Expertise for guiding multinational business through U.S. taxation of inbound and outbound transactions, international business expansion, and transfer pricing. The insights and guidance of the world's leading international tax authorities plus the research and productivity tools you need - all on one platform. Written by leading practitioners in the field, the Foreign Income Portfolios provide everything necessary to research, plan, and implement strategies to streamline compliance while minimizing clients’ exposure to taxes.
Expert Analysis
Written by leading tax authorities, nearly 100 Portfolios provide practical analysis in virtually any scenario involving U.S. taxation of cross-border transactions transactions — from foreign tax credits and branch profits tax to foreign partners and partnerships and Subpart F Corporations. In addition to topic-specific guidance, you get specific technical information necessary to manage business expansion and operations in 40 countries. Portfolios are organized as follows::
- U.S. Taxation of International Transactions: “Outbound” (U.S. Business Investing Overseas); “Inbound” (Foreign Business Investing in the U.S.); Rules That Apply to Both Types of Transactions
- Transfer Pricing: U.S. Transfer Pricing Rules and Economic Principles Transfer Pricing Rules of 14 Major Foreign Countries
- Business Operations Abroad: 40 country-specific Portfolios covering the basic business and tax requirements involved in operating a business in a particular country, including Puerto Rico
- U.S. Tax Overview: This introduces the researcher to the U.S. federal tax system, including procedural aspects. The major focus is on income taxation, including the rules covering individuals, corporations, partnerships, estates, and trusts, plus alternative minimum tax.
Practice Tools
- Federal Tax Calendar
- Interactive Federal tax forms
- Tables, charts, and lists
- Working Papers: Sample elections, Sample filled-in forms
Source Documents
- Full text of the IRC
- Final, Temporary, and Proposed Regulations
- IRS Documents - including Revenue Rulings, Revenue Procedures, Notices and Announcements, PLRs and TAMs, CCAs, FSAs, and SCAs
- IRS Publications
- Treasury regulations and decision preambles
- Full Text of Federal Cases from all federal courts from 1913 to date; Tax court rules; Court of Federal Claims Rules
- Selected full text of legislation with committee reports
- Circular 230
- Coordinated Issue Papers/Industry Specialization Papers — 2000-Present
- Tax Treaties — full text of treaties between the US and foreign countries.
News & Commentary
- Daily Tax Highlights — Daily highlights from each issue of the Daily Tax Report, covering key legislative, regulatory, and legal tax developments.
- Tax and Accounting Memorandum — An authoritative outlook, including commentary from BNA’s Advisory Boards, on new issues, developments, trends, and strategies.
- Weekly Report — Timely notification of tax-related legislative, judicial and regulatory developments.
- Insights & Commentary — Commentary by leading authorities on a variety of current and emerging tax issues.
- International Journal — Expert monthly commentary on U.S. inbound and outbