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International Tax Issues 2021


Speaker(s): Angela E. Holland, Ari Berk, Christopher Trump, Danielle E. Rolfes, Diana S. Doyle, Elizabeth Nelson, José E. Murillo, Joseph M. Calianno, Kimberly S. Blanchard, Laura Williams, Michael A. DiFronzo, Oren Penn, Peter A. Glicklich, Peter H. Blessing, Rocco V. Femia, Ronald A. Dabrowski, Stephen R.A. Bates, Thomas M. Zollo
Recorded on: Feb. 2, 2021
PLI Program #: 304630

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).


Angela Holland is a senior counsel in Branch 6 of the Office of the Associate Chief Counsel (International). Branch 6 is responsible for international transfer pricing as well as a number of other practice areas. In her time at the IRS, Angela has worked on a range of complex cross-border transactions, including transfers of tangible and intangible property, intercompany services, intercompany financial transactions, restructurings, cost sharing arrangements, tax shelter transactions, and advance pricing agreements (APAs). Before joining the IRS, Angela worked for several years in private practice in the area of structured finance tax. She received a B.S. in Finance from Morgan State University and a J.D. and MBA from Howard University.      


Ari Berk is a Principal in the Passthroughs group in the Washington National Tax Office of Deloitte Tax LLP.  He specializes in the taxation of partnerships and their partners in domestic and cross-border mergers and acquisitions, financing transactions, and restructurings.  Ari has extensive experience with issues straddling the intersection between the rules governing partnerships and international taxation.  Prior to re-joining Deloitte, Ari was an Attorney Advisor in the Office of Tax Legislative Counsel at the U.S. Department of the Treasury, a senior manager in the same Passthroughs group in which he is now a Principal, and an attorney for the Internal Revenue Service, Office of Chief Counsel in the Passthroughs and Special Industries division.


Background

Ron is the Technical Deputy in KPMG’s Washington National Tax office.  He has over 20 years of experience in international and business taxation.  He was a partner at KPMG from 2004 through 2010 and returned to KPMG in 2014 after serving in a variety of executive positions in the federal government:

  • Special Counsel in the Treasury Department’s Office of Tax Policy;
  • International Tax Counsel on the Majority Staff of the Senate Finance Committee; and
  • Deputy Associate Chief Counsel (International – Technical) at the IRS Chief Counsel’s office.

 

Professional and industry experience

Ron has extensive experience in large-scale, cross-border mergers and acquisitions, including the planning and execution of business separations and acquisition integration.  Ron’s experience spans industries.  He has extensive experience in telecommunications, pharmaceuticals, financial businesses, oil & gas, and oil-field services. 

Ron has also taken leadership roles within KPMG on emerging and cutting edge issues, including leading ongoing initiatives in evaluating the reformed tax system.  Ron is also part of KPMG’s Complex Transactions Practice.

 

Publications and speaking engagements

Ron is a co-author with Kevin Dolan et al of U.S. Taxation of International Mergers, Acquisitions, and Joint Ventures (Warren, Gorham & Lamont).  He is a frequent speaker and writer on a variety of international tax and tax policy topics.

 


Christopher is the Principal-in-charge of Deloitte’s Washington National Tax - International Tax and Transfer Pricing 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.


Diana Doyle chairs the Chicago Tax Department, where her practice focuses on tax planning for multinational companies, with an emphasis on private and public company mergers and acquisitions.

She has advised domestic and international companies on such matters as structuring taxable and tax-free stock and asset acquisitions and dispositions, cross-border migrations, tax-free reorganizations and spin-offs, securities offerings, limited liability company agreements and partnership tax. Ms. Doyle also has significant experience with tax audits, administrative appeals and litigation.

Ms. Doyle serves as a member of and is a past chair of the planning committee for the University of Chicago Tax Conference and is a frequent writer and speaker on a variety of tax topics, including the following recent articles and presentations:

  • “TCJA & CARES Act Interactions – Traps for the Unwary” at Tax Executives Institute 75th Annual Conference (2020)
  • Investment Banking: Valuation, LBOs, M&A, and IPOs – Third Edition (2020) (Contributor)
  • “Cross-Border M&A Planning and Development” at Practising Law Institute’s International Tax Issues Conference (2019)
  • “The Graphic Guide to Section 163(j),” published in Tax Executive Institute Magazine (March/April 2019)
  • “International Joint Venture Issues” at Practising Law Institute’s Tax Planning for Domestic & Foreign Partnerships, LLCs, Joint Ventures & Other Strategic Alliances Conference (2019)
  • “Tax Issues in M&A Contracts” at Practising Law Institute’s Tax Strategies for Corporate Acquisitions, Dispositions, Spin-Offs, Joint Ventures, Financings, Reorganizations & Restructurings Conference (2019)
  • “Back in Time: In Search of a Coherent Theory of Transactional Retroactivity,” published in the University of Chicago Federal Tax Conference edition of TAXES (March 2017).

