David F Abbott |
|
|---|---|
|
Mayer Brown 1221 Avenue of the Americas New York, NY 10020-1001 US Tel: +1 212 506 2642 Fax: +1 212 849 5642 Email: dabbott@mayerbrown.com Website: www.mayerbrown.com David Abbott is a highly respected tax litigator and transactional lawyer. He advises clients across a broad range of critical issues, with a particular focus on key areas of corporate concerns involving tax litigation. David's dispute resolution practice emphasises tax litigation and controversy, as well as bankruptcy disputes. He has experience with tax audits and appeals, and represents clients before the US Tax Court and the US Court of Federal Claims. David's current and past cases involve corporate acquisition-related issues, payment of acquisition-related fees and financing-related issues such as debt versus equity characterisations, debt/equity swaps, transfer pricing and tax treatment of leasing transactions, including LILOs and SILOs. In addition, David has represented equity investors in Chapter 11 bankruptcy cases involving several leading airlines with respect to aircraft lease tax indemnity agreement claims. Straddling his tax litigation and transactional work, David has extensive experience with valuations of business enterprises plus tangible and intangible assets. He works regularly with valuation experts to document and justify appraisal conclusions and present or defend them in tax audits and litigation. On the transactional side, David represents equity investors, lenders and lessees in equipment and real estate leasing transactions such as sale-leasebacks, leveraged and single-investor leasing, cross-border lease arrangements, acquisition and divestiture of leasing portfolios and leasing subsidiaries and related tax-oriented financing structures and debt instruments. His transactional tax counsel also encompasses acquisitions and divestitures, financial products, consolidated return regulations, general corporate taxation and partnership taxation. 
|
Howard Berman |
|
|---|---|
|
Deloitte Tax LLP 30 Rockefeller Plaza New York, NY 10112-0015 US Tel: +1 212 436 2242 Email: hberman@deloitte.com Website: www.deloitte.com Howard Berman, Deloitte US, is a member of the tax controversy services team. Howard specialises in representing clients before the Internal Revenue Service (IRS) and in coordinating complex IRS examinations and appeals for multinational enterprises. Howard has significant experience handling inbound and outbound transfer pricing matters, was one of the first practitioners to use alternative dispute resolution (ADR) techniques (that is, third party mediation) with the IRS and regularly uses fast-track settlement and other ADR techniques to negotiate the resolution of complex tax disputes for his clients. In addition to transfer pricing issues, Howard has helped clients resolve issues surrounding the treatment of debt financing structures, the allocation of interest and other deductions to US source activities, the determination and computation of taxpayers' subpart F income and the correct information reporting of transactions between US and related foreign entities. For more than 20 years, Howard has represented clients in a variety of industries, including financial services, heavy manufacturing, pharmaceuticals, media and retail. Howard served as a senior trial attorney for the US Department of the Treasury, and represented the IRS before the US Tax Court. While representing the IRS, Howard served as industry counsel for the financial services and LBO/merger and acquisition industries. In his tenure at the US Department of the Treasury, Howard helped to develop the coordinated examination programme, and, in that capacity, advised many IRS agents and appellate officers with respect to the development of cases and the resolution of technical issues. Howard also has significant experience in IRS practice and procedure, penalty and quality control issues and has spoken and written extensively with respect to numerous IRS practice and procedure issues. Howard has a JD from the State University of New York at Buffalo – Faculty of Law and Jurisprudence, and a BA from Brandeis University. 
|
Kevin Brown |
|
|---|---|
|
PwC 600 13th Street, NW Suite 1000 Washington, DC 20005-3333 US Tel: +1 202 346 5051 Email: kevin.brown@us.pwc.com Website: pwc.com/taxcontroversy Kevin Brown is the co-leader of PwC's Washington national tax services' US tax controversy and regulatory services team. Kevin joined PwC after several notable professional roles, including stints as acting commissioner of the Internal Revenue Service (IRS) and chief operating officer of the American Red Cross. In his nine years at the IRS, Kevin worked in a number of positions. Most significantly, he served as the acting commissioner, where he managed more than 100,000 IRS employees responsible for a budget of $12 billion and the collection of more than $2.2 trillion dollars, approximately 95% of all federal revenues. Other roles held by Kevin at the IRS included: deputy commissioner for services and enforcement, where he was responsible for the four IRS operating divisions, as well as all staff and activities related to IRS audits, collections, investigations, and service delivery, including telephone operations and returns processing; commissioner of the small business/self-employed (SB/SE) division, where he oversaw excise, estate and gift, and employment tax for more than 45 million small business and self-employed taxpayers, and managed Bank Secrecy Act examinations on behalf of the IRS; principal adviser and chief-of-staff for former IRS Commissioner Mark Everson; as well as division counsel for the SB/SE division and assistant to former IRS commissioner Charles Rossotti. Kevin's career also includes experience in the US Department of Justice, Tax Division, where he served as counsel to the assistant attorney general, and as a trial attorney who argued more than 50 cases in the US Courts of Appeals. While at PwC, Kevin has represented clients in a broad range of matters, including IRS audits, appeals and obtaining administrative guidance. In particular, he has helped a number of companies enter into pre-filing agreements – thereby affording them certainty that their return positions will not be subject to later challenge on audit. In addition, Kevin led a coalition of insurance companies in securing an industry-wide resolution allowing them greater latitude in their treatment of impaired securities. More recently, he led another insurance industry coalition that obtained a safe harbour regarding the treatment of hedging gains and losses associated with variable annuities. Kevin earned his JD (cum laude) from Boston College Law School and his BA (cum laude) from Hamilton College. He is a member of the Massachusetts and District of Columbia bar associations. 
|
Michael Bryan |
|
|---|---|
|
Deloitte Tax LLP 1700 Market St Philadelphia, PA 19103-3984 US Tel: +1 215 977 7564 Fax: +1 855 405 7742 Email: mibryan@deloitte.com Website: www.deloitte.com Michael Bryan, Deloitte US, is a managing director in Deloitte Tax's Washington national tax-multistate practice. For the five years before joining Deloitte, Mike was the director of the New Jersey Division of Taxation. Mike carries strong credentials with respect to state policy considerations and audit defence, and has deep relationships with other tax administrators. Prior to his leadership role with the state of New Jersey, Mike spent 16 years overseeing all federal, international and state controversy matters for a large publicly traded media company in Philadelphia. Mike coordinates state controversy services for multistate tax's clients nationally, particularly controversies within New Jersey, and is instrumental in working through issues with the states on behalf of Deloitte clients. Mike serves as a resource to the entire multistate tax practice with respect to technical review of filing considerations and newly-developed technical positions, restructuring and other transactions and drafting formal opinions. His licensing, education and professional memberships include:
|
Christopher Campbell |
|
|---|---|
|
Deloitte Tax LLP 555 West 5th St Suite 2700 Los Angeles, CA, 90013-1010 US Tel: +1 213 553 3072 Fax: +1 877 580 2172 Email: cwcampbell@deloitte.com Website: www.deloitte.com Christopher Campbell, Deloitte US, is a principal in Deloitte's multistate tax controversy services team in Los Angeles, and a liaison to the Washington national tax-multistate practice as a California controversy and technical lead. He specialises in representing clients before, and resolving tax disputes with, the California taxing authorities and the Internal Revenue Service (IRS). Chris is also a member of the private wealth group as his clients include high-net-worth individuals, family offices, and fiduciaries for whom he advises on federal income tax matters and California and other state tax matters involving residency, trust taxation, and the sourcing of income derived from investment partnerships, among other issues. Chris most recently led the tax controversy and litigation practice and the state and local tax practice for Loeb & Loeb, regularly representing clients in audits, appeals, and litigation with the IRS, California State Board of Equalisation, and California Franchise Tax Board. Chris worked closely with that firm's trusts and estates practice, and handled numerous audits and appeals involving federal income, estate and gift taxes. Chris also has extensive experience in bankruptcy tax matters, and was frequently retained to represent debtors and creditors as special tax counsel in bankruptcy cases. His licensing, education and professional memberships include:
|
Cabell Chinnis |
|
|---|---|
|
Mayer Brown Two Palo Alto Square, Suite 300 3000 El Camino Real Palo Alto, CA 94306-2112 US Tel: +1 650 331 2020 Fax: +1 650 331 2067 Email: cchinnis@mayerbrown.com Website: www.mayerbrown.com Cabell Chinnis specialises in audits and appeals, especially in the contentious area of transfer pricing. He has obtained speedy and favourable results by identifying key issues in the case and resolving them. He also has significant experience in advance pricing agreements and tax treaties. In audits, Cabell provides advice on working with the exam teams in special situations, preparing executives and other business personnel for interviews by the IRS or their experts, coordinating presentations to the exam team and resolving discovery disagreements with the exam team or Department of Justice. Cabell has successfully advised clients on how best to escalate within the IRS to senior agency personnel to facilitate resolution of audit issues. In appeals, Cabell specialises in handling complex matters and expediting resolution of issues if they are more limited in scope. His cases since January 1 2013 have involved section 482 issues in a variety of areas (services, tangible goods, transfers of intangibles), valuation disputes, research and development credit, and section 199. Cabell also handles tax-related alternate dispute resolution, including fast-track and 'limited issue' audits. In addition, he counsels tax exempt entities on a full range of matters, including their organisation, operation and sponsorship. Cabell began his nearly 30-year career by serving as a judicial clerk at the US Supreme Court for the Hon. Louis Powell, Jr.
|
Kerwin Chung |
|
|---|---|
|
Deloitte Tax LLP 555 12th St. NW, Suite 400 Washington, DC 20004 US Tel: +1 202 879 3108 Fax: +1 202 661 1126 Email: kechung@deloitte.com Website: www.deloitte.com Kerwin Chung, Deloitte US, is a principal in the Deloitte Tax Washington national tax office transfer pricing team, and leader of Deloitte's national advance pricing agreement (APA) and mutual agreement procedure (MAP) group. Kerwin has more than 20 years' transfer pricing experience, specialising in APAs, MAPs, planning, examinations, and customs matters. His clients include US and foreign-based multinationals in numerous industries, including apparel, automotive, biotech, chemicals, computers, electronics, energy, food and beverage, industrial machinery, internet, logistics, office products, pharmaceuticals, professional services, publishing, semiconductors, software and telecommunications. Kerwin's practice has involved complex transfer pricing issues, including a bilateral APA and rollback for a pharmaceutical company that resulted in the withdrawal of an Internal Revenue Service (IRS) transfer pricing adjustment and penalty assessment, amounting to more than $100 million. Kerwin has also been involved in a bilateral APA, covering cost sharing platform contribution transactions and cost sharing transactions for a software company, and bilateral APAs and competent authority representations with respect to inbound and outbound intercompany license transactions in several industries. Kerwin has co-authored numerous publications, including Seeking efficiencies in the new IRS APA and MAP programmes, published by International Tax Review (November 2011); Competently Negotiating the US Competent Authority Process, published by the 59 Tax Executive No. 3, (May/June 2007); and the Transfer Pricing Rules and Compliance Handbook, published by CCH (2006). Kerwin has been included in Euromoney's Transfer Pricing Expert Guide since 2002 and in International Tax Review's Tax Controversy Leaders guide since 2015. He is an active member of the ABA tax section transfer pricing committee, having moderated a panel on transfer pricing in a down economy issues in 2009 and presented on a panel discussing the IRS APA programme in 2011. He has a JD (cum laude) from Harvard Law School and a BBA in accounting and real estate from the University of Hawaii. Kerwin has been admitted to the New York Bar and the District of Columbia Bar.
