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International Tax Issues 2013 (Chicago)

 
Author(s): Lowell D. Yoder
Practice Area: International Law, Tax
Published: Sep 2013
ISBN: 9781402420559
PLI Item #: 48547
CHB Spine #: D388

Adam Halpern is the Chair of the tax group at Fenwick & West LLP.  His practice focuses on the U.S. federal income taxation of international transactions.  He advises clients on cross-border company formations, operations and restructurings, as well as general tax planning.  He has successfully represented clients in numerous tax controversies, from audit defense to Appeals to litigation.

Adam also has substantial experience representing buyers and sellers in domestic and cross-border M&A transactions, as well as post-acquisition tax integration.

Adam is a frequent speaker at conferences on U.S. international tax, regularly speaking at TEI and PLI, among others.  He is a lecturer in law at Stanford Law School, teaching classes in international tax.

 


Damon M. Lyon focuses his practice on cross-border mergers and acquisitions, global planning and international controversies for multinational companies. He advises clients on a broad range of tax issues, including tax-efficient structuring of acquisitions, dispositions, financings, internal reorganizations and joint ventures. Damon also provides advice concerning multi-jurisdictional business structures, such as intangible holding companies and finance company structures. 


David Waimon is a member of Ernst & Young LLP's International Tax Services practice and is based in Chicago. David's practice focuses on transactional and international tax planning.

Dave serves as the firm's Associate Director of ITS Transaction Services, and is responsible for coordinating the cross-border transaction practice.

An attorney and CPA, Dave joined Ernst & Young as a partner in 2001. He has been identified as one of the leading U.S. tax practitioners by the International Tax Review.  Prior to joining the firm, Dave was a partner at the law firm of Baker & McKenzie where he specialized in international taxation.

Dave is an adjunct professor at Northwestern University School of Law where he teaches Taxation of International Transactions. He serves on the Planning Committee for the University of Chicago Federal Tax Conference and on the Advisory Board for the Journal of Taxation of Global Transactions. He is a member of the American Bar Association Section on Taxation, the Illinois State Bar Association, and The Chicago Bar Association.

He is a frequent speaker for the World Trade Institute, the Tax Executives Institute, ATLAS, Council for International Tax Education, and Practicing Law Institute, and the author of numerous articles regarding international taxation (see attached Exhibit).

Dave is a graduate of Illinois State University (B.S, high honors, 1980) and the University of Illinois School of Law (J.D., magna cum laude, 1984). He earned his CPA certificate in 1980. He was admitted to the District of Columbia Bar in 1984 and the Illinois Bar in 1985.


Eric Solomon recently retired as the Co-Director of Ernst & Young LLP’s National Tax Department in Washington, DC.  Eric has advised clients on a wide range of transactional and tax policy issues.  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 confirmation as Assistant Secretary.

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 is Chair of the American Bar Association Section of Taxation.  Eric is also 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 of law 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.


JIM FULLER is a partner in the Tax Group at Fenwick & West LLP in Mountain View, California.  He is one of the world’s top 25 tax advisers, according to Euromoney. 

Fuller is one of the three “most highly regarded” U.S. tax practitioners according to Law and Business Research’s Who’s Who Legal (2016), and is the only U.S. tax adviser to receive a coveted Chambers star performer rating (higher than first tier) in Chambers USA (2017).

He also is the only U.S. tax advisor in Tier 1 for both Corporate Tax and International Tax according to Chambers Global (2017). The Corporate Tax Tier 1 category has ten US persons; International Tax Tier 1 has six.

Ten Fenwick tax partners have appeared in Euromoney’s World’s Leading Tax Advisors, seven appear in ITR’s World’s Tax Controversy Leaders and five have appeared in Euromoney’s World’s Leading Transfer Pricing Advisors.

Fenwick & West LLP has represented 6 of the Fortune Top 10 companies, over 50 of the Fortune 100 companies, and over 100 of the Fortune 500 companies in federal tax matters.  Fenwick is first tier in Tax Planning, Tax Transactional, and Transfer Pricng, according to International Tax Review.

Fuller and his firm have served as counsel in over 150 large-corporate IRS Appeals proceedings and over 70 federal tax court cases.

Fenwick & West was named San Francisco Tax Firm of the Year seven times by International Tax Review.  Fenwick also was named ITR’s U.S. Tax Litigation Firm of the Year three times, and has reeived multiple ITR M&A tax awards including Americas M&A Tax Firm of the Year and Americas Deal of the Year awards.  These awards were given at ITR’s annual and well-attended Americas Awards Dinners in New York City.


