwC’s Washington National Tax Services (WNTS) practice where she specializes in providing international tax services. She is involved in on-going international tax reform issues and assists U.S. and foreign-based multinational clients with designing and implementing tax efficient structures and financing mechanisms. Prae has worked with clients across various industry sectors, including oilfield services, manufacturing, and private equity.

Prior to her current role at WNTS, Prae was in the International Tax Services group in the PwC Houston Office. Prae earned her B.A. from the University of Waterloo and her J.D. from Osgoode Hall Law School in Toronto, Canada. Prae is a member of the New York State Bar Association.


Specialty:

Stephen is a principal in the National Tax Department, based in San Francisco. Stephen provides tax advice to multinational corporations on transactional and controversy matters, including transfer pricing, intellectual property alignment, international restructuring and supply chain management. He advises large multinationals in a variety of industries, including the software, semiconductor, life sciences, consumer products, manufacturing, and services sectors.

           

Background

Prior to joining Ernst & Young LLP, Stephen was a principal at another Big Four firm and an international tax associate at the law firm of Weil, Gotshal & Manges LLP.

Stephen is a frequent speaker on international tax issues before various organizations, including Tax Executives Institute, the D.C. Bar Association, and the American Tax Association. He is the author of numerous articles regarding international tax reform and the technology industry (Tax Notes International), contract manufacturing (Tax Notes International), manufacturing branch rules (Journal of Corporate Taxation), planning for cross-border services (Tax Notes), taxation of space, ocean and communications income (Journal of International Taxation and TAXES Magazine), sourcing of computer software royalties (Tax Management International Journal), cloud computing (Tax Notes), offshore e-commerce (Journal of Taxation of Financial Institutions) and attribution of corporate agent activities (Georgia Law Review).

Stephen earned a J.D. with high honors from the George Washington University Law School and a B.A. from Northwestern University in political science and international studies. Stephen is admitted to the New York and District of Columbia bar.


Steve Sideris is a Principal in the EY Los Angeles transfer pricing practice.

Steve’s experience includes global documentation, planning and controversy for multinational companies. He regularly consults with companies regarding US tax reform and the OECD’s BEPS action items related to transfer pricing.

Steve has assisted clients in a variety of industries, including technology, life sciences, financial services, retail and consumer products, telecommunications, media & entertainment and healthcare.

Steve has significant experience leading transfer pricing engagements related to intellectual property valuation, restructuring & supply chain planning, global documentation, advance pricing agreements. and tax due diligence.

Steve holds a BA in economics from Trinity College and an MBA in finance & operations from Boston University. Steve is a Candidate Member of the American Society of Appraisers and holds a graduate certification in taxation from Bentley University. He is a speaker at TEI conferences on transfer pricing developments.


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.

 


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.


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.