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Tax Planning for Partnerships 2020: Highlights and Hot Topics


Speaker(s): Bahar A. Schippel, Benjamin J. Applestein, Bradley M. Seltzer, Bryan C. Skarlatos, Christopher Trump, Clifford M. Warren, David H. Kirk, David H. Schnabel, Eric B. Sloan, Eric Solomon, Glenn E. Dance, James B. Sowell, Jeffrey M. Trinklein, Jennifer H. Alexander, Karen Lohnes, Kimberly S. Blanchard, Phillip Gall, Samuel T. Greenberg, Sara B. Zablotney, Stephen D. Rose, Todd D. Golub
Recorded on: May. 12, 2020
PLI Program #: 300061

Bahar Schippel is a Partner with the law firm of Snell & Wilmer L.L.P. in Phoenix, Arizona.  She specializes in tax planning for mergers and acquisitions, joint ventures and real estate transactions, drafting LLC and partnership agreements, tax planning in connection with fund formation and operations, structuring tax-efficient debt workouts, designing service provider equity compensation for LLCs and partnerships and representing taxpayers before the Internal Revenue Service. Bahar served on the Council of the ABA Tax Section and is a Past Vice Chair (Pro Bono and Outreach) thereof. Bahar is a Past Chair of the ABA Tax Section Partnership Committee. She is currently a member of the ABA's National Conference of Lawyers and CPAs. Bahar is also the Past Chair of the Tax Section of the State Bar of Arizona and is the Past Chair of the Arizona Tax Advisory Commission, which oversees the tax specialization program in Arizona. She is also a Regent of the American College of Tax Counsel, and a member of the Bloomberg BNA Real Estate Advisory Board and the Wolters Kluwer Legal Tax Advisory Board, which all include some of the nation's leading authorities on tax law. Bahar frequently speaks at national and regional tax conferences and contributes articles to top-tier tax publications. Prior to joining Snell & Wilmer, Bahar served as Attorney-Advisor for the United States Tax Court in Washington, DC, and as Teaching Assistant to the Honorable David Laro at Georgetown University Law Center.


Ben Applestein is a principal in the Passthroughs group in the National Tax Office of Deloitte Tax LLP in San Francisco, where his practice focuses on the use of partnerships and limited liability companies in domestic and cross-border mergers and acquisitions, financing transactions, restructurings, and capital markets. 

Prior to joining Deloitte, Ben worked as a Senior Vice President in Tax Advisory at Macquarie Holdings (USA), an Australian investment bank in New York and as a tax associate at Simpson Thacher and Bartlett in New York and Palo Alto, where he worked on a number of notable acquisitions, capital markets offerings, and private equity funds.

Ben has represented a wide array of clients including some of the largest private equity firms in the country.  

 

Education & Certifications

  • Attorney, licensed to practice in California and New York
  • New York University – LL.M. (Tax)
  • University of California, Hastings College of the Law – J.D.
  • Duke University – A.B.


Brad Seltzer brings nearly 40 years of experience representing Fortune 100 companies, especially utility, energy and telecom clients in complex tax matters. Strategies. He also represents clients in large tax disputes with the Internal Revenue Service (IRS) at both the trial and appellate court levels, and prepares private letter rulings, technical advice requests and accounting method changes for the IRS National Office.


Christopher is the Principal-in-charge of Deloitte’s Washington National Tax - International Tax Services group.  He regularly advises clients on issues involving foreign currency, loss surrender and utilization, and the design and implementation of principal company structures. He serves multinational companies in a variety of industries specializing in mergers and acquisitions, foreign tax credit planning, financing transactions, repatriation, and the utilization of partnerships in cross-border transactions. 

Prior to joining Deloitte, Mr. Trump was the Assistant to the Branch Chief, Branch 4, in the Office of the Associate Chief Counsel (International) for the Internal Revenue Service. Mr. Trump also worked in the Office of the Associate Chief Counsel (Passthroughs & Special Industries).  He is a frequent speaker and is the author of numerous articles on tax planning for U.S. based multinational corporations.