Domestic and international acquisitions and reorganizations, foreign currency issues, subpart F and foreign tax credit provisions. Mr. McDonald has also been involved in a number of federal tax controversies, including AMP, Inc. v. United States, Laidlaw v. Commissioner, and Square D v. Commissioner. Mr. McDonald has also been involved in a number of Illinois state tax controversies.

Publications, presentations and articles

Mr. McDonald has written/co-authored a number of publications, including but not limited to:

  • International Aspects of Section 304 Transactions, Tax Strategies for Corporate Acquisitions, Dispositions, Spin-Offs, Joint Ventures, Financings, Reorganizations and Restructurings published by Public Law Institute (2004);
  • James M. O’Brien, et. al., U.S. Corporations Doing Business Abroad (ed. 1998, 2002, 2004, 2006, 2008, 2010 & 2013);
  • Mr. McDonald co-authors a bi-monthly column entitled, “International Tax Watch” for TAXES magazine.

Awards and rankings

Mr. McDonald has been named one of the top tax advisors by Chambers USA (2011, 2012, 2013 and 2014), and as one of the top ten international tax advisers in the Midwest region by Euromoney’s International Tax Review (2003). He was also mentioned in World Tax 2007 as an attorney in Chicago known for cross border M&A transactions.

Government service

Mr. McDonald served from September 1, 2005 to September 31, 2006, as the legal advisor to Dr. Anwar ul-haq Ahady, Minister of Finance for the Islamic Republic of Afghanistan. During this time, Mr. McDonald: assisted in the development of the income tax regulations and insurance regulations for Afghanistan; assisted with negotiations at the “Paris Club” and the drafting and execution of bilateral agreements between the United States, Germany and Russia confirming debt relief for Afghanistan; and participated in a number of other projects on behalf of the Islamic Republic of Afghanistan.

Education and admission

Education:

  • Northwestern University School of Law (J.D., magna cum laude)
  • Certified Public Accountant
  • Marquette University, (B.A., Accounting, summa cum laude)

Admissions:

  • Illinois
  • Northern District of Illinois
  • Federal Circuit Court of Appeals
  • U.S. Tax Court


Lowell D. Yoder is a partner in the law firm of McDermott Will & Emery’s Chicago office and is the global head of the Firm's Tax Practice.  He focuses his practice on cross-border mergers and acquisitions, global tax planning and international tax controversies, representing high-tech, pharmaceutical, ecommerce, financial, consumer and industrial companies.  He advises on tax efficient structuring of cross-border acquisitions, dispositions, financings, internal reorganizations and joint ventures, as well as tax beneficial planning for intangible holding companies, global supply chains, and multi-jurisdictional services arrangements.  Lowell also represents clients before the Internal Revenue Service handling audits and obtaining tax rulings.  He works with an extensive network of lawyers worldwide developing tax favorable transactional and operational cross-border structures. 

Lowell has spoken on a variety of international topics before numerous professional organizations.  He is the editor-in-chief of CCH’s International Tax Journal, and has authored and published numerous articles and treatises on international topics. Lowell was an adjunct professor at the Northwestern University School of Law, where he taught advanced international taxation.

Lowell is an active member of International Committees and Advisory Boards. He chairs Practising Law Institute’s International Tax Issues.  He is a fellow of the American College of Tax Counsel and is USA Branch Counsel of the International Fiscal Association.  He is a member of the Planning Committees for the University of Chicago Law School’s Annual Federal Tax Conference and the GWU/IRS Annual Institute on International Taxation, and on the Advisory Board of the Tax Management International Journal.


Manal Corwin is KPMG LLP’s National Service Line Leader for International Tax as well as Principal in Charge of Washington National Tax—International Tax Policy. She rejoined the firm in April of 2013 following completion of her tenure as Deputy Assistant Secretary of Tax Policy for International Affairs in the Treasury Department.

Manal advises multinational corporations on U.S. international tax aspects of their structures, operations and transactions. She specializes in consulting and advising on issues relating to international tax policy, expense allocation, source of income rules, foreign tax credits, subpart F, U.S. taxation of international transportation income, and certain special tax benefit provisions. In addition, Manal leads KPMG’s Global BEPS Network and advises clients on developments and implications of BEPS measures.

During her tenure at the U.S. Treasury Department, Manal helped shape the Administration’s views and policies in all areas of international taxation and worked closely with the IRS, members of Congress, and key tax regulators globally. In this regard, Manal worked on the international tax provisions of several of the Administration’s budget proposals as well as the development of the Administration’s framework for tax reform. Manal also served as the U.S. delegate and Vice Chair to the OECD’s committee on fiscal affairs and was actively engaged in the origination and development of the OECD BEPS initiative. She served as the U.S. delegate to the Global Forum on Tax and Transparency as well. Significantly, Manal was also responsible for leading the development and implementation of the intergovernmental approach to the Foreign Account Tax Compliance Act (FATCA), which has been endorsed as the foundation for a global standard for automatic exchange of information. In addition, Manal was head of the delegations responsible for negotiating income tax treaties with Japan, Spain, Chile, and the United Kingdom.

Prior to joining the Treasury Department (first as International Tax Counsel in the Office of Tax Policy and then as Deputy Assistant Secretary for International Tax Affairs), Manal was a principal in KPMG’s Washington National Tax practice 2001 to 2009, where she advised multinational corporations on U.S. international tax aspects of their operations and transactions and represented clients in tax controversies before the IRS.

Earlier in her career, Manal served as the Deputy and then Acting International Tax Counsel in the Office of Tax Policy at the U.S. Treasury Department. Prior to that, Manal practiced as an attorney specializing in international taxation at the law firm of Covington & Burling in Washington, D.C. Manal also served as a judicial clerk for then Chief Judge Levin Campbell on the U.S. Court of Appeals for the First Circuit.

Manal is a frequent speaker and commentator on international tax rules and policies. She is a member of the Massachusetts and the District of Columbia bar associations. She is a graduate of the Boston University School of Law, where she was editor-in-chief of the Law Review and recognized as a distinguished scholar. She earned her undergraduate degree from Harvard University.


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.

 


Nicholas J. DeNovio, Global Chair of Latham & Watkins’ International Tax Practice, is a partner in the Washington, D.C. office and member of the Audit Committee and Strategic Client Committee.
 
Mr. DeNovio advises large domestic and international corporations on cross-border transactions involving mergers and acquisitions, spin-offs, financings, and group structuring. He has represented a number of the world's leading corporations on multi-billion dollar transactions covering jurisdictions around Europe, Asia, and the Americas.

Mr. DeNovio began his career in private practice in New York City and became a partner at a global law firm. He is a member of the board for the George Washington University (GWU)/Internal Revenue Service (IRS) International Tax Program and served as Chair of the University of Chicago’s Federal Tax Conference from 2012 – 2014.  Mr. DeNovio is consistently ranked by The Legal 500 US, Chambers USA and Super Lawyers as one of the leading tax lawyers in the District of Columbia. In addition, The Legal 500 US and Chambers Global regularly recognize him for his international tax work.

Mr. DeNovio is a renowned speaker and writer for organizations such as Tax Executives Institute (TEI), Practicing Law Institute (PLI), International Fiscal Association (IFA), National Foreign Trade Council (NFTC) and various bar associations.

 


Mr. Oosterhuis is a senior international tax practitioner with Skadden, Arps, Slate, Meagher & Flom, where he is Of Counsel.  Mr. Oosterhuis has had over 30 years of experience in international acquisition and disposition transactions and tax planning for U.S. and foreign-based multinational corporations.  He also represents clients on controversy matters with the Internal Revenue Service, including intercompany pricing matters.

He received his B.A. from Brown University and his J.D. Degree from Harvard Law School.  After law school he became a Legislation Attorney for the Joint Committee on Taxation, U.S. Congress, and later served as the Committee's Legislation Counsel.  He has served as an Adjunct Professor at Georgetown University Law Center, where he taught International Taxation in the Master of Taxation graduate law program.

He has lectured at various professional seminars and institutes, has written on a variety of tax planning and tax policy matters, and has testified before Congressional tax writing committees on tax policy issues. 

 


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

Prior to joining Treasury, Mr. Stack served as head of the international tax practice group at the law firm of Ivins, Phillips & Barker. In the private sector, he has over 26 years of experience in international tax matters, representing both corporations and individuals. His work for corporations has included structuring both inbound and outbound ventures, the establishment of efficient cross border structures, the formation of joint ventures and private equity funds and all aspects of international mergers and acquisitions.

He is a member of the American Bar Association Tax Section, New York State Bar Association Tax Section, and International Fiscal Association. Mr. Stack has participated in numerous panels on international tax issues at the meetings of the American Bar Association Tax Section as well as the Federal Bar Association. He graduated from Georgetown University Law Center in 1984, where he was editor-in-chief of the Georgetown Law Journal. After graduating, he clerked for Judge Thomas A. Flannery of the United States District Court for the District of Columbia and Justice Potter Stewart (Ret.) of the United States Supreme Court.


Rocco V. Femia is a member of Miller & Chevalier Chartered.  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 U.S. international tax consequences of their cross-border business operations, including issues involving supply chain planning, funding arrangements and cash management (including repatriation). Mr. Femia’s transfer pricing work has included 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.

Mr. Femia is a former Associate International Tax Counsel at the U.S. Department of the Treasury, Office of Tax Policy.  While at the Treasury, Mr. Femia had responsibility for a broad spectrum of U.S. tax treaty and international tax regulatory and legislative matters.  

Mr. Femia writes and speaks regularly on a variety of international tax and transfer pricing issues, and is a former Adjunct Professor at the Georgetown University Law Center.  Mr. Femia graduated, magna cum laude, from Georgetown University Law Center in 1995.  He received his B.A. in Economics from Duke University in 1991.

 


Steven is a leader of the International Mergers and Acquisitions practice, International Tax Services group at Ernst & Young LLP, the US EY member firm. He practices in the area of cross-border mergers, acquisitions and restructurings on US and non-US entities.

Steven is also an adjunct Professor of Law at Northwestern University School of Law, where he teaches an advanced class on cross-border mergers and acquisitions.  Steven consistently has been named one of the world’s leading cross border M&A tax advisors by International Tax Review as well as one of the world’s leading international tax advisors by Euromoney.

He is a member of the Planning Committee of the University of Chicago Law School’s Federal Tax Conference and is a frequent speaker before a variety of tax organizations including the American Bar Association, The Tax Executives Institute, and the Practicing Law Institute.

Steven has authored (or co-authored) tax articles for the Journal of International Taxation, Taxes, the Practicing Law Institute Handbook on Mergers and Acquisitions, the Journal of Taxation of Financial Products, and Tax Notes.

Steven has been a primary tax advisor to numerous US and non-US multinationals in some of the largest cross border transactions executed. 


Tim Tuerff is an international tax partner in the Washington National Office, serving U.S.-based multinational clients involved in cross-border transactions.  His practice involves consulting related to structuring of international business operations, mergers and acquisitions, financing international operations, repatriation and utilization of foreign tax credits.

Mr. Tuerff brings over twenty years of experience providing international tax consulting services to multinational corporations as well as a senior level government service to his client engagements.  This experience includes practicing in the national office of international accounting firms, the practice of law in Washington D.C. and government service as Special Assistant to the Chief Counsel of the Internal Revenue Service.  Mr. Tuerff has served as the Managing Partner for the Deloitte Washington National Tax Office and as a member of the Board of Directors of Deloitte LLP.  Mr. Tuerff’s variety of experience allows him to provide practical tax planning advice taking into account transactions that are currently executed in the marketplace as well as the position of global taxing authorities.  He has also testified before the U.S. Congress Ways and Means Subcommittee on Select Revenue Measures concerning the International Tax Reform Discussion Draft addressing a territorial system of taxation.

Mr. Tuerff is a frequent contributor to tax periodicals, including Tax Notes and Tax Notes International and the Practicing Law Institute journal, Tax Planning for Domestic & Foreign Partnerships, LLCs, Joint Ventures & Other Strategic Alliances, the American Bar Association, International Franchising Journal, and BNA Tax Management Portfolio No. 6380, Outbound Tax Planning for U.S. Multinational Corporations. These periodicals stress the importance of comprehensive tax planning for global transactions.

Professional Memberships

Mr. Tuerff is a member of the American Bar Association and the District of Columbia Bar Association.  Mr. Tuerff is also a District of Columbia certified public accountant.

 


"extremely confident and persuasive in the courtroom and a pleasure to work with" Chambers USA 2008

Since joining Mayer Brown in 1990, Tom Kittle-Kamp has represented clients in all phases of tax controversy and litigation. His litigation experience includes the trial and appeal of major corporate cases involving Section 482 allocations, substance-over-form theories, intangible assets, debt-equity characterization, valuation disputes, capitalization questions, Subpart F and other international tax issues, Subchapter C issues, and leasing transactions. Tom also maintains an extensive practice of advising and representing clients with respect to administrative matters, including IRS audits, IRS Appeals (including Fast Track and appeals mediation procedures) and competent authority negotiations. He also represents corporate clients with respect to tax-sharing disputes.