|
Kenneth B Clark |
|
|---|---|
|
Fenwick & West LLP Silicon Valley Center 801 California Street Mountain View, CA 94041 US Tel: +1 650 335 7215 Email: kclark@fenwick.com Website: www.fenwick.com Kenneth B Clark is a partner in the tax group of Fenwick & West and chairs its tax litigation practice. Fenwick has received numerous accolades for its tax controversy practice, including recognition by International Tax Review as US tax litigation firm of the year in several different years. The principal focus of Kenneth's practice is complex federal tax litigation and tax controversy work. He regularly practices in the US Tax Court and has published a number of articles relating to tax controversies. Fenwick & West has worked on more than 70 federal tax litigations. Kenneth has worked on numerous high profile tax controversy matters for clients such as Xilinx, Inc.; The Limited, Inc.; Limited Brands, Inc.; Textron Inc.; Daimler AG; G.M. Trading; Dover Corporation; Adaptec, Inc.; Analog Devices; Sanofi SA; Cameco; and CBS. With four decades of experience, Ken also has managed a variety of complex commercial disputes in a number of foreign countries and more than 20 states. Litigation prevention and alternative dispute resolution (ADR) also have been important parts of his practice. He has served as Fenwick & West's ADR coordinator, as an American Arbitration Association arbitrator, and has been involved in numerous mediations and arbitrations. Kenneth received a BA from the University of Redlands, where he graduated summa cum laude, and was first in his class. He received a JD from New York University School of Law, cum laude, and was a member of that school's Law Review. Kenneth also received an MBA from the University of California at Berkeley. He has extensive experience in teaching speaking techniques. Kenneth is a member of the State Bars of California and New York and is admitted to practice in the US Tax Court and numerous federal courts. 
|
Ward Connolly |
|
|---|---|
|
PwC 488 Almaden Boulevard San Jose, CA 95110 US Tel: +1 408 817 8234 Email: ward.connolly@pwc.com Website: www.pwc.com/taxcontroversy Ward Connolly is a principal in PwC's national tax services (NTS) group and is resident in the firm's Silicon Valley Technology Center of Excellence in San Jose, California. Ward is a member of PwC's advance pricing, mutual agreement and transfer pricing controversy practice. Ward has 20 years of experience as a tax professional and has represented US and foreign multinational enterprises in complex tax audits, administrative disputes (IRS appeals), alternative dispute resolution (e.g. mediation), advance pricing agreements (APAs) and litigation. Ward has been recognised as one of the world's leading tax controversy advisers by International Tax Review and one of the best lawyers in the San Francisco Bay Area by Bay Area Lawyer magazine. Ward has also been recognised in International Tax Review's World Tax guide for his skills in transfer pricing, where he has extensive experience with the issues faced by clients in the high-tech, biotech, and pharmaceutical industries. Prior to joining PwC, Ward was a partner at Fenwick & West. Ward was previously a faculty member in the department of economics at Trinity University. Ward earned his JD, with honours, from Duke University School of Law, and his PhD in economics and his BA from the University of South Carolina. Ward is a member of the California Bar Association and has written many technical articles for trade journals and other publications. Ward has been a frequent speaker for professional tax groups, including numerous chapters of the Tax Executives Institute and BNA/CITE.
|
Jon Contreras |
|
|---|---|
|
Deloitte Tax LLP 5250 N. Palm Ave., Suite 300 Fresno, CA 93704 US Tel: +1 559 449 6328 Fax: +1 559 449 6828 Email: jocontreras@deloitte.com Website: www.deloitte.com LinkedIn: linkedin.com/in/contrerasjon Jon Contreras, Deloitte US, joined the firm with significant experience in IRS campus matters to serve the tax controversy needs of their clientele worldwide. Before joining Deloitte, he worked in the examination division for the Internal Revenue Service (IRS) at the Fresno service centre for 14 years. Today, with more than 20 years of experience serving clients in all facets of tax controversy, Jon specialises in IRS practice and procedure as it relates to service centre/campus processing issues. With extensive knowledge in audits, administrative appeals, penalty abatements and alternative dispute resolution, Jon represents clients before the IRS examination division and IRS appeals. Currently serving as managing director of the tax controversy group in Fresno, California, Jon has been with Deloitte for 19 years. He manages the firm's national IRS practice and procedures group as it relates to IRS campus operations overseeing a team of seven dedicated and highly-skilled former IRS tax professionals with in-depth knowledge of IRS tax return processing, penalty abatement and filing issues unique to large corporations and pass-through entities. An active member of his community and within his firm, Jon serves as a speaker to educate professional groups about IRS controversy issues, practices and procedures. He holds membership in the California Society of Enrolled Agents, the California Society of Certified Public Accountants, the American Institute of Certified Public Accountants and the Fresno Area Hispanic Foundation. He has also been active in support of his alma mater California State University, Fresno and held membership in the Fresno State Alumni Association and Fresno State Bulldog Foundation.
|
Daniel Cook |
|
|---|---|
|
Deloitte Tax LLP Chicago, Illinois US Tel: +1 312 486 5478 Fax: +1 866 603 7464 Email: dancook@deloitte.com Website: www.deloitte.com Daniel Cook, Deloitte US, is a managing director specialising in federal tax controversy services. Dan has represented taxpayers at all stages of federal tax controversy, including IRS examinations, the IRS administrative appeals process, alternative dispute resolution proceedings, and collection due process matters. In addition, he has advised clients regarding pre-examination matters including audit readiness studies, internal company compliance initiatives, strategic planning initiatives and proactive voluntary disclosure initiatives by taxpayers to the IRS. Prior to joining Deloitte Tax, Dan also represented taxpayers in litigation proceedings before the US Tax Court, the US District Court, the US Federal Court of Claims and in post-trial appeals to the US Circuit Courts of Appeals. Dan's clients have included multinational enterprises in the finance, insurance, oil and gas, and pharmaceutical industries, as well as professional partnerships and their members, and individuals. Dan received a BA in 2000 from Carleton College; a JD, with distinction, in 2004 from the University of Iowa College of Law; and a LLM in taxation, with honours, in 2005 from the Northwestern University School of Law.
|
Anthony Curtis |
|
|---|---|
|
PwC 300 Madison Avenue New York, NY 10017 US Tel: +1 646 471 0700 Mobile: +1 917 922 3806 Fax: +1 813 329 2215 Email: anthony.curtis@pwc.com Website: pwc.com/taxcontroversy A principal since 2000, Anthony Curtis is a senior economist, transfer pricing specialist and US consumer markets transfer pricing (TP) sector leader for PwC. He is part of PwC's tax controversy practice, integrating tax controversy resolution and prevention specialists from federal and international tax, transfer pricing, state and local tax with former government and other specialists. Tony has more than 26 years of experience conducting economic analysis for PwC. For 24 years, he has specialised primarily in the economics of inter-company pricing, including planning studies to help taxpayers determine appropriate transfer prices for future transactions, economic studies for use in the defence of transfer prices under examination, and economic analyses for advance pricing agreements (APAs) and competent authority negotiations with the Internal Revenue Service (IRS) and foreign tax authorities. He currently is negotiating several APAs, transfer pricing audits, and competent authority cases with the IRS for his clients, including bilateral and multilateral cases involving China, Italy, Switzerland, and the UK. As the TP consumer markets sector leader, Tony works specifically with PwC's leading consumer products, retail and luxury goods clients to ensure that they have access to the best practices and personnel of the PwC network. Over his career, Tony has served as the NYC tax controversy practice leader, the TP leader for PwC's NY metro transfer pricing region, has led the practice's globally coordinated documentation service offering, as well as serving as the Americas editor for PwC's transfer pricing news articles. He is also a frequent author and presenter. Tony is also passionate about PwC's people and enjoys recruiting and working on PwC's diversity and inclusion initiatives. Tony previously taught graduate courses in business economics and money and banking at Johns Hopkins University. He has a MBA with a concentration in marketing and a BBA with a concentration in business economics and public policy from The George Washington University and has completed several graduate classes in taxation at Fordham University.
|
Valerie Dickerson |
|
|---|---|
|
Deloitte Tax LLP 555 12th St NW Ste 400 Washington DC, 20004-1207 US Tel: +1 202 220 2693 Fax: +1 714 424 1684 Email: vdickerson@deloitte.com Website: www.deloitte.com Valerie Dickerson, Deloitte US, leads the multistate group within Deloitte Tax's Washington national tax practice advising the firm's multistate and multinational clients on the state and local aspects of significant transactions, controversies, and filing positions for which the group has also provided significant formal tax opinions. As an integral part of that practice, Valerie specialises in California tax matters, representing and advising clients in California audits, protests, appeals, and settlements, as well as discretionary administrative resolutions. In addition, she leads Deloitte Tax's multistate tax controversy services team of controversy-focused professionals with litigation and accounting backgrounds, including a number who have significant experience as litigators and a number who are former state tax agency executives and legal staff. Valerie's controversy experience includes issues involving nexus, throwback, unitary/non-unitary relationships, non-business income/expense, market-based sourcing for services and intangibles, state tax treatment of foreign entities, dividend treatment, stock/asset dispositions, expense disallowance, transactions, constitutionality of statutes and regulations. She has advised on such matters for industries including health plans, life science, technology, media, energy, food service, insurance, manufacturing, consumer products, and retail. Further, her experience includes providing or advising on formal state tax opinions. Her licensing, education and professional memberships include:
|
Paul DiSangro |
|
|---|---|
|
Mayer Brown Two Palo Alto Square, Suite 300 3000 El Camino Real Palo Alto, CA 94306-2112 US Tel: +1 650 331 2045 Fax: +1 650 331 4545 Email: pdisangro@mayerbrown.com Website: www.mayerbrown.com Paul DiSangro specialises in resolving tax disputes with the Internal Revenue Service (IRS) and state agencies. Paul obtains favourable results in an efficient time frame by partnering with clients to develop a clear strategy for navigating the thorny issues that arise in complex tax cases. He has more than 20 years of experience representing clients in all facets of tax controversy, including audits and administrative appeals, alternative dispute resolution, and litigation. Paul has successfully handled a broad range of tax issues with the IRS including, most recently, transfer pricing, cost sharing, subpart F exceptions, the R&D credit, the section 199 domestic production activity deduction, IP migration and valuation disputes, captive insurance company benefits, executive compensation, depreciation, capitalisation, deductions, withholding, independent contractors vs. employees, offshore accounts, partnership issues, and debt vs. equity. Paul is currently litigating a section 199 issue for Bare Escentuals in the US Tax Court. Paul also has extensive state and local tax controversy experience with the California Franchise Tax Board, the California Board of Equalisation, the California Employment Development Department, and the California Unemployment Insurance Appeals Board, as well as with tax agencies in other states. His recent state cases have included state transfer pricing and valuation disputes, alternative apportionment, sales and use taxes for online sales, trust and estate issues, market-based sourcing, tax shelters, independent contractors vs. employees, and navigating voluntary disclosure programmes in more than 40 states. Paul is recognised as a leading tax controversy adviser in International Tax Review's 2016 Tax Controversy Leaders guide. Paul has authored several important works on US and international tax issues and he is widely sought as a speaker and presenter at professional tax seminars and symposia. He is the organiser of the annual Tax Controversy Seminar in Silicon Valley with the Tax Executives Institute. In addition, he has taught international tax classes as an adjunct professor at the LLM level.
|
Thomas J Driscoll |
|
|---|---|
|
Deloitte Tax LLP 111 S Wacker Drive, 18th Floor Chicago, IL 60606 US Tel: +1 312 486 9564 Email: thosdriscoll@deloitte.com Website: www.deloitte.com Thomas J Driscoll, Deloitte US, is a senior partner. In addition to holding key client roles, Tom has been a practice leader in various roles throughout his career, most recently as partner in charge of Deloitte's international tax and transfer pricing practice in the US. He specialises in the international tax, trading and treasury area, assisting clients with financing strategies, supply chain and business model structuring, intellectual property planning strategies, hedging/risk management strategies, foreign tax credit planning, repatriation techniques and global tax optimisation. Clients served include US and non-US based multinational companies in the consumer goods sector as well as financial market participants. Tom is a frequent speaker on various topics involving federal income taxation as a part of Deloitte's national training programmes as well as at numerous national forums. Tom was an adjunct professor at the University of Chicago's Graduate School of Business as well as Northwestern University's J.L. Kellogg Graduate School of Management. His education and certifications include:
|
Daniel Dumezich |
|
|---|---|
|
Deloitte Tax LLP 111 South Wacker Drive Chicago, IL 60606 US Tel: +1 312 486 5167 Email: ddumezich@deloitte.com Website: www.deloitte.com Daniel Dumezich, Deloitte US, is the managing director of federal tax controversy services. Before joining Deloitte Tax, Daniel was in the private practice of law for 26 years, including a four-year term as the chair of the federal tax controversy practice at a major international law firm. During his practice of law, Daniel has tried cases in the US Tax Court involving §482 reallocations and subpart F issues. He has also tried matters involving the deductibility of interest expense relating to a debt versus equity characterisation, a debt-equity swap, and capitalisation versus current deductibility of expenditures. Acquisition-related issues he has tried include valuation of assets and tax advantaged structuring. Outside of litigation, Daniel has settled cases favourably for his clients, including his representation of 980 former partners of a large professional firm in a case in which the IRS sought more than $450 million in taxes – the matter settled for approximately 5% of that amount. He has achieved similar results for major financial institutions including banks, hedge funds, insurance companies and individuals involved with tax advantaged transactions deemed abusive by the IRS. Also he has represented clients on income and withholding tax matters. Daniel served as a judge in Indiana and in Indiana's General Assembly as a state representative. He is also a frequent speaker on various tax controversy topics for a variety of organisations. Daniel received a Bachelor of Business Administration with a major in accounting in 1982 from Western Michigan University and a Master of Science in taxation in 1985 from DePaul University. He received his JD with the highest distinction in 1989 from the John Marshall Law School.
|
David L Forst |
|
|---|---|
|
Fenwick & West LLP Silicon Valley Center 801 California Street Mountain View, CA 94041 US Tel: +1 650 335 7254 Email: dforst@fenwick.com Website: www.fenwick.com David Forst focuses on international corporate taxation. David is included in Legal Media Group's Tax Advisers Expert Guide. He is also in the Legal 500 Hall of Fame and Law and Business Research's International Who's Who of Corporate and Tax Lawyers (for the past seven years). David is listed in Chambers USA America's Leading Lawyers for Business (2011-2016), 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 AB (cum laude) Phi Beta Kappa from Princeton University's Woodrow Wilson School of Public and International Affairs, and received his JD, with distinction, from Stanford Law School.
|
James Fuller |
|
|---|---|
|
Fenwick & West LLP Silicon Valley Center 801 California Street Mountain View, CA 94041 US Tel: +1 650 335 7205 Fax: +1 650 919 0942 Email: jpfuller@fenwick.com Website: www.fenwick.com Jim Fuller is a partner in the tax group at Fenwick & West in Mountain View, California. He is one of the world's top 25 tax advisers, according to Euromoney. Fuller is described as one of the three "most highly regarded" US tax practitioners in Law Business Research's Who's Who Legal (2016), and is the only US tax adviser to receive a coveted Chambers 'star performer' rating (higher than first tier) in Chambers USA (2017). Fuller and his firm have served as counsel in more than 150 large-corporate IRS Appeals proceedings and more than 70 federal tax court cases. Eight Fenwick tax partners appear in International Tax Review's Tax Controversy Leaders guide. Fenwick has been named US (or Americas) 'Tax Litigation Firm of the Year' three times at International Tax Review's annual Americas Awards. Two of our tax partners were shortlisted by Euromoney at its Women in Business Law Awards in the America's 'Leading Lawyer for Tax Dispute Resolution' category. One is a two-time winner of the award. In 2017, Larissa Neumann won the award for Americas Best in Transfer Pricing. Much of our tax dispute resolution work has involved transfer pricing. Fenwick & West is first tier in International Tax Review's World Transfer Pricing guide (2017). Five Fenwick tax partners have appeared in Euromoney's Transfer Pricing Expert Guide. Transfer pricing cases in which we have been involved include: Apple Computer, Xilinx, DHL, and LimitedBrands, among others. The vast majority of our transfer pricing cases have been resolved in appeals, some on a 'no change' basis. Other cases in which we've represented clients in federal tax litigation matters include those that involved Sanofi, CBS, Analog Devices, Dover, Chrysler, Textron, Johnson Controls, Del Commercial, Illinois Tool Works, VF, S.C. Johnson, Intel, CMI Int'l, Laidlaw, Hitachi, Union Bank, GM Trading, and others.
|
Jennifer Fuller |
|
|---|---|
|
Fenwick & West LLP Silicon Valley Center 801 California Street Mountain View, CA 94041 US Tel: +1 650 335 7284 Email: jfuller@fenwick.com Website: www.fenwick.com Jennifer Fuller is a senior partner in the tax group at Fenwick & West in Mountain View, California. She was included for the fifth time as one of the world's top 25 women tax advisers in Euromoney's guide to the world's leading women business lawyers (2015). Jennifer was named 'America's Best in Tax Dispute Resolution' by Euromoney at its 2014 and 2015 Americas Women in Business Law awards, the only repeat winner. She also has been on Euromoney's Women in Business Law shortlist four times for the award 'Best in Tax'. Jennifer's work during 2016 included large-corporate tax litigation and M&A matters, including work on some of the recent and widely publicised inversion transactions. Jennifer is on the executive leadership committee of the International Fiscal Association, which is a highly-regarded worldwide association of leading tax advisers, and has appeared regularly in Euromoney's guide to the world's leading tax lawyers. Jennifer has served as the Northern California chair for the California State Bar International Tax Committee. She has spoken at and chaired numerous seminars on international tax subjects. Jennifer's articles have appeared in Tax Notes International magazine and in Tax Notes magazine. Whittier College awarded Jennifer its Alumna Achievement Award in 2013 "for superior accomplishments in her career". Later that year, Jennifer was elected to serve on the Whittier College Board of Trustees, a position she still holds. Jennifer has been a tax partner at Fenwick for more than 20 years, and plays an instrumental role in the firm's tax practice. The firm has represented six of the Fortune top 10 companies, more than 50 of the Fortune 100 and more than 100 of the Fortune 500 companies in federal tax matters. Jennifer has also been included in Euromoney's guide to the world's leading tax advisers, Law and Business Research's International Who's Who of Corporate Tax Lawyers, International Tax Review's leading lawyers in the western US, Euromoney's guide to the leading US tax lawyers, and International Tax Review's guide to the best tax advisers in North America.
|
Erin G Gladney |
|
|---|---|
|
Mayer Brown 1221 Avenue of the Americas New York, NY 10020-1001 US Tel: +1 212 506 2639 Fax: +1 212 262 1910 Email: egladney@mayerbrown.com Website: www.mayerbrown.com Erin G Gladney is a tax controversy partner in Mayer Brown's New York office. Erin represents clients in all stages of federal tax controversies, including audits, administrative appeals, and litigation. Her experience includes controversies involving transfer pricing, advance pricing agreements, economic substance, substance-over-form doctrines, and summons enforcement. Erin also has experience defending against civil tax penalties and preserving taxpayers' attorney-client privilege and work product protection during audit, appeals, and litigation.
|
Edward Grady Jr |
|
|---|---|
|
Deloitte Tax LLP 30 Rockefeller Plaza New York, NY 10112-0015 US Tel: +1 212 436 3936 Fax: +1 844 227 6293 Email: edgrady@deloitte.com Website: www.deloitte.com Edward Grady Jr, Deloitte US, has more than 35 years of experience managing and negotiating the resolution of substantive financial services industry issues at global financial institutions. He recently retired as a managing director and head of federal tax controversies at JPMorgan Chase where he was a member of the corporate tax department's management team. During his tenure, he successfully resolved more than 35 multi-year IRS examinations with all levels of the IRS, including examination, appeals and fast track. Ed has also served as an adjunct assistant professor of tax in the graduate programme at CUNY-Baruch College's Zicklin School of Business. He earned his undergraduate degree in accounting from St. Peter's University and his JD from Fordham Law School. He is a member of the New Jersey and District of Columbia Bars.
|
Adam Halpern |
|
|---|---|
|
Fenwick & West LLP Silicon Valley Center 801 California Street Mountain View, CA 94041 US Tel: +1 650 335 7111 Email: ahalpern@fenwick.com Website: www.fenwick.com Adam Halpern is the chair of the tax group at Fenwick & West. His practice focuses on the US federal income taxation of international transactions, including Subpart F, foreign tax credits, transfer pricing, tax treaties, characterisation and source of income, inversions, and expense allocation. He regularly advises on the taxation of cross-border operations, acquisitions, dispositions, and restructurings. Adam's controversy practice spans federal tax controversies at all levels, including audit, appeals, and litigation in the Tax Court and the Court of Federal Claims. His matters have included transfer pricing, section 367(d), substantial contribution, and complex tax treaty issues, among others. He was involved in the Dover check-the-box case. He has handled large IDR and summons defence matters involving extensive document review, production and privilege issues. Adam is a lecturer in law at Stanford Law School, a co-lecturer at UC Berkeley Law School, and the 2013 distinguished adjunct professor at Golden Gate University's masters in taxation programme, teaching classes in international tax. He is a frequent speaker at Tax Executives Institute and the Practising Law Institute. Adam is recognised as a leading tax lawyer by Euromoney, International Tax Review and Chambers USA. The Fenwick & West tax group has advised more than 100 Fortune 500 companies on tax matters, and has served as counsel in more than 150 large-corporate IRS appeals proceedings and more than 70 federal court tax cases. Recent high-profile court cases include Analog Devices, Inc. v. Commissioner, 147 T.C. No. 15 (2016); CBS Corp. v. United States, 2012-1 C.B. 50,346 (Fed. Cl.); and Xilinx, Inc. v. Commissioner, 125 T.C. 37 (2005), aff'd, 598 F.3d 1191 (9th Cir. 2010). The Wall Street Journal described Xilinx as "the biggest tax case in the last 20 years." It has laid the foundation for the next generation of transfer pricing. Fenwick has been named San Francisco Tax Firm of the Year and US Tax Litigation Firm of the Year numerous times by International Tax Review.
|
John T Hildy |
|
|---|---|
|
Mayer Brown 71 S Wacker Drive Chicago, IL 60606 US Tel: +1 312 701 7769 Fax: +1 312 706 8785 Email: jhildy@mayerbrown.com Website: www.mayerbrown.com John T Hildy is an experienced advocate in federal tax disputes faced by multinational corporations. He has represented clients in some of the most complex tax litigation in the country. The amounts at stake in federal tax disputes can often be staggering. So big, in fact, that it often seems cases become "too big to settle" as the positions of the tax authorities and taxpayers are separated by hundreds of millions, and even billions, of dollars. John is adept at bridging this gap. Over the course of his career, he has participated in settlements of two disputes in which the dollars at stake reached into 10 digits. John's practice also emphasises issue resolution at the earliest stage feasible, not just on the steps of the courthouse. To that end, John has experience using a broad set of alternative dispute resolution tools, including: Tax Court-supervised mediation; IRS appeals review of docketed issues; early referral to appeals; fast track and appeals mediation; pre-filing agreements (PFAs); and competent authority and advanced pricing agreements (APAs). John frequently advises clients in addressing the types of evidentiary privileges most commonly encountered by the tax department (e.g. attorney-client, tax adviser, work product privileges) and represents taxpayers in associated administrative summons enforcement matters where necessary. The mainstay of John's controversy practice relates to disputes surrounding international tax matters, especially transfer pricing. As a complement to John's controversy practice, he also regularly advises clients on how to structure and defend transactions with significant transfer pricing implications, including cross-border transfer pricing of tangible and intangible property, shared headquarter services, and cost sharing arrangements. He has advised both US taxpayers with respect to international tax implications of offshore operations, as well as non-US taxpayers with respect to the implications of their US activities. John has been recognised as a leading tax controversy adviser in International Tax Review's Tax Controversy Leaders guide since 2011 and is also recognised as a notable practitioner by Chambers USA.
|
Cynthia Hustad |
|
|---|---|
|
Deloitte Tax LLP 555 Mission Street San Francisco, CA 94105-0920 US Tel: +1 415 783 5567 Fax: +1 415 783 8962 Email: chustad@deloitte.com Website: www.deloitte.com Cindy Hustad, Deloitte US, is the West Region tax controversy competency leader and represents corporate clients before the IRS. During her 15-year tenure at Deloitte, Cindy has successfully represented many large and small clients, both at the examination and appeals levels, specialising in transfer pricing and international issues. Before joining Deloitte, Cindy was a special trial attorney with the IRS Chief Counsel's Office where she represented the IRS in the US Tax Court in upwards of 50 litigated cases. During her period at the IRS, Cindy also advised large case agents, international examiners, and appeals officers in some of the largest examinations undertaken by the IRS involving a wide range of complex international and domestic corporate issues. Cindy also represented the government in litigating several large corporate tax and transfer pricing cases, including DHL v. Commissioner. Cindy has also held the position of law clerk at the US Court of Appeals for the Ninth Circuit, while other positions held include acting assistant professor at the New York University Law School. Cindy is admitted to the state bar of California, holds an admission to practice at the US Tax Court and is a past president of the San Francisco Tax Litigation Club. She was also the recipient of the IRS Chief Counsel National Litigation Award in 1997. Cindy holds a BA from the University of Wisconsin, a JD from the University of Wisconsin Law School and achieved her LLM (tax) at the New York University Law School.
|
Sharon Katz-Pearlman |
|
|---|---|
|
KPMG 345 Park Avenue New York, NY 10154 US Tel: +1 212 872 6084 Fax: +1 212 409 8270 Email: skatzpearlman@kpmg.com Website: www.kpmg.com Sharon Katz-Pearlman is the national principal-in-charge of KPMG's tax dispute resolution network in the US. She also serves as KPMG International's head of global tax dispute resolution and controversy, overseeing a network of dispute resolution specialists from KPMG's member firms. Sharon advises clients during all phases of the disputes continuum, from pre-dispute (e.g. audit readiness, voluntary disclosures, pre-filing assistance) through to examination, appeals and the alternate dispute resolution processes. With more than 25 years of experience in the field, Sharon works with clients on all aspects of their IRS matters, dealing with a wide variety of domestic and international tax issues. Sharon's US practice focuses primarily on representation before the IRS, of multinational corporate clients and financial institutions, both domestic and international. She provides assistance in all facets of alternate dispute resolution, including pre-filing agreements, early referral and mediation, as well as traditional examination and appeals consulting. Sharon advises on disputes involving a wide range of technical issues including transfer pricing, corporate reorganisations, partnership matters, and competent authority proceedings. She is also an adjunct professor of law at the New York University School of Law, where she teaches civil tax controversies and litigation, in the LLM (graduate tax) programme. Prior to joining KPMG, Sharon was a special litigation attorney with the IRS Office of Chief Counsel, Manhattan district counsel, advising many exam and appeals teams on varied issues. She was also responsible for the development and litigation of major tax matters before the US Tax Court and served on a number of litigation teams. While with the IRS, Sharon received the National Attorney of the Year Award (the James Markham Memorial Award), presented annually to one field attorney in the country for outstanding contribution to the Office of Chief Counsel. Sharon is a frequent presenter at tax conferences and has spoken at those sponsored by The American Law Institute, the Practicing Law Institute, NYU Tax Institute, the NYU Tax Controversy Forum (which she has co-chaired), the Southern Federal Tax Institute, the Institute of International Bankers, Tax Executives Institute, Executive Enterprises, and the Center for International Tax Education and the ABA Tax Section. She has published several articles addressing various IRS procedural issues, and has authored a chapter in The Transfer Pricing Handbook, discussing the IRS examination process for transfer pricing taxpayers. She has also published several articles on various IRS related topics, including the fast track mediation/settlement programme, the IRS Restructuring Act, transfer pricing and the corporate reportable transaction regulations. Sharon is listed in International Tax Review's Tax Controversy Leaders guide, and the Comprehensive Guide to the World's Leading Tax Controversy Advisors. 
|
John Keenan |
|
|---|---|
|
Deloitte Tax LLP 555 12th St NW Ste 400 Washington, DC 20004-1207 US Tel: +1 202 879 5605 Email: jkeenan@deloitte.com Website: www.deloitte.com John R Keenan, Deloitte US, is the managing director of the tax controversy group in the Washington national tax office. In his role as a tax controversy specialist, John represents clients before the IRS Examination Division and IRS Appeals. John also assists clients on a wide range of procedural issues, such as statute of limitations, refund claims, and penalty issues as well as solving sensitive problems through strategic solutions. Before joining Deloitte, John worked in Arthur Andersen's federal tax services office, specialising in tax controversy issues. From 1988 to 1998, John served as a senior attorney in the IRS Chief Counsel's Office where he represented the IRS before the United States Tax Court and provided advice to IRS personnel on all matters incident to the assessment and collection of taxes. John also was appointed a special assistant US attorney, which allowed him to represent the IRS in the US Bankruptcy Courts. John has a number of qualifications and memberships. He has been admitted to the District of Columbia Bar and the Tennessee Bar, and is admitted to practice in the US Tax Court. He is a member of the administrative practice committee of the American Bar Association, and a member of the IRS advocacy and relations committee at the American Institute of CPAs (AICPA). John also frequently speaks to professional groups on IRS controversy and IRS practice issues. He has a JD from the University of Memphis and a BA from Rutgers University.
|
Andrew J Kim |
|
|---|---|
|
Fenwick & West LLP Silicon Valley Center 801 California Street Mountain View, CA 94041 US Tel: +1 650 335 7146 Email: akim@fenwick.com Website: www.fenwick.com Andrew Kim is a partner in the tax group of Fenwick & West. His practice focuses on US and international corporate tax matters, and tax dispute matters. Andy has significant experience in representing clients with respect to cross-border transactions, corporate restructurings, international joint ventures, transfer pricing, and dispute resolution matters. Andy appears in Euromoney's World's Leading Tax Advisors, International Tax Review's Tax Controversy Leaders guide, Law Business Research's Who's Who Legal: Corporate Tax, The Legal 500, and Chambers USA. Andy served as counsel in Analog Devices, Inc. v. Commissioner in the US Tax Court, and CBS Corporation v. United States in the US Court of Federal Claims, and currently serves as counsel in TBL Licensing LLC v. Commissioner in the US Tax Court. Andy is a lecturer at the University of California, Berkeley School of Law, where he teaches international taxation. He has published articles on international tax issues and developments in the Journal of Taxation, International Taxation, the Euromoney Corporate Tax Handbook, and World Tax. Andy frequently speaks on international tax issues at meetings for professional tax groups, including the Tax Executives Institute and Bloomberg BNA. Fenwick's tax practice has earned a reputation as one of the nation's leading domestic and international tax practices. Fenwick was named US (or Americas) Tax Litigation Firm of the Year three separate times by International Tax Review. Fenwick has also been recognised by International Tax Review as first tier in both its rankings for the world's leading tax planning firms and world's leading transactional firms, and has been recognised as the Americas M&A Tax Firm of the Year. Andy received his JD (cum laude) from Harvard Law School, and BS in psychology with highest honours from the University of Illinois. Andy is a member of the State Bars of California and Illinois.
|
Thomas Kittle-Kamp |
|
|---|---|
|
Mayer Brown 71 S Wacker Drive Chicago, IL 60606 US Tel: +1 312 701 7028 Fax: +1 312 706 9197 Email: tkittlekamp@mayerbrown.com Website: www.mayerbrown.com Tom Kittle-Kamp is the co-leader of Mayer Brown's tax controversy and transfer pricing practice. His litigation experience includes the trial and appeal of major corporate cases involving Section 482 allocations, substance-over-form theories, intangible assets, debt-equity characterisation, valuation disputes, capitalisation 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 extensive experience in all aspects of international transfer pricing, particularly matters involving intangible assets and intellectual property. As an adjunct to his tax controversy practice, Tom 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 has been repeatedly recognised by Chambers USA, Legal 500, and International Tax Review's Tax Controversy Leaders guide. He is the co-author of the treatise "Federal Income Taxation of Intellectual Properties and Intangible Assets" (Thomson Reuters WG&L Tax Series 1997), which is updated twice a year. Before law school, he worked as a newspaper reporter.
|
Brian W Kittle |
|
|---|---|
|
Mayer Brown 1221 Avenue of the Americas New York, NY 10020-1001 US Tel: +1 212 506 2187 Fax: +1 212 849 5987 Email: bkittle@mayerbrown.com Website: www.mayerbrown.com Brian W Kittle is co-leader of Mayer Brown's tax controversy and transfer pricing practice. Since joining the firm in 2006, Brian has represented clients in every facet of tax controversy and litigation – from IRS examinations and administrative appeals, through the litigation, trial and appellate review of highly complex tax controversies involving a broad range of international and domestic tax issues. His controversy experience also includes frequent use of IRS alternative dispute resolution tools, including pre-filing and advance pricing agreements. In addition to his controversy practice, Brian also provides tax advice on related party and highly-sophisticated transactions involving acquisitions and integrations. He also frequently speaks on and authors articles about substantive and procedural tax issues. Brian has been repeatedly recognised as a rising star by International Tax Review's Tax Controversy Leaders guide and Super Lawyers. Brian is also recognised as a notable practitioner by Chambers USA for Tax: New York. Before joining Mayer Brown, Brian served as an attorney adviser to Judge Joseph R Goeke of the US Tax Court. This experience provides him with unique insight into the Tax Court's procedures and decision-making process.