Cliff Warren is Senior Level Counsel in the Passthroughs division of IRS’ Office of Chief Counsel.  Prior to this position, Cliff was head of tax at KKR.  Before that, he was head of tax at a large NYC hedge fund and a tax leader at the company formerly known as GE Capital.  Cliff is a graduate of Middlebury College, New York Law School and NYU’s LLM program.


Eric Solomon is a partner at Steptoe & Johnson LLP in Washington DC, where he advises clients on a wide range of transactional and policy issues.  Before joining Steptoe he was Co-Director of Ernst & Young LLP’s National Tax Department in Washington DC.  He has over 40 years of tax experience in private practice and government service.

Eric served as Assistant Secretary for Tax Policy at the U.S. Treasury Department from December 2006 to January 2009.  As Assistant Secretary, he headed the Office of Tax Policy, which serves as the primary advisor to the Treasury Secretary on legal and economic matters relating to domestic and international taxation.  Eric joined the Office of Tax Policy in 1999.  He served in both the Clinton and George W. Bush Administrations.  He was Senior Advisor for Policy, Deputy Assistant Secretary (Tax Policy) and Deputy Assistant Secretary (Regulatory Affairs) prior to his 2006 Senate confirmation as Assistant Secretary.  He led the Office of Tax Policy during the financial crisis in 2008.

Eric has received numerous awards for his government service.  In recognition of his contributions at the Treasury Department, Eric received the Alexander Hamilton Award, which is the highest award for Treasury service, and the Distinguished Presidential Rank Award.  He has also received distinguished service awards from the Tax Foundation, the Tax Council Policy Institute, Tax Executives Institute, and the taxation sections of the State Bar of California, the State Bar of Texas, and the Federal Bar Association.

From 1996 to 1999, Eric was a principal in Ernst & Young LLP’s National Tax Mergers and Acquisitions group in Washington, DC.  Previously, he was Assistant Chief Counsel (Corporate) at the Internal Revenue Service, heading the IRS legal division responsible for all corporate tax issues.  He began his career with law firms in New York City and was a partner at Drinker Biddle & Reath in Philadelphia.

Eric received his A.B. from Princeton University (Phi Beta Kappa), his J.D. from the University of Virginia and his LL.M. in taxation from New York University.  He was Chair of the American Bar Association Section of Taxation in 2018-2019, and was formerly a member of the Executive Committee of the Tax Section of the New York State Bar Association. He is Co-Chair of the Practising Law Institute conference on Tax Strategies for Corporate Acquisitions and Dispositions.

Eric is an adjunct professor at Georgetown University Law Center, where he teaches a course in corporate taxation.  He received the Distinguished Adjunct Professor Award for Georgetown University’s graduate law programs.


Eric Sloan is a partner in the New York and Washington DC 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 focuses his tax practice on the use of partnerships and limited liability companies in domestic and cross-border mergers and acquisitions, financing transactions, and restructurings. He also has developed substantial experience in initial public offerings, including advising on many “UP-C” IPOs in a range of industries.

Mr. Sloan has represented four of the largest private equity firms and the two largest privately held companies in the United States, as well as many publicly traded companies. He advised on the first publicly traded "permanent capital fund" launched by a major U.S.-based private equity firm and the first pass-through portfolio company investments made by four of the largest U.S.-based private equity firms.

He 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. He has also handled restructurings of partnerships, as well as private equity fund structuring and leveraged recapitalizations of private equity portfolio companies. 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 him as an "excellent technician" and "articulate and extremely fast." In 2016,

Who’s Who Legal recognized Mr. Sloan as an “Expert” in the area of Corporate Tax.

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.

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 in 1990. He also earned 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.


Glenn is a partner at Holthouse, Carlin, Van Trigt (HCVT) in Orange County, CA.  From 2015-2017, Glenn served as special counsel to the IRS Associate Chief Counsel - Pass-thrus and Special Industries.  He was previously a partner at Arthur Andersen from 1993-2002 and at Ernst and Young from 2002-2014, and a managing director at Grant Thornton from 2017-2019.  Glenn has also taught partnership tax at The Georgetown University Law Center, the Villanova School of Law, the University of Southern California and Golden Gate University.    Glenn obtained his bachelor of Business Administration from Temple University in 1978 and a JD from Temple University School of Law in 1981.  He has practiced in Dallas, Los Angeles and Washington DC, and is a member of the Texas State Bar and a CPA in Washington DC. 