Tom has deep experience in all aspects of international transfer pricing, particularly matters involving intangible assets and intellectual property. He provides tax planning advice with respect to cross-border transactions involving intangible assets, goods and services; transfer-pricing documentation; and the development, exploitation and disposition of intangible assets, including licenses, sales and cost-sharing arrangements. He is co-author of the treatise Federal Income Taxation of Intellectual Properties and Intangible Assets (Warren, Gorham & Lamont 1997), which is updated twice a year. Before law school, he worked for several years as a newspaper reporter.

According to Chambers USA, Tom is "extremely confident and persuasive in the courtroom and a pleasure to work with." According to Legal 500, Tom is "a very rare combination - a subtle courtroom advocate and a real tax expert." Tom has been recognized by Chambers USA from 2008 through 2012, by Legal 500 from 2008 through 2012, by the International Tax Review Tax Controversy Leaders guide for 2011 and 2012, and by the Euromoney 2010 "Guide to theWorld's Leading Tax Advisors."

News & Publications

  • "Massachusetts District Court Explores the United States’ Burden of Proof Argument on Deductions of Government Settlements," Mayer Brown Legal Update, 21 May 2013
  • "US Ninth Circuit Reverses Course in Xilinx, Rejects IRS Effort to Require Cost Sharing of Employee Stock Options," Mayer Brown Legal Update, 24 March 2010
  • "Ninth Circuit Reverses Tax Court in Xilinx, Rules IRS Administrative Position Contrary to Arm’s Length Standard," Mayer Brown Legal Update, 29 May 2009
  • "Federal Income Taxation of Intellectual Properties & Intangible Assets," (Warren, Gorham & Lamont 1997)


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.

 

 


Will is an investment banker and Managing Director at Citigroup Global Markets Inc., where he focuses on tax-advantaged domestic and cross-border M&A transactions and capital structure solutions for public and private companies. 

Will has served as an adjunct assistant professor at Brooklyn Law School and taught classes on the taxation of securities and derivatives and the taxation of partnerships.  He has also taught as an adjunct at the Peter J. Tobin School of Business at St. John’s University and given guest lectures for classes at Harvard Law School and NYU’s Leonard N. Stern School of Business.

Will currently serves on the Board of Directors of the International Tax Institute, is a member of the New York Steering Committee of the International Fiscal Association, and was formerly Chair of the U.S. Activities of Foreigners and Tax Treaties Committee of the ABA’s Section of Taxation.  He is a former John S. Nolan Fellow and also served on the ABA’s Task Force on International Tax Reform.  Will speaks frequently about Federal income tax matters. 

Prior to joining Citigroup, Will was a Senior Attorney at Cravath, Swaine & Moore LLP, a law firm in New York City; he earned his J.D. (magna cum laude) from Boston University School of Law. 


Lowell D. Yoder is a partner in the law firm of McDermott Will & Emery’s Chicago office and is the global head of the Firm's Tax Practice.  He focuses his practice on cross-border mergers and acquisitions, global tax planning and international tax controversies, representing high-tech, pharmaceutical, ecommerce, financial, consumer and industrial companies.  He advises on tax efficient structuring of cross-border acquisitions, dispositions, financings, internal reorganizations and joint ventures, as well as tax beneficial planning for intangible holding companies, global supply chains, and multi-jurisdictional services arrangements.  Lowell also represents clients before the Internal Revenue Service handling audits and obtaining tax rulings.  He works with an extensive network of lawyers worldwide developing tax favorable transactional and operational cross-border structures. 

Lowell has spoken on a variety of international topics before numerous professional organizations.  He is the editor-in-chief of CCH’s International Tax Journal, and has authored and published numerous articles and treatises on international topics. Lowell was an adjunct professor at the Northwestern University School of Law, where he taught advanced international taxation.

Lowell is an active member of International Committees and Advisory Boards. He chairs Practising Law Institute’s International Tax Issues.  He is a fellow of the American College of Tax Counsel and is USA Branch Counsel of the International Fiscal Association.  He is a member of the Planning Committees for the University of Chicago Law School’s Annual Federal Tax Conference and the GWU/IRS Annual Institute on International Taxation, and on the Advisory Board of the Tax Management International Journal.