|
Kenneth Klein |
|
|---|---|
|
Mayer Brown 1999 K Street, NW Washington, DC 20006-1101 US Tel: +1 202 263 3377 Fax: +1 202 263 3300 Email: kklein@mayerbrown.com Website: www.mayerbrown.com Kenneth Klein concentrates his practice on international taxation. His experience includes planning, structuring/restructuring, tax controversies (IRS examinations and appeals), regulations, legislation, private letter rulings, and amicus briefs. He has represented domestic and international clients in numerous industries, including manufacturing, financial services, software, transportation, pharmaceuticals, services, real estate, agricultural, trading, and entertainment, among others. Ken has experience with outbound investments, inbound investments, income bifurcation and amalgamation, controlled foreign corporations (subpart F), investments in US property, intangibles, contract manufacturing, source of income, foreign tax credits, transfer pricing, portfolio interest, conduit financing arrangements, withholding tax, tax treaties, investment funds, derivatives, and stock and securities lending. Ken was co-chairman of Mayer Brown's tax transactions practice from 2006-2012. Before Mayer Brown, Ken worked at the IRS, first as attorney and then as assistant branch chief in the legislation and regulations division and the general litigation division (1977-1981), and later as the associate chief counsel (technical) (1988-1990). Ken was an associate and then a tax partner at Cadwalader, Wickersham & Taft from 1981-1988 and 1990-2002. He was also a fellow of the American Society of International Law (1976-1977). Ken is recognised year after year for his skills in international taxation. He has been lauded by clients for his "sophisticated cross-border tax planning, structuring and restructuring for a number of US and non-US multinationals". Legal 500 refers to Ken as "very experienced" and has named him a leading lawyer for six consecutive years. For the past seven years, Ken has been named among the world's leading tax advisers (Euromoney). He is recognised as a leading tax controversy adviser in International Tax Review's Tax Controversy Leaders guide and named among the 'Best Tax Lawyers' in Washington DC by Washingtonian Magazine and Washington Post Magazine. Ken has also been featured as a leading tax lawyer in Washington DC by Super Lawyers for six consecutive years. Ken is chair of the Washington International Tax Study Group, president of the Legal Aid Society of the District of Columbia and is on the board of visitors of the University of Georgia School of Law.
|
Larry R Langdon |
|
|---|---|
|
Mayer Brown Two Palo Alto Square, Suite 300 3000 El Camino Real Palo Alto, CA 94306-2112 US Tel: +1 650 331 2075 Fax: +1 650 331 4575 Email: lrlangdon@mayerbrown.com Website: www.mayerbrown.com Attorney Larry R Langdon brings comprehensive experience in the areas of tax controversy and planning to clients' service. He is widely recognised for his knowledge of federal tax policies and applications and has been characterised by Chambers USA as "a great tax mind". Larry has been a speaker at the American Bar Association Section of Taxation, American Institute of CPAs, Manufacturers Alliance [MAPI], Tax Executives Institute and many other professional and industry groups. Larry joined Mayer Brown in 2003. Previously, he held senior positions with the US Internal Revenue Service (commissioner, large and mid-size business division, 1999-2000; legislation and regulations division, office of counsel, 1964-1968; and joint committee division, office of chief counsel, 1961-1962) and, in the private sector, with leading firms such as Hewlett-Packard (VP, general transition manager, 1999; VP, tax, licensing and customs, 1978-1999); Vetco (director of taxes and corporate secretary, 1976-1978); and the Ford Motor Company (senior tax attorney, general counsel's office, 1968-1976). Larry also worked with the CARE organisation from 1962-1964.
|
Marc Levey |
|
|---|---|
|
Baker McKenzie 452 Fifth Avenue New York, NY 10018 US Tel: +1 212 891 3944 Fax: +1 212 310 1644 Email: marc.levey@bakermckenzie.com Website: www.bakermckenzie.com Marc Levey is a partner in the New York office of Baker McKenzie. He has more than 35 years of experience in international taxation and is a nationally recognised expert in his field, particularly in structuring and defending transfer pricing strategies. He has frequently been acknowledged by Euromoney in its guide to the world's leading tax advisers and included in its Best of the Best global tax experts. Marc's practice focuses on transfer pricing and cross-border transactions; tax controversies and litigation; general corporate, international and partnership taxation, and restructuring multinational company's global operations. He has worked in various industries such as pharma/life sciences, financial institutions, energy, automotive, chemicals, electronics, consumer goods, gaming, fashion and luxury products. Marc serves on the US transfer pricing management committee, was the past chairman of the firm's global transfer pricing steering committee and is chair of the firm's luxury and fashion industry practice group. Marc previously served as tax attorney with the international tax ruling group of the National Office of the Internal Revenue Service (IRS) from 1975 to 1977. He acted as senior trial attorney with the Tax Division of the US Department of Justice from 1977 to 1981. He was the Special Attorney to the Attorney General of the US Department of Justice in 1982. Marc represents a wide range of clients in proceedings before the IRS and federal courts and has substantial experience in handling tax controversies. He has been, and still is, tax counsel to numerous significant Tax Court and US Claims Court cases and has also successfully negotiated conclusions to numerous IRS tax audits, appeals controversies, fast track appeals, Competent Authority matters and advance pricing agreements. Marc has been a featured speaker at numerous international tax seminars throughout the world. He is also the editor and author of tax treatises US Taxation of Foreign Controlled Business, co-author of International Transfer Pricing OECD Guidelines, Warren Gorman Lamont treatises, the co-author of Transfer Pricing: Rules, Compliance and Controversy 4th Edition, CCH Incorporated, the co-author of Transfer Pricing: Alternate Practical Strategies 890 Tax Management Foreign Income Portfolios (2001 and 2007), co-editor of Transfer Pricing and Dispute Resolution (IBFD 2011) and co-editor of Transfer Pricing and Intra-Group Financing (IBFD 2012). Marc has authored more than 180 publications over the last 20 years in leading global tax publications. He received his JD from University of Cincinnati College of Law in 1972 and his BS from Wilkes University in 1969. He received his LLM in taxation with honours from University of Miami Law School in 1983. He is admitted to practise in the states of New York, California and in the District of Columbia. 
|
Darrin Litsky |
|
|---|---|
|
Deloitte Tax LLP 30 Rockefeller Plaza New York, NY 10112-0015 US Tel: +1 212 436 5760 Fax: +1 212 653 7883 Mobile: +1 646 436 6402 Email: dlitsky@deloitte.com Website: www.deloitte.com Darrin Litsky, Deloitte US, is trained as a lawyer and is a certified public accountant. He is also a transfer pricing specialist in Deloitte's New York office. Darrin has a diverse background of 30 years of professional tax and accounting experience with industry, Big 4 firms, a major law firm, and the Internal Revenue Service's (IRS) advance pricing agreement (APA) programme. While in industry, Darrin served as general tax counsel of a publicly owned telecommunications company and was responsible for its worldwide transfer pricing in more than 40 countries. Darrin served as a team leader for four years with the IRS APA programme. Including his time in government practice, Darrin has been substantively involved in hundreds of APA and mutual agreement procedure (MAP) requests involving a variety of different countries and industries. His current transfer pricing practice is primarily APA and MAP request representations and audit defence. Darrin is a past chairman of the transfer pricing committee of the American Bar Association (ABA) Tax Section. In 2014, Darrin led an ABA task force that provided formal comments to the IRS on proposed procedures for obtaining an APA. Similarly, in 2005, Darrin was responsible for leading the ABA's formal comments to the IRS on the operation of the APA programme. As part of this effort, he provided oral testimony on the APA programme in a public hearing held in Washington. In 2004, Darrin led another ABA task force that provided formal comments on proposed Treasury regulations for transfer pricing of intercompany services. In 2006, Darrin contributed to the ABA's comments on temporary Treasury regulations for transfer pricing of intercompany services. His recent articles and publications include:
Darrin has also given numerous speeches and presentations over the years at the American Bar Association, the American Conference Institute, New York University, Tax Executive Institute, Broadband Tax Institute, CITE, ATLAS, and at IRS meetings and conferences on transfer pricing issues and advance pricing agreements including the following:
Darrin obtained his JD from Georgetown University Law Center in 1993 and a BS Economics, (magna cum laude) from the Wharton School, University of Pennsylvania, in 1986.
|
William McGarrity |
|
|---|---|
|
Mayer Brown 71 S Wacker Drive Chicago, IL 60606 US Tel: +1 312 701 8928 Fax: +1 312 706 9236 Email: wmcgarrity@mayerbrown.com Website: www.mayerbrown.com William McGarrity is a tax controversy partner in Mayer Brown's Chicago office. He represents clients in all stages of federal tax controversies, including examination, administrative appeals, and litigation. Will's work encompasses issues related to transfer pricing, cost sharing agreements, valuation, treatment of goodwill and going concern value, debt-equity characterisation, economic substance, and administrative procedure as applied to the IRS regulatory process. Will has experience litigating major corporate cases in the areas of transfer pricing, debt-equity characterisation, and administrative law challenges to regulations (Altera, Guidant, Tyco). Throughout these litigation matters, Will has worked extensively with leading experts in the fields of economics, finance, and forensic accounting. Will also advises clients on transfer pricing documentation and structuring, particularly with respect to intangible property (both discrete IP as well as novel issues related to soft intangibles like goodwill and going concern value), drawing on his litigation experience to anticipate potential legal and expert arguments.
|
Kristin M Mikolaitis |
|
|---|---|
|
Mayer Brown 1221 Avenue of the Americas New York, NY 10020-1001 US Tel: +1 212 506 2265 Email: kmikolaitis@mayerbrown.com Website: www.mayerbrown.com Kristin M Mikolaitis is a partner in the tax controversy practice in Mayer Brown's New York office. Since joining the firm in 2008, Kristin has represented taxpayers at all stages of federal tax controversies, including during audit, in administrative appeals, and before federal courts. Kristin's controversy experience includes major corporate tax matters involving international tax and transfer pricing, substance-over-form disputes, economic substance issues, financial and leasing transactions, and civil tax penalties. Her litigation experience includes extensive pre-trial and trial work in the US Court of Federal Claims and the US Tax Court, as well as matters in various US courts of appeals. Kristin has also actively participated in the firm's pro bono efforts by representing individuals in tax, landlord-tenant, and estate planning matters. Kristin serves on the firm's committee on diversity and inclusion, hiring committee, and litigation training committee, and the New York office's women's forum steering committee. She also serves on the National Women's Law Center's leadership advisory committee and is co-chair of its pro bono services and public policy sub-committee.
|
Mark Nehoray |
|
|---|---|
|
Deloitte Tax LLP 555 W. Fifth Street Los Angeles, CA 90013 US Tel: +1 213 688 4104 Email: mnehoray@deloitte.com Website: www.deloitte.com Mark Nehoray, Deloitte US, is a senior partner, based in Los Angeles. Mark is consistently recognised as a leading transfer pricing adviser by publications including International Tax Review and Euromoney's Transfer Pricing Expert Guide. With more than 35 years of experience in tax and transfer pricing, Mark assists multinationals with transfer pricing studies, restructuring of foreign royalties and other foreign income streams. Mark led the team that successfully negotiated Mexico's first transfer pricing ruling. Mark is the transfer pricing adviser to three of the world's largest multinationals and has conducted a significant number of transfer pricing studies across various industries (e.g. entertainment and media, gaming, multi-level marketing, hi-tech, apparel, and non-profit). These projects have included both defensive work with respect to on-going Internal Revenue Service (IRS) audits and Competent Authority assistance, as well as planning studies and APAs. Over the past 15 years, he has been responsible for Deloitte's largest APA, as well one of the largest multilateral APAs in the programme. He is currently assisting two large US-based multinationals with their IRS transfer pricing examinations, another two US-based multinationals with their unilateral APAs, as well as assisting 10 foreign-based multinationals with their bilateral APAs. Since 2002, Mark has been the executive producer and the host of Deloitte's Transfer Pricing Dbriefs, a monthly internet program. He is a frequent speaker at US transfer pricing conferences sponsored by Bloomberg BNA. His recent publications include: the OECD Guidance on Transfer Pricing Documentation: Preparing for the New Global Standard; Bloomberg BNA's Tax Management Transfer Pricing Report (May 26 2016); Complying with OECD's Country-by-Country Reporting, Anaplan (November 2014); 'Integrating Tax and Treasury Operations with Transfer Pricing' in the CFO Journal (from the Wall Street Journal, August 27 2014); and International Tax Review's 'Transfer Pricing of Intangibles – Media and Entertainment' (December 2013), ('Turning Tech Investments into Value Repositories' (February 2011), and 'How APAs Fit into Today's Regulatory Landscape' (May 2009). Mark has a bachelor's degree in business administration and a master's degree in business taxation from the University of Southern California.