Jeffrey M. Trinklein is a partner in the London and New York offices of Gibson, Dunn & Crutcher and serves as Co-Partner-in-Charge of the London office, and Co-Chair of Gibson Dunn’s Tax Practice Group.

Mr. Trinklein has extensive experience in U.S. and international taxation, with special emphasis on advice to foreign clients with investments in the United States and advice to U.S. clients with foreign operations.

Mr. Trinklein’s areas of practice include advice to U.S. individuals and companies establishing investments outside the U.S., planning advice on worldwide investment structures and acquisition financing and general U.S. corporate and partnership tax planning.  He has represented clients with tax structuring for a range of mergers and acquisition transactions, ranging from public company acquisitions, to private equity fund transactions, to the acquisition of a U.S. professional sports franchise.  He has also assisted foreign countries with the drafting of proposed legislation.

Mr. Trinklein is ranked by The Best Lawyers in America©, Chambers Global:  The World’s Leading Lawyers for Business, Chambers USA:  America’s Leading Lawyers for Business and The Legal 500 United States as a leading tax lawyer.  Chambers USA describes Mr. Trinklein as “a creative and confidence-inspiring practitioner who can effectively communicate tax nuances” and “communicates clearly and is always very responsive and ready to assist, often in a compressed timeframe.”

Mr. Trinklein joined Gibson Dunn in 1985 and has previously worked in Gibson Dunn’s Munich, London, Dallas and Orange County offices.  From 1998 to 2002, Mr. Trinklein was a member of the Adjunct Faculty at Southern Methodist University’s Dedman School of Law, where he taught courses on U.S. taxation of international transactions and financial derivatives.  Mr. Trinklein has also served as an adjunct faculty member at the London Program of the University of  Detroit School of Law and lectures and writes frequently on tax law topics.  He has a working knowledge of German and French.

Mr. Trinklein received his Juris Doctor, with honors in 1985 from the University of Virginia and his bachelor’s degree in 1982 from the University of Chicago.  Mr. Trinklein is a member of the New York State Bar Association.


Jennifer H. Alexander is the Co-Managing Principal of the Passthroughs group in the National Tax Office of Deloitte Tax LLP, where she specializes in the use of partnerships and limited liability companies in domestic and cross-border mergers and acquisitions, financing transactions, and restructurings.

Prior to returning to Deloitte, Jennifer served in the Office of Tax Legislative Counsel at the U.S. Department of the Treasury as an Attorney Advisor.

Jennifer is the co-author of the WG&L treatise on Partnership taxation.  In addition, she has authored articles that have appeared in numerous professional publications, including Tax Notes, Journal of Taxation, TAXES, and Tax Planning for Domestic & Foreign Partnerships, LLCs, Joint Ventures, & Other Strategic Alliances (Practising Law Institute).  Jennifer is a frequent lecturer on a variety of topics dealing with U.S. federal income taxation, having spoken at many of the country’s leading tax conferences, including the Practising Law Institute, the Southern Federal Tax Institute, the New York University’s Institute on Federal Taxation and Summer Institute on Federal Taxation, the American Bar Association Tax Section, and the Tax Executives Institute.

Jennifer received her B.A. in Government and Politics from the University of Maryland, and her J.D. from the Georgetown University Law Center.  Jennifer is a member of the American Bar Tax Section and Vice Chair of the Tax Section’s Committee on Partnerships and LLCs.  She is a member of the State Bar of Maryland and is admitted to practice in 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.  