Chambers USA consistently ranks Ms. Doyle for her efforts in the Tax practice, and she has been recognized by The Legal 500 for her work in the US Taxes: Non-Contentious practice. She chairs Latham’s Brexit Task Force and is a member of its global strategic Initiatives Committee. Ms. Doyle is a past board member of the Chicago-based Coalition of Women’s Initiatives in Law and a past Advisory Board member of Latham’s Women Enriching Business (WEB) initiative.

Education

  • JD, University of Chicago Law School, 1996
  • BS, Northwestern University, 1988


Elizabeth Nelson is a Partner in International Tax Services in the Washington National Tax Services office of PricewaterhouseCoopers LLP. 

Elizabeth primarily specializes in outbound international taxation. 

Elizabeth has a broad background in international tax, however, her areas of expertise include dual consolidated losses, foreign tax credit (FTC) limitation matters and other FTC matters, and gain recognition agreements. 

Elizabeth is a C.P.A. and has a Masters in Taxation from the University of Texas at Austin.


Joe Calianno is a Managing Director in the US National Tax practice in the Washington D.C. office. He advises clients on all areas of international tax, including provisions related to the Tax Cuts and Jobs Act and cross-border restructuring.

Prior to joining Andersen, Joe spent several years as a partner at BDO and Grant Thornton, where he served as the International Technical Tax Practice Leader in both firm’s national tax offices.

Joe also previously served as Special Counsel to the Deputy Associate Chief Counsel (International) in the office of Chief Counsel, Internal Revenue Service. As Special Counsel, he was a technical advisor to the Associate and Deputy Associate Chief Counsel International and was involved in reviewing international tax regulations, revenue rulings, Notices, TAMs, PLRs, and providing technical advice to the IRS field offices. He also practiced with PWC’s National Tax office and Miles & Stockbridge, a large law firm.

Joe has been a guest lecturer at New York University Law School in the Graduate Tax Program (International Business Transactions class) and an adjunct faculty member at Georgetown Law School in the Graduate Tax Program.

Joe is a frequent speaker on international and corporate tax issues. He has spoken for organizations such as the ABA, AICPA, Atlas, BNA, DC Bar, Dallas Bar, Federal Bar, GW/IRS, Houston International Tax Forum, IFA, NYU Advanced International Tax Institute, Practising Law Institute, TEI, St. Louis International Tax Group, USD School of Law/Procopio International Tax Institute, Wall Street and World Trade Council tax conferences.

He has also published articles for national journals and organizations such as CCH Incorporated, International Tax Review, RIA’s Journal of International Taxation, Practising Law Institute, Tax Notes International, Tax Management International Journal, Tax Management Memorandum and The Tax Adviser.

Joe has held leadership positions in several organizations, including the ABA, AICPA, IFA and the Federal Bar.  Joe is both a CPA and attorney.

 

EDUCATION

  • New York University School of Law, LLM (Taxation)
  • New York University Leonard N. Stern School of Business, MBA
  • Villanova University School of Law, JD, Villanova Law Review
  • University of Scranton, BS (Accounting)

 


José Murillo assumed his position as Deputy Assistant Secretary, International Tax Affairs, in the U.S. Treasury Department’s Office of Tax Policy on March 1, 2021. In his role as DAS, International Tax Affairs, José provides advice and counsel to the Assistant Secretary (Tax Policy) related to international tax policy and tax treaties.

Prior to assuming his current role, José was a partner and the leader of the international tax and transaction services practice in Ernst & Young LLP’s (EY) National Tax Department based in Washington, D.C.  José’s practice focused primarily on cross-border acquisitions, dispositions, and restructurings, and most recently he led EY’s initiatives around the 2017 Tax Cut and Jobs Act.

Prior to rejoining EY in August 2010, José spent approximately three years with the US Treasury Department’s Office of the International Tax Counsel, where he assisted in the development of international tax policy, Treasury regulations, and in negotiating income tax treaties.

Prior to joining the U.S. Treasury Department in 2007, José was a member of EY international tax services practices in Houston and Washington, DC.