|
Larissa Neumann |
|
|---|---|
|
Fenwick & West LLP Silicon Valley Center 801 California Street Mountain View, CA 94041 US Tel: +1 650 335 7253 Email: lneumann@fenwick.com Website: www.fenwick.com Larissa Neumann focuses her practice on US tax planning and tax controversy with an emphasis on international transactions. She has broad experience advising clients on mergers and acquisitions, restructurings and has extensive transfer pricing experience. She has successfully represented clients in federal tax controversies at the audit level and in IRS appeals, the US Tax Court and in other federal courts. Larissa's keen analytical skills coupled with her focus on providing clients practical solutions to complex tax issues have earned her a reputation as a leading tax adviser both in the Silicon Valley and nationwide. Larissa appears in Euromoney's World's Leading Tax Advisers and International Tax Review's Tax Controversy Leaders guide. Larissa teaches international tax at the University of California, Berkeley Law School and co-authors a monthly column in Tax Notes International. Larissa was counsel in the recent important taxpayer Tax Court victory involving transfer pricing for Analog Devices, Inc. v. Commissioner, 147 T.C. No. 15 (2016), and the 2017 successful resolution for Sanofi in Aventis, S.A. v. United States, US Court of Federal Claims Dkt. No. 11-647T. She also is counsel for VF Corporation/Timberland in TBL Licensing LLC v. Commissioner, Tax Court Dkt. No. 21146-15, a pending Tax Court case that involves § 367(d) and § 482. Euromoney's Women in Business Law named Larissa as America's best transfer pricing lawyer in 2017. She also was named by Euromoney as one of the world's leading transfer pricing advisers (2017). Larissa appears in Euromoney's Women in Business Law (a short list of the top women tax lawyers in the world) and International Tax Review's Women in Tax Leaders guide. Euromoney Women in Business Law shortlisted Larissa twice for the award America's Best Lawyer in Tax Dispute Resolution. Larissa was named to the Daily Journal's 2017 list of Top Women Lawyers in California and was honoured with the Women of Influence award by the Silicon Valley Business Journal in 2017. In 2016, Larissa was named a Rising Star in tax by Law360 and named in the Silicon Valley Business Journal's 40 Under 40. Larissa frequently speaks at conferences for professional tax groups, including TEI, IFA, Pacific Rim Tax Institute, Bloomberg, and the ABA. She is the ABA international law tax liaison. Fenwick has one of the world's top tax planning and tax transactional practices, according to International Tax Review, and is first tier in tax, according to World Tax. Fenwick is consistently named the San Francisco Tax Firm of the Year by International Tax Review and has been named US Tax Litigation Firm of the Year a number of times.
|
Shawn R O’Brien |
|
|---|---|
|
Mayer Brown 700 Louisiana Street Suite 3400 Houston, TX 77002-2730 US Tel: +1 713 238 2848 Fax: +1 713 238 4602 Email: sobrien@mayerbrown.com Website: www.mayerbrown.com Shawn R O'Brien is a tax controversy partner in the Houston office. Shawn represents clients in all types of tax disputes with taxing authorities on international, federal and state levels. He routinely advises clients on various tax issues during tax examinations, in administrative appeals and as an advocate in trial and appellate litigation before the US Tax Court, US district courts and the US Court of Federal Claims. Shawn's tax controversy and litigation experience spans a broad range of areas, including transfer pricing controversies, debt versus equity issues, international withholdings, advance pricing agreements, tax shelter disallowances, estate and gift tax valuations, research and development tax credits, excise taxes, and changes in accounting methods. Shawn advises foreign and domestic corporations, partnerships, MLPs, and LLCs seeking corporate and tax advice in connection with various types of foreign and domestic transactions, including mergers and acquisitions, restructurings, divestitures, leveraged buyouts, structured financings, and oil and gas transactions. Shawn serves on the Internal Revenue Service Advisory Council (IRSAC) where he is a member of the large business and international (LB&I) subcommittee. IRSAC was created to provide an organised public forum for IRS officials and representatives of the public to discuss key tax administration issues. IRSAC provides the IRS Commissioner and divisions' leadership with important feedback, observations, and suggestions. Shawn is particularly focused on a variety of tax issues facing the energy industry including tax controversy, joint ventures, restructuring, acquisition and disposition of energy assets. Shawn is ranked in Chambers USA 2017 Tax: Litigation – Texas.
|
Pam Olson |
|
|---|---|
|
PwC 600 13th Street NW, Suite 1000 Washington, DC 20005 US Tel: +1 202 414 1401 Fax: +1 678 529 1022 Email: pam.olson@us.pwc.com Website: pwc.com/taxcontroversy Pam Olson is a US deputy tax leader and Washington national tax services (WNTS) leader of PwC. In her role with WNTS, Pam leads a team that includes many former senior government officials and policy advisers. Prior to joining PwC, Pam led the Washington tax practice at Skadden, Arps, Slate, Meagher & Flom and served as assistant secretary for tax policy at the US Department of Treasury. Pam has represented clients in a broad range of matters, including IRS audits, appeals and litigation; congressional investigations; private letter ruling requests, proposed regulations, and other IRS and Treasury guidance; and in the legislative process. She has advised clients on tax and social security reform and on the structuring of financing, partnership, and M&A transactions. She is a frequent speaker on tax, economic and federal budget matters and has testified before several congressional committees, most recently before the Senate Finance Committee on international tax reform. Pam also held positions with the chief counsel's office of the Internal Revenue Service as special assistant to the chief counsel, attorney-adviser in the Legislation and Regulations Division and trial attorney in San Diego District Counsel. In 2000 and 2001, Pam was the first woman to serve as chair of the American Bar Association Section of Taxation. Pam received her BA, MBA, and JD from the University of Minnesota.
|
Edward C Osterberg Jr |
|
|---|---|
|
Mayer Brown 700 Louisiana Street Suite 3400 Houston, TX 77002-2730 US Tel: +1 713 238 2666 Fax: +1 713 238 4656 Email: eosterberg@mayerbrown.com Website: www.mayerbrown.com Edward C Osterberg Jr is a tax transactions and consulting partner in Mayer Brown's Houston office. His extensive experience includes all areas of business income taxation, with emphasis on corporate and partnership taxation and international transactions. Ed has advised corporate and individual clients on the federal tax consequences of various transactions, including mergers and acquisitions, tax-free reorganisations, corporate spin-offs and other divestitures, partnerships, international operations including cross-border joint ventures with non-US partners, and inbound investment into the US by non-US investors. Chambers USA refers to Ed as "the dean of tax" and "very bright". Chambers USA also says: "He devotes a substantial part of his practice advising on the tax implications of high-value corporate matters, such as debt and equity instruments, spin-offs and restructurings". In addition to numerous speaking engagements and publications in the tax area, Ed recently served as president of the International Fiscal Association US Branch.
|
Kimberley Peterson |
|
|---|---|
|
Deloitte Tax LLP 225 West Santa Clara Street Suite 600 San Jose, CA 95113-2303 US Tel: +1 408 704 4041 Fax: +1 408 704 8074 Email: kimpeterson@deloitte.com Website: www.deloitte.com Kimberley Peterson, Deloitte US, is a managing director in the Silicon Valley office of Deloitte Tax's tax controversy services west region practice. Since joining Deloitte in 2008, Kim has successfully represented many corporate and partnership clients before the Internal Revenue Service (IRS), both at the examination and appeals levels, throughout the US. Kim specialises in transfer pricing and other cross-border and international issues. Before joining Deloitte, Kim spent 13 years with the IRS Chief Counsel's Office, as international field counsel, associate area counsel, and deputy area counsel for strategic litigation. While at the IRS, Kim advised large case agents, international examiners, and appeals officers in some of the largest examinations undertaken by the IRS, involving a wide range of complex international and domestic corporate issues. Kim also represented the IRS in the US Tax Court in large case litigation involving transfer pricing and other international issues, including in the DHL v. Commissioner and Microsoft v. Commissioner cases, receiving western regional and national litigation awards. As associate area counsel and deputy area counsel for strategic litigation, Kim had responsibility for large case litigation, including the special trial attorney litigation of Xilinx v. Commissioner and Veritas v. Commissioner. Kim is a member of the State Bar of California and is admitted to practice before the US Tax Court and the US Court of Appeals for the Ninth Circuit. Kim is a frequent speaker on IRS practice and procedure and the management of complex IRS examinations, especially transfer pricing examinations. In 2015, Kim became an instructor in tax practices, penalties and procedures in the San Jose State University master's in taxation programme. Kim received her BS in business administration from the University of California, Berkeley, and her JD from the University of Arizona, James E Rogers College of Law.
|
Keith Reams |
|
|---|---|
|
Deloitte Tax LLP 980 9th Street Suite 1800 Sacramento, CA 95814-2738 US Tel: +1 415 783 6088 Email: kreams@deloitte.com Website: www.deloitte.com Keith Reams, Deloitte US, is the US and global leader for clients and markets for Deloitte's global transfer pricing services practice. He has advised clients around the globe on intercompany pricing transactions with respect to income tax regulations in Argentina, Australia, Belgium, Brazil, Canada, Chile, China, Colombia, Czech Republic, Denmark, France, Germany, India, Ireland, Israel, Italy, Japan, Korea, Luxembourg, Malaysia, Mexico, the Netherlands, Norway, Peru, Poland, Singapore, South Africa, Spain, Switzerland, Taiwan, Thailand, the UK, and the US. Keith has assisted numerous multinational enterprises with international valuation and economic consulting services involving merger and acquisition activity, international tax planning, and restructuring and reorganisation of international operations. Keith is on the global tax management team for Deloitte's technology, media and telecommunications (TMT) group and is a leader in the area of transfer pricing for newly emerging industries, such as electronic commerce and cloud computing, where he has extensive experience around the world in helping clients extend their business models into new territories. Keith has testified as a qualified expert in numerous valuation and transfer pricing disputes, including the cases of Nestle Holdings Inc. v. Commissioner; DHL Corp. v. Commissioner; and United Parcel Service of America, Inc. v. Commissioner. In addition, he is one of only three economists in the US approved by the New York State Department of Taxation and Finance to provide transfer pricing expertise and testimony in cases involving cross-border transactions within commonly controlled affiliated groups. He has also helped many clients to successfully resolve valuation and transfer pricing disputes before they reach trial. Keith completed course requirements for a PhD in international finance from New York University. He holds a Master of Arts degree in economics from California State University Sacramento and a BS degree in chemical engineering from Stanford University.
|
William A Schmalzl |
|
|---|---|
|
Mayer Brown 71 S Wacker Drive Chicago, IL 60606 US Tel: +1 312 701 7225 Fax: +1 312 706 9202 Email: wschmalzl@mayerbrown.com Website: www.mayerbrown.com William A Schmalzl focuses on tax litigation, corporate tax planning and state tax advice. He represents clients in all stages of tax litigation. He advises clients extensively during IRS audits. He has resolved many matters at IRS appeals and has used fast track and mediation procedures when appropriate. Further, he has litigated cases in the US Tax Court, federal district court and courts of appeals and Illinois state courts. He has extensive experience with privilege and discovery issues, including electronic discovery. William's trial experience includes Seagate Technology, National Semiconductor, United Parcel Service, RJR Nabisco, ConEd, Wells Fargo and Flextronics. William's practice has focused on international issues, particularly transfer pricing issues. His undergraduate majors in economics and mathematics have proven invaluable in the preparation of expert reports and in the examination of expert witnesses at trials involving transfer pricing issues. In addition to international tax issues, he has represented clients in matters involving the research tax credit, section 199, section 263A, the investment tax credit, debt-equity, substance over form issues, sale-leasebacks, franchises, patents and other intangibles. Before he joined Mayer Brown, William served as an articles editor of the Harvard Law Review and a clerk to the Honourable Robert Ainsworth, Jr of the 5th Circuit Court of Appeals (1977-78).