Phillip Gall is a Principal in the Partnership Transaction Planning & Economics Group in Ernst & Young LLP’s National Tax Department and is located in New York. He focuses on the taxation of partnerships, joint ventures, and limited liability companies. Phillip has significant experience in the formation, operation, and unwinding of these types of entities for large multinationals and for investment funds in both the international and domestic context.  Phillip is an Adjunct Professor at New York University School of Law, where he has taught partnership tax courses for a number of years, and is a member of the Executive Committee of the New York State Bar Association Tax Section. Phillip has a B.S.B.A., summa cum laude, from Washington University and a J.D., cum laude, and LL.M. (Tax) from New York University School of Law.


Sara Zablotney is a partner in the New York office of Kirkland & Ellis LLP.  She focuses her practice on the tax aspects of mergers, acquisitions, divestitures, joint ventures and spin-offs, both domestic and cross-border. She also advises clients on the tax aspects of securities issuances, bankruptcy and restructuring, and investment fund formation.  Sara was recognized by Chambers USA for Tax [NY] from 2017–2018, as a Law360 MVP for Tax in 2017, as a “Rising Star” by Law360 for Tax Law in 2014, and is recommended by The Legal 500 U.S.   Sara received her B.A. from Duke University (magna cum laude) in 1999 and her J.D. from New York University School of Law (cum laude) in 2002, where she received the Leonard J. Schreier Memorial Prize in Ethics and the Norma Z. Paige Award.  She speaks frequently on topics relating to mergers and acquisitions and private equity.  She is a member of the New York State Bar Association Tax Section’s Executive Committee, where she is Co-Chair of the Partnerships Committee.  She currently sits on the Advisory Board for the Kenan Institute of Ethics at Duke University, and formerly sat on the Advisory Board for the Sarah P. Duke Gardens.


Stephen was most recently a partner and the global head of tax at TPG Global in San Francisco, CA.

Prior to joining TPG in February, 2018, Stephen was a partner of Munger, Tolles & Olson LLP in Los Angeles, concentrating on the structuring and taxation aspects of complex business transactions, including mergers and acquisitions, joint ventures, private equity transactions, workouts and restructurings, and innovative financings. 

Mr. Rose has been selected for inclusion in Chambers USA, and is a fellow of the American College of Tax Counsel.  He received a B.A. from the University of California at San Diego, an M.B.A. from the University of California at Berkeley, a J.D. from the University of California, Hastings College of the Law and an LL.M. in taxation from New York University School of Law, where he served as a graduate editor of the Tax Law Review and was the recipient of a Tax Law Review merit scholarship. 

Stephen has also served for many years as an adjunct law professor at both the UCLA School of Law and the USC School of Law, teaching advanced corporate and partnership taxation courses.  He is a frequent lecturer at national conferences, including the NYU Tax Institute, the Tax Executives Institute, the USC Tax Institute, and Practising Law Institute programs, and has written many articles on a variety of taxation subjects.  Currently, Mr. Rose is on the Executive Planning Committees for both the NYU Tax Institute and the USC Tax Institute (Chair), and serves as co-chair for the Practising Law Institute Partnership Tax program.

In addition to his professional activities, Mr. Rose was a longtime trustee of the Curtis School in Los Angeles, where he was Board Chair from 2012 to 2017.


Todd is a principal in the Partnership Transactional Planning & Economics Group of Ernst & Young LLP’s National Tax Department, based in Chicago, Illinois.  Todd regularly advises clients on a wide range of partnership transactions, both domestic and international with a particular emphasis on private equity transactions, fund formation, applying partnership techniques in large corporate acquisitions, strategic alliances, international joint ventures and restructurings.  He also advises investors (taxable and tax-exempt) on the tax aspects of fund investments (PE, VC, real estate, and others). 

Prior to joining Ernst & Young, Todd was a partner in an international law firm where his tax practice focused primarily on partnership planning, mergers and acquisitions, and real estate transactions.

Todd has written many articles on federal income tax matters for such publications as the Journal of Taxation and TAXES.  Todd is a regular speaker on partnership tax issues and has spoken at many conferences including the Tax Executives Institute, the American Bar Association, the University of Chicago’s Federal Tax Institute, New York University’s Institute on Federal Taxation, USC Tax Institute, ALI-ABA, the Texas Tax Institute, Southern Federal Tax Institute, and Practising Law Institute.