 


Michael A. DiFronzo serves as a Principal in and leader of the International Tax Services group in the Washington National Tax Office of PwC.  In that role, Michael serves as a global resource for the firm’s international tax practice.  His practice includes all aspects of international taxation, with a particular focus on international mergers, acquisitions and restructurings and the U.S. anti-deferral rules.  He also works closely with U.S. and non-U.S. based multinationals on cross-border financing, cash repatriation and other planning issues.  

Before joining PwC, Michael was a senior executive in the U.S. Treasury Department.  He worked for the Office of Chief Counsel, Internal Revenue Service as the Deputy Associate Chief Counsel (International – Technical).  In that capacity, he had primary responsibility for the oversight of published guidance related to the taxation of cross-border investment and related issues.  Michael served in that role from 2006 - 2010.

Prior to joining the Office of Chief Counsel, Internal Revenue Service, Michael served as a partner in the Tax Department of McDermott Will & Emery LLP in Chicago, Illinois.  There he served as an international tax attorney for large U.S. and non-U.S. multinational corporations.  Michael’s work experience also includes the National Tax Office of Deloitte & Touche LLP and the Washington, DC office of Weil Gotshal & Manges LLP.

Michael received an LL.M. in taxation from New York University School of Law, a J.D. from University of Montana School of Law, and a B.S. in Accounting from Montana State University.  Michael served on the Board of International Tax Advisors and as a guest lecturer for New York University School of Law’s graduate tax program from 1999 - 2010.   Michael also served on the Board of Visitors for the University of Montana School of Law from 2006 - 2011.

Michael’s professional affiliations include the tax sections of the American Bar Association and the DC Bar Association, as well as the International Fiscal Association.  He is the author of numerous articles on cross-border tax issues and a frequent speaker.  Michael is currently a member of the District of Columbia, Illinois, Montana and Nevada bar associations and is admitted to practice before the United States Tax Court.  He is also licensed as a CPA.


Mr. Blessing is the Associate Chief Counsel (International) in the office of Chief Counsel, Internal Revenue Service. He oversees an office of approximately 95 attorneys and other professionals responsible for legal advice, guidance, and support to the IRS, Treasury, and the public on international tax issues in all procedural postures. 

Prior to joining the IRS Chief Counsel’s office, Mr. Blessing practiced as a member of the International Tax, Corporate Tax, and Complex Transactions practices units within the Washington National Tax practice at KPMG LLP.  He was a partner for over 25 years with Shearman & Sterling LLP, where his practice focused on international tax matters and financial institutions. Mr. Blessing received his B.A. from Princeton University.  He received his J.D. from Columbia Law School and his LL.M (Taxation) from New York University School of Law.

Mr. Blessing has served as the President of the USA Branch of the International Fiscal Association (2016-18) and member of IFA’s Permanent Scientific Committee (2010-16), Chair of the New York State Bar Association Tax Section (2010), Chair of the International Bar Association Taxes Committee (2010-11), Vice Chair Government Relations of the ABA Tax Section (2014-16), and President of the International Tax Institute, and has taught as an adjunct law professor at Columbia Law School (2008-11) as well as classes at NYU School of Law.  He has authored numerous articles and texts on taxation, including a treatise on US income tax treaties.  Mr. Blessing graduated from Princeton University, Columbia Law School and New York University School of Law (LLM Taxation). 


Ms. Williams was appointed Chief of Branch 4 in the Office of Associate Chief Counsel (International) at the IRS in 2019. Branch 4 has primary jurisdiction over cross-border M&A provisions such as section 245A, 367, 1248 and 7874. Prior to joining the Office of Associate Chief Counsel, Ms. Williams was in the International Tax and Transaction Tax Services practice at EY in Washington DC where she assisted clients with international restructurings, including post-M&A integration, tax attribute planning, and international tax accounting matters. Ms. Williams is a certified public accountant (CPA) licensed in the District of Columbia and an attorney admitted to the State Bar of Georgia.


Oren S. Penn is an International Tax Services Principal in the PwC Washington National Tax Services office.  Mr. Penn is responsible for providing U.S. tax policy advice for many of the firm's multinational clients and is a leading practitioner in the area of advising non-U.S. based companies with significant U.S. operations.

Prior to joining PwC, Mr. Penn served as Legislation Counsel on the staff of the U.S. Congressional Joint Committee on Taxation, advising the U.S. Congress on policy and legislative matters relating to the taxation of cross-border transactions.  In this position, he was involved in developing, drafting, and analyzing a wide range of international tax legislation.  He also advised the Senate on U.S. tax treaty matters. 