|
Ronald Schrotenboer |
|
|---|---|
|
Fenwick & West LLP Silicon Valley Centre 801 California Street Mountain View, CA 94041 US Tel: +1 650 335 7207 Fax: +1 650 938 5200 Email: rschrotenboer@fenwick.com Website: www.fenwick.com Ronald Schrotenboer practices at Fenwick & West's Mountain View office. His published decisions include Xilinx, Inc. v. Commissioner, 125 T.C. 37 (2005), aff'd (9th Cir. 2010) (stock option amounts not required to be cost shared under § 482); Sun Microsystems v. Commissioner 69 T.C.M. 1884 (1995), (incentive stock option deduction qualifies for R&D credit); Appeal of Finnigan Corporation, CCH 401-797 (1990), (throwback rule is applied on a unitary basis; Appeal of Joyce overruled); and Petition of Intel Corporation, CCH 402-675 (1992), (technology transfers are not subject to California sales tax). Ronald received his BA degree, with honours, in 1977 from Calvin College in Grand Rapids, Michigan. He received his JD degree magna cum laude from the University of Michigan in 1980. He graduated as a member of the Order of the Coif and was an editor on the Michigan Law Review for two years.
|
George Soba |
|
|---|---|
|
Deloitte Tax LLP 191 Peachtree Street, Suite 2000 Atlanta, GA 30303-1749 US Tel: +1 404 220 1153 Fax: +1 202 661 1072 Email: gsoba@deloitte.com Website: www.deloitte.com George Soba, Deloitte US, is a principal of the transfer pricing practice. George has more than 19 years of experience with Deloitte, representing US and foreign multinational clients in transfer pricing controversies (audits, appeals, and competent authority proceedings between the US and foreign tax authorities), and in advance pricing agreements (APAs). He advises clients on the transfer pricing aspects of global tax rationalisation, planning, documentation, and audit defence preparation. George's industry experience includes aerospace, consumer goods companies (retailers, distributors, and manufacturers), e-commerce, financial transaction processing and electronic trading exchanges, healthcare (vertically integrated pharmaceutical companies, biotech, and medical instruments) and contract research organisations, heavy manufacturing (construction equipment, printing, automotive companies, and automotive parts manufacturers), real estate investment trusts (REITs), and technology (wafer manufacturers, chip design and manufacturing, internet-related optical routers, servers, and infrastructure). Before joining Deloitte, George worked as a field attorney for nine years in the IRS office of chief counsel, served as an adviser to IRS examination teams conducting transfer pricing audits, advised appeals officers on the resolution of transfer pricing matters, served as one of the first IRS field attorneys on APAs, was on the IRS litigation team for the Perkin-Elmer transfer pricing trial before the US Tax Court, and was seconded to the IRS APA programme where he served as a team leader during the establishment of the APA programme. He then worked for two years in the office of associate chief counsel (international), advising large-case examination teams on transfer pricing issues, evaluating transfer pricing controversies for potential litigation by the IRS, advising the US competent authority on transfer pricing, permanent establishment, and business profits issues, and as a team leader in the APA programme. George is a frequent speaker on transfer pricing topics and has authored and co-authored papers on transfer pricing audits, blocked income, APAs, and other topics. He holds an LLM in tax from New York University School of Law and is a member of the American and Washington, DC Bar associations.
|
Scott M Stewart |
|
|---|---|
|
Mayer Brown 71 S Wacker Drive Chicago, IL 60606 US Tel: +1 312 701 7821 Fax: +1 312 706 9203 Email: sstewart@mayerbrown.com Website: www.mayerbrown.com Since joining Mayer Brown in 1989, Scott M Stewart's practice has focused exclusively on tax disputes, including transfer pricing issues arising under Internal Revenue Code (IRC) 482 and intercompany debt matters arising under IRC 385. He represents taxpayers at all levels of federal tax controversy, including audits, administrative appeals before the Internal Revenue Service, mediation involving the appeals division of the IRS, and litigation before the US Tax Court. He has consistently been recognised by Chambers USA, which states that he "frequently leads on market-defining transfer pricing disputes, often with multi-billion dollar outcomes". Scott has extensive experience with deductibility of interest expense in related-party transactions, including debt-versus-equity characterisation and "sham transaction" and "economic substance" issues, dating back to his involvement in the landmark Nestlé Holdings case during the 1990s. Recently, Scott led the Mayer Brown team that filed 15 Tax Court petitions concerning debt-equity issues on behalf of Tyco International and related companies. The cases, which involved $3 billion in interest expense incurred from 1998 through 2000 and implicated an additional $6.5 billion in interest expense incurred from 2001 through to 2007, were settled for 5% of the amount in dispute. Scott is also experienced in all aspects of international transfer pricing, including cross-border movements of tangible and intangible property, advance pricing agreements, cost sharing arrangements, section 6662 documentation, section 936 Puerto Rico possessions corporations and issues related to the OECD's BEPS initiative. His transfer pricing litigation experience includes a number of the major cases of the past two decades, such as National Semiconductor, Seagate Technology, Nestlé Holdings and United Parcel Service. Scott holds a JD from Harvard Law School and an MBA from the Johnson Graduate School of Management at Cornell University.
|
David Swenson |
|
|---|---|
|
PwC 600 13th Street NW, Suite 1000 Washington, DC 20005 US Tel: +1 202 414 4650 Email: david.swenson@us.pwc.com Website: pwc.com/taxcontroversy David Swenson is the global leader of PwC's tax controversy and dispute resolution (TCDR) network and is resident in the Washington, DC office. The TCDR global network includes more than 650 tax controversy professionals, located in upwards of 80 countries across the globe, who assist multinational enterprises to prevent, manage, and resolve tax audits and disputes worldwide. Following a prominent legal career spanning 25 years, David has substantial experience in advising multinational enterprises (MNEs) on international tax matters, and assisting companies in their efforts to pursue a variety of measures aimed at proactively preventing, efficiently managing, and favourably resolving tax audits and disputes worldwide. Over the years, David has participated in more than 250 tax controversies involving audits and disputes between MNEs and the Internal Revenue Service (IRS), as well as dozens of other revenue authorities around the world. Many of these tax disputes were resolved at the audit level or through the proactive use of administrative appeals, mediation, arbitration, APAs, or the Competent Authority/MAP process. Other controversies were docketed in a US court of law, proceeded to trial, and resulted in important decisions for MNEs, including cases involving transfer pricing (Bausch & Lomb I), the foreign tax credit (Ampex), Competent Authority matters (Yamaha), the definition of 'manufacturing' for Subpart F purposes (Bausch & Lomb II), foreign currency (Carborundum), and intellectual property rights (Exide/Exxon). David also participated in several landmark tax cases before the US Supreme Court, including the Barclays Bank, Boeing, and Goodyear cases. David has been described as "one of the top five tax controversy experts in the US", and he received recognition as a "leading attorney" in US tax litigation by Chambers US, and as one of the world's top 25 transfer pricing specialists. In addition, David received a Meritorious Service Certificate from the Treasury Department and IRS, and has been an adjunct professor at Georgetown University Law Center, where he continuously taught courses for 25 years relating to international corporate income taxation. David received his MLT from Georgetown University Law School, and his JD, with honours, and BA, with distinction, from the University of Mississippi. David also has been admitted to practice before the US Tax Court, the US Court of Federal Claims, numerous US Federal Courts of Appeal, and the US Supreme Court.
|
Joe Tobin |
|
|---|---|
|
Deloitte Tax LLP 555 12th St. NW Suite 400 Washington, DC 20004 US Tel: +1 202 220 2081 Email: jtobin@deloitte.com Website: www.deloitte.com Joe Tobin, Deloitte US, is a senior manager in global transfer pricing at Deloitte's Washington national tax practice. Joe is very experienced in transfer pricing controversy and transfer pricing planning, especially in the area of cost sharing arrangements. Joe serves a wide variety of clients, specialising in intangible-centric industries such as the high-technology industry and the bio-pharmaceutical industry. Joe was the primary drafter of US Treasury's Regs. §1.482-7 (2011) and Regs. §1.482-7 (2013) on final cost sharing regulations. Joe was chosen by USCIB to comment on the OECD's 2015 discussion draft on cost contribution arrangements. Joe also helped the ABA and USCIB draft comments on Notice 2015-54 and the Section 367 temporary regulations and Section 482 temporary regulations released in September 2015. Joe was previously senior counsel at the Department of Treasury, within the Internal Revenue Service (IRS) office of associate chief counsel (international) (branch 6) (transfer pricing) in Washington DC, where he was the national office reviewer in charge of many of the high-profile transfer pricing litigation cases involving transfers of intangibles. Joe also advised IRS exam and field counsel on hundreds of contentious transfer pricing audits that went to IRS appeals. Joe has also commented on several versions of the draft IRS appeals settlement guidelines on cost sharing buy-ins, which have never been published. Joe was also known as the "go to" person for advanced pricing agreements (APAs) with complex technical issues involving cost sharing arrangements (CSAs), and he advised on several such APAs with CSAs. Joe has spoken at numerous conferences, webcasts, and training sessions on transfer pricing and cost sharing. He has been a member of the Georgetown Law Adjunct Faculty since 2013, where he co-teaches a class on transfer pricing. Joe received a master's degree in tax law from New York University in 2007, a JD from the University of Virginia in 2005, and a Bachelor of Arts in Philosophy and Political Science from Reed College in 1995. Joe is licensed to practice law in Nevada and New York.