Todd was a lecturer at the University of Chicago Law School where he taught a course on partnership taxation.

He is a member of the American Bar Association’s Section of Taxation, and is a past Chairman of the Committee on Partnerships and LLCs.   

Todd received his B.S. and J.D. from Indiana University and his LL.M (Taxation) from the New York University School of Law.


For more than thirty years, Bryan C. Skarlatos has represented individuals and corporations in civil and criminal tax controversies, white collar criminal matters, regulatory investigations, tax whistleblower cases and voluntary disclosures. He is often hired as an expert on tax standards, penalties and procedures. 

Mr. Skarlatos is an adjunct professor at New York University School of Law, where he teaches a course on Tax Penalties and Prosecutions.  He created and chairs the annual New York University Tax Controversy Forum and the Practicing Law Institute program on Nuts and Bolts of Tax Penalties.  Mr. Skarlatos is a fellow in the American College of Tax Counsel and he also has served as the chair of tax committees for many bar associations including the American Bar Association, New York State Bar Association and New York City Bar Association.

Mr. Skarlatos has been recognized by New York Super Lawyers as one of the Top 100 lawyers in New York and he is listed in Best Lawyers in America where he was named Tax Litigator of the Year in New York for 2014 and 2017.  He also is ranked in Band One of Chambers USA: America’s Leading Lawyers for Business, which describes him as having a, “smart reassuring presence with insight into the government…extremely knowledgeable and very well connected to the various taxing authorities…Clients applaud him as being exceptionally brilliant at coming up with great outcomes.”

Mr. Skarlatos speaks throughout the country on tax-related topics and he frequently is quoted in publications such as The Wall Street Journal, USA Today, Forbes, Bloomberg, Reuters, Financial Times, Tax Analysts-Tax Notes, and Bloomberg BNA Daily Tax Report.

 


David is a partner in the National Tax Department of Ernst & Young LLP in Washington, D.C.  Throughout his career, David has focused primarily on the taxation of individuals, trusts, S corporations and partnerships. 

Prior to joining Ernst & Young LLP in March 2014, David was an attorney in the Passthroughs and Special Industries division of the Office of Chief Counsel, Internal Revenue Service. Within Chief Counsel, David specialized in federal income taxation of estates and trusts, S corporations, and partnerships (Subchapters J, K and S of the Internal Revenue Code), as well as certain other tax matters of general applicability to individuals and estates & trusts. Most notably, David was the principal author of the income tax regulations under Section 1411 of the Internal Revenue Code (Net Investment Income Tax) and Revenue Procedure 2013-30 (Unified Late S Corporation Elections). David is the author of the Bloomberg-BNA Tax Management Portfolio 511-1st: Section 1411 — Net Investment Income Tax.

Before joining Chief Counsel, David was an associate in the tax practice of Arnold & Porter LLP in Washington, D.C.  Prior to joining Arnold & Porter LLP, David spent eight years in the Private Client Advisors group of Deloitte Tax LLP. 

David earned a Bachelor of Science in Accounting from Syracuse University and a JD from the University of Pittsburgh. He also earned an LLM in Taxation from Georgetown University Law Center and has served as an adjunct professor in the same program since 2009. David is also a member of the advisory boards of AICPA's Journal of Accountancy. 

David is a Certified Financial Planner, a certified public accountant in the District of Columbia and a member of the bar in the District of Columbia and Pennsylvania.


Jim Sowell is a Principal at KPMG LLP and leads the Real Estate Practice in KPMG’s National Tax Office.  Jim’s practice is focused primarily on tax issues relating to partnerships, REITs, and debt workouts with respect to such entities.  Jim previously was an Associate Tax Legislative Counsel in the Office of Tax Policy at the U.S. Treasury Department where he was responsible for legislation and guidance relating to partnerships, REITs, and like-kind exchanges.  Jim is a former Chairman of the Real Estate Committee of the American Bar Association (Tax Section) and a former Vice Chairman of the Real Estate Roundtable’s Tax Policy Advisory Committee. Jim is a member and former President of the Board of Trustees for the Southern Federal Tax Institute and is an active participant on NAREIT’s Government Relations Committee. Jim has written numerous articles and speaks extensively on partnerships and REITs.