Prior to working with the Joint Committee on Taxation, Mr. Penn served as an attorney with Baker & McKenzie in Chicago, Illinois, where he was primarily involved in planning and controversies relating to the taxation of cross-border transactions.  

Mr. Penn regularly speaks on international tax topics. He graduated cum laude from the Northwestern University School of Law in 1993 and from the University of Cincinnati with a degree in Accounting in 1990. 


Peter Glicklich is the Managing Partner of the firm's New York office and a partner in its Taxation practice.  For over 25 years, he has counseled North American and foreign-based multinationals and other institutions on their international and corporate tax concerns.

Peter concentrates his practice in the taxation of inbound corporate and international transactions.  He advises public and closely held corporations, private equity and hedge funds, and REITs in connection with their mergers and acquisitions, cross-border financings, restructurings, reorganizations, spinoffs and intercompany pricing.  Peter has advised entities in diverse fields, including real estate, infrastructure, finance, retail, manufacturing, mining, biotechnology, service software, transportation, telecommuni¬≠cations, beverages and pharmaceuticals.  He has worked with institutional investors, private equity, hedge and venture capital funds, foreign governments, pension plans, Fortune 500 companies, investment banks, commodities and securities dealers, insurance companies, and others.  Peter also arbitrates tax-related contract disputes arising in connection with M&A and other transactions and handles tax controversies.

A cum laude graduate of Harvard Law School, and an honors degree graduate of the University of Wisconsin — Madison, Peter is on the Executive Committees of the International Fiscal Association and of its U.S.A. Branch, the Advisory Board of BNA, and he speaks and writes frequently on international tax topics, including at the Practicing Law Institute.


Rocco Femia represents large, multinational corporate clients in high-stakes U.S. international tax and transfer pricing planning, controversy, and policy matters. Mr. Femia is a former official at the U.S. Department of the Treasury and delegate to the OECD and brings this perspective to bear in advising clients. Mr. Femia was named one of the country's leading practitioners in the field of taxation by Chambers USA: America's Leading Lawyers for Business 2010 to 2020, and one of the Best Lawyers in America® from 2009 to 2020. Clients quoted by Chambers have said that Mr. Femia is noted for his "great reputation as an international planner."

Mr. Femia's practice focuses on counseling and advocacy work on behalf of U.S. and foreign-based multinational enterprises. These projects typically involve complex, highly technical U.S. international tax, tax treaty, and transfer pricing issues often involving hundreds of millions or billions of dollars. Mr. Femia has counseled clients with respect to the implementation of the new U.S. international tax rules enacted in the 2017 Tax Cuts and Jobs Act (TCJA), including the section 965 transition tax and the new GILTI and BEAT regimes. This work has included advice related to restructuring or other planning to avoid inappropriate results, and engagement with policymakers. Mr. Femia's transfer pricing work includes advisory work related to new business arrangements and transfers of intangible property, the negotiation of Advance Pricing Agreements with the IRS and other tax authorities, the resolution of disputes through the Competent Authority or MAP process and the resolution of disputes with the IRS through the administrative Appeals process and litigation.


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.


Tom is a Principal in the International Corporate Services practice of KPMG Chicago’s Washington National Tax. He specializes in structuring the operations of multinational corporations.

Tom focuses on structuring the operations of multinational corporations, primarily in the industrial and consumer market sectors. Tom has led a large number of international supply chain redesign projects for U.S.-based multinationals involving the establishment of regional entrepreneur companies. He also has significant experience advising non-U.S. multinationals on issues related to the establishment and operation of their U.S. businesses, including the application of treaty provisions, the U.S. effectively connected income rules, and the U.S. interest-stripping rules. Tom has considerable experience in tax controversy matters, particularly those involving transfer pricing. He has represented taxpayers before IRS Appeals throughout the US, in the US Tax Court, and in competent authority proceedings. Tom served as the United States reporter on business restructurings to the 2011 International Fiscal Association World Congress. He has spoken at many of the world’s leading tax forums, including the George Washington/IRS Tax Conference, the University of Chicago Tax Conference, several national and international meetings of the International Fiscal Association, the American Bar Association’s annual meeting, and the Tax Executive Institute’s annual meeting.

Tom is recognized in the Tax Law Review’s Guide to the World’s Leading Tax Advisors, Guide to the World’s Leading Transfer Pricing Advisors, and Tax Controversy Leaders Guide.

 

 


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.