|
Brian Toman |
|
|---|---|
|
Deloitte Tax LLP 555 Mission Street San Francisco, CA 94105-0920 US Tel: +1 415 783 6137 Fax: +1 866 855 0796 Email: btoman@deloitte.com Website: www.deloitte.com Brian Toman, Deloitte US, is a special adviser with Deloitte Tax's multistate tax controversy services practice, and a liaison to Deloitte Tax's Washington national tax-multistate practice as a California controversy and technical lead. Prior to joining Deloitte, Brian was a partner with Reed Smith, focused on state and local tax controversies, tax planning and transactional matters. Before entering private practice, he had held the position of chief counsel of the California Franchise Tax Board (FTB). The FTB's legal function is second in size and scope only to the legal function of the Internal Revenue Service. As chief counsel of the FTB, Brian had responsibility for the FTB's litigation cases, administrative protests, administrative appeals and settlement functions. Brian has extensive experience in California corporation income tax, personal income tax, sales and use tax and property tax matters. He is recognised nationally as a leading authority on the unitary concept and formula apportionment. Brian has been engaged as an expert witness in both California corporate and residency matters. He has functioned as the lead attorney, in both public service and private practice, in settling complex cases in California concerning corporate franchise/income tax and personal income tax, including disputes as to residency for high-net worth individuals. His licensing, education and professional memberships include:
|
Jack Trachtenberg |
|
|---|---|
|
Deloitte Tax LLP 30 Rockefeller Plaza New York, NY 10112-0015 US Tel: +1 212 436 4324 Fax: +1 855 901 5794 Email: jtrachtenberg@deloitte.com Website: www.deloitte.com Jack Trachtenberg, Deloitte US, is a principal in Deloitte's multistate tax controversy services team in New York and a liaison to the Washington national tax-multistate practice as a New York controversy and technical lead. Jack focuses on all aspects of state and local tax controversy matters for corporations and passthroughs, including income/franchise and sales and use tax, and has deep experience serving high-net worth individuals in personal income tax matters, including residency. Jack has extensive experience advising clients on New York State and New York City tax matters, having successfully litigated cases before the New York State Division of Tax Appeals, the New York State Tax Appeals Tribunal and the New York State Supreme Courts. Before joining Deloitte, Jack was a partner in the state tax practice at Reed Smith. In 2009, the Governor of New York appointed Jack to serve as the first deputy commissioner and taxpayer rights advocate at the New York State Department of Taxation and Finance. In this role, Jack created and implemented the state's office of the taxpayer rights advocate, which intervenes on behalf of taxpayers facing tax disputes for which the normal resolution process has proved unsatisfactory. His licensing, education and professional memberships include:
|
Jeffrey Wax |
|
|---|---|
|
Deloitte Tax LLP 555 West 5th Street Los Angeles, CA, 90013 US Tel: +1 213 593 4516 Fax: +1 213 694 5435 Email: jwax@deloitte.com Website: www.deloitte.com Jeffrey Wax, Deloitte US, has more than 35 years of experience in the federal income tax controversy arena. After seven years of private legal practice working with former IRS and Treasury Department senior attorneys, Jeff joined the tax department of a Fortune 20 company where he headed the tax controversy group. During his in-house tenure, Jeff led the successful effort to bring the company's federal income tax audits and appeals current, including handling four complete exam cycles, three complete appeals cycles, and three Tax Court cases, including one case with 259 docketed issues and a deficiency in excess of $1 billion. Jeff is the partner in charge of Deloitte's tax controversy services practice for the west region of the US, providing comprehensive representation during all phases of exams and appeals. He regularly contributes to internal and external trainings on all aspects of IRS practice and procedure. Jeff graduated from UCLA with a bachelor's degree in political science and geography. He received his JD from McGeorge School of Law and is admitted to practice before the US Tax Court. Jeff is a member of the California and Nebraska State Bar Associations.
|
Gary Wilcox |
|
|---|---|
|
Mayer Brown 1999 K Street, NW Washington, DC 20006-1101 US Tel: +1 202 263 3399 Email: gwilcox@mayerbrown.com Website: www.mayerbrown.com Gary Wilcox is a partner in Mayer Brown's Washington DC office and a member of the tax controversy and transfer pricing practices. Gary recently joined Mayer Brown after serving as a co-leader of PwC's US tax controversy practice. Previously, Gary led the tax practice at another international law firm. Prior to that, he served as the deputy chief counsel of the US Internal Revenue Service (IRS), where he was in charge of approximately 700 attorneys in the office of chief counsel and had primary responsibility within the IRS for developing its positions on technical tax issues and the issuance of regulations and rulings. Gary represents multinational corporations in the audit and appeals phases of an IRS dispute as well as in litigation. He has particular experience with controversies arising from complex transactions, typically in a cross-border context, such as leveraged distributions and other repatriations, intercompany debt, worthless stock deductions, and cost sharing arrangements. He has litigated significant cases in the US Tax Court involving intercompany debt (ScottishPower) and consolidated return (Duquesne Light) issues. Gary has many years of experience advising clients on structuring mergers, acquisitions and internal reorganisations. He is a frequent lecturer on corporate tax issues, and is an author of the BNA Tax Management Portfolio entitled "Corporate Acquisitions – (A), (B), and (C) Reorganizations". Today, he uses this controversy and planning experience to advise clients at the transaction planning stage on how best to prepare for a potential future IRS audit. His advice is aimed at having an audit ready defence file, addressing the "soft doctrines" such as substance-over-form and step transaction, and identifying privileged documents. Gary has been repeatedly recognised by the International Who's Who of Corporate Tax Lawyers and International Tax Review's Tax Controversy Leaders guide. Gary is a council director of the American Bar Association's tax section and a fellow of the American College of Tax Counsel.
|
Joel V Williamson |
|
|---|---|
|
Mayer Brown 71 S Wacker Drive Chicago, IL 60606 US Tel: +1 312 701 7229 Fax: +1 312 706 9204 Email: jwilliamson@mayerbrown.com Website: www.mayerbrown.com Joel V Williamson is widely acknowledged as one of the nation's leading tax attorneys and litigators. He has litigated more than 60 tax cases. His experience includes the unrivalled trial of six major IRC § 482 transfer pricing cases: Eli Lilly, GD Searle, Westreco (Nestlé), Seagate Technology, National Semiconductor, United Parcel Service, and Eaton. Presently, Joel is serving as trial counsel in the Guidant LLC case involving IRC § 482 and 367 issues. Joel has also litigated numerous cases involving economic substance, including the United Parcel Service case just noted, as well as the Flextronics, ConEd and Tribune cases. In the international tax area, Joel has litigated subpart F, constructive triangular dividend and R&D moratorium issues in Gulf Oil, The Limited, and Boeing, and Brazilian and other foreign tax credits for banks, Bankers Trust and Riggs Bank, as well as foreign versus domestic-source income IRC § 863(b) questions in the Intel case. In addition, Joel has litigated IRC § 338 corporate acquisition related issues, like debt versus equity involving Nestlé's acquisition of Carnation. Joel served as trial counsel in the mega Tyco debt versus equity cases. He is also presently serving as trial counsel in the recently filed Hyatt tax accounting and EOG alternative minimum tax cases. Joel has litigated significant procedural questions, including the proper role of IRS trial counsel in the audit examination process, Westreco (Nestlé). He is also experienced in summons enforcement actions for both foreign and domestic records. Joel is proud to have been recognised by Chambers USA as a leading lawyer in each of the years from 2003 to 2016. In addition, Legal 500 recognised him as a leading lawyer in 2008, 2011, 2012, 2013, 2014, 2015, 2016, and 2017, describing Joel as a "highly skilled trial attorney possessing great judgment". Joel was also named in 2017 in the Legal 500 Hall of Fame. Joel served as an officer in the US Army from 1970 through to 1972, assigned to the Offices of the Staff Judge Advocate, 12th Support Brigade, Ft. Bragg, NC, and subsequently to Saigon Support Command, the Republic of South Vietnam. After his return from Vietnam in 1972, Joel joined the chief counsel's office, US Department of Treasury. In 1978, he was appointed as one of 20 special trial attorneys located throughout the US. Joel joined Mayer Brown in 1986 as a partner.
|
Robert H Albaral
Baker McKenzie
Michael J Alter
Fried Frank
Brad Anwyll
Steptoe & Johnson
Jenny A Austin
Morgan, Lewis & Bockius
Summer Austin
Baker McKenzie
Peter H Blessing
KPMG
William Bonano
Pillsbury Winthrop Shaw Pittman
Thomas Borders
McDermott Will & Emery
Kim Boylan
White & Case
Steven S Brown
Martin, Brown, Sullivan, Roadman & Hartnett
Thomas Callahan
Thompson Hine
Nathaniel Carden
Skadden, Arps, Slate, Meagher & Flom
George M Clarke
Baker McKenzie
Jerold Cohen
Eversheds Sutherland
Erin Collins
KPMG
Andrew Crousore
Baker McKenzie
Michael Danilack
PwC
Michael Desmond
Law Offices of Michael J Desmond
Steven R Dixon
Miller & Chevalier
Mike Dolan
KPMG
Rod Donnelly
Morgan, Lewis & Bockius
Carol A Dunahoo
Baker McKenzie
Michael Durney
Law Offices of Michael C Durney
Elizabeth Erickson
McDermott Will & Emery
Jeffry J Erney
Dentons
David Ernick
PwC
G Michelle Ferreira
Greenberg Traurig
Miriam Fisher
Latham & Watkins
Sean Foley
KPMG
Scott H Frewing
Baker McKenzie
Stephen Gardner
Cooley
George Gerachis
Vinson & Elkins
Stephen F Gertzman
Miller & Chevalier
Fred Goldberg Jr
Skadden, Arps, Slate, Meagher & Flom
Charles W Hall
Norton Rose Fulbright
George A Hani
Miller & Chevalier
Rob Hanson
EY
Lawrence M Hill
Winston & Strawn
Charles E Hodges
Jones Day
Alan I Horowitz
Miller & Chevalier
Charles P Hurley
Norton Rose Fulbright
Kevin M Johnson
Baker Hostetler
Thomas Johnston
Shearman & Sterling
Maria O'Toole Jones
Miller & Chevalier
Richard Jones
Sullivan & Worcester
Roger Jones
McDermott Will & Emery
Joseph B Judkins
Baker McKenzie
Philip Karter
Chamberlain, Hrdlicka, White, Williams & Aughtry
Kevin L Kenworthy
Miller & Chevalier
Donald L Korb
Sullivan & Cromwell
Stephen P Kranz
McDermott Will & Emery
Frank Lavadera
KPMG
Gregg Lemein
Baker McKenzie
Patricia Lewis
Caplin & Drysdale
Jerome B Libin
Eversheds Sutherland
Thomas V Linguanti
Morgan Lewis & Bockius
Dante Lucas
KPMG
Raj Madan
Skadden, Arps, Slate, Meagher & Flom
John B Magee
Morgan, Lewis & Bockius
James N Mastracchio
Dentons
Jane May
McDermott Will & Emery
Wade McKnight
Deloitte Tax LLP
Victor H Miesel
Cherry Bekaert
Robert C Morris
Norton Rose Fulbright
Christopher P Murphy
Skadden, Arps, Slate, Meagher & Flom
Joseph A Myszka
Baker McKenzie
David Nagle
Sullivan & Worcester
Deborah Nolan
EY
David G Noren
McDermott Will & Emery
Kathryn O'Brien
PwC
Mark A Oates
Baker McKenzie
Joshua D Odintz
Baker McKenzie
Emily A Parker
Thompson & Knight
Jean Pawlow
McDermott Will & Emery
Martin R Press
Gunster
Jose Manuel Ramirez
KPMG
Patricia Anne Rexford
Baker McKenzie
Mark T Roche
Baker McKenzie
Colleen Feeney Romero
Baker McKenzie
Daniel A Rosen
Baker McKenzie
David Rosenbloom
Caplin & Drysdale
Susan E Ryba
Baker McKenzie
Leslie Samuels
Cleary Gottlieb Steen & Hamilton
Paul E Schick
Baker McKenzie
Leslie Schneider
Ivins, Phillips & Barker
William Sharp
Sharp Partners
Sanford Stark
Morgan, Lewis & Bockius
Douglas Stransky
Sullivan & Worcester
Patricia J Sweeney
Miller & Chevalier
Phillip J Taylor
Baker McKenzie
Jasper G Taylor III
Norton Rose Fulbright
Mary Thomas
Weaver
Brian Trauman
KPMG
Josh Ungerman
Meadows Collier
Juan F Vasquez, Jr
Chamberlain, Hrdlicka, White, Williams & Aughtry
Mario J Verdolini
Davis Polk & Wardwell
Robert S Walton
Baker McKenzie
James I Warren
Miller & Chevalier
Duane Webber
Baker McKenzie
Jay Weill
Sideman & Bancroft
Todd Welty
McDermott Will & Emery
Daniel J White
Baker McKenzie
B John Williams Jr
Skadden, Arps, Slate, Meagher & Flom
Robert L Willmore
Crowell & Moring
Diana Wollman
Cleary Gottlieb Steen & Hamilton
Steven Wrappe
KPMG
Russell Young
Baker McKenzie
Shanwu Yuan
Baker McKenzie
Alexander Zakupowsky, Jr
Miller & Chevalier
Thomas E Zehnle
Sole practitioner
Thomas Zollo
KPMG