Jim has his undergraduate and law degrees (both with high honors) from the University of Florida and has an LL.M. in taxation from New York University, where he served as an editor on the Tax Law Review.

 


Karen Lohnes is the leader of the PwC Passthrough Group.  She is a fully dedicated specialist in all aspects of Partnership taxation.  Mrs. Lohnes assists clients with joint venture matters, including structuring domestic and foreign partnership acquisitions and disposition transactions.

Mrs. Lohnes has extensive consulting experience in the areas of partnership formation and operational issues, including disguised sales, substantial economic effect analysis and section 704(c) methods.  Her experience also includes treatment of contractual alliances, application of section 197, basis adjustments and section751 analysis.
Prior to joining the legacy firm PricewaterhouseCoopers LLP, Mrs. Lohnes was a tax associate with Covington & Burling where she focused on partnership, corporate and general tax matters.  She also served as a law clerk to US Tax Court Chief Judge Lapsley Hamblen, Jr.

Mrs. Lohnes is a regular speaker at national conferences including PLI, TEI and ABA.  She is a co-author of the BNA on LLCs and author of numerous articles including, “Value equals basis and partners’ distributive share; stuffing, fill-ups, and waterfalls,” and “Controversial Ruling Requires Gain to be Recognized on Distributions From Merged Partnership” both published in Journal of Taxation, “Foreign Partnership: Rules, Issues, and Planning Opportunities Regarding U.S. Filing Requirements,” published in International Tax Journal, “Effecting Capital Gain Treatment on Disposition of a Partnership Interests,” published in the University of Southern California Tax Institute’s Major Tax Planning and “Maximizing Section 197 Amortization in Partnership Transactions” and “To File or Not to File, That is the Question for Foreign Partnerships,” published in The Tax Advisor.  She is a member of the ABA Partnership Tax Committee and is chair of the Partnership Workout Subcommittee.

Education and credentials
Mrs. Lohnes holds a J.D. from Boston University School of Law, where she graduated summa cum laude and served as Editor on the Boston University Law Review.  She also holds a B.S. Accounting from Louisiana State University.


Kim Blanchard is a partner in Weil’s Tax Department whose practice encompasses a variety of largely international transactions involving corporate acquisitions and mergers, internal restructurings, business formations and joint ventures. Ms. Blanchard also advises domestic, foreign and multinational clients in connection with venture capital investment and fund formation, partnerships, real estate and exempt organization issues.

Ms. Blanchard has lectured and published extensively on topics ranging from international tax planning for U.S. businesses to the special tax issues facing foreign persons, pension plans and other exempt investors who invest in U.S. private equity partnerships and in U.S. real estate.

Ms. Blanchard is consistently recognized as a leading Tax lawyer by Chambers USA, Chambers Global, Legal 500 US, Best Lawyers in America and The Best of the Best USA.  She is a former Chair of the New York State Bar Association Tax Section and past President of the International Tax Institute. She is the author of the Tax Management Portfolio on PFICs, a “Leading Practitioner Contributor” to the Tax Management International Journal and a member of Practical Law Company’s U.S. advisory board. In addition, Ms. Blanchard is a member of the Board of Trustees of the American Indian College Fund and of the Board of Directors of the Girl Scouts of Greater New York.

 


Samuel Greenberg is a principal in the national office of Ernst & Young LLP, where he specializes in partnership and pass-thru transaction planning. He has experience in all aspects of federal taxation and concentrates primarily on the use of partnerships in formations, acquisitions, dispositions, mergers and restructurings. He has also worked extensively with ultra-high-net-worth families, investment funds and tax-exempt entities.  Mr. Greenberg is a frequent speaker at industry forums and tax conferences. He also teaches partnership tax at the University of Southern California Gould School of Law and has previously taught income tax timing at Loyola Law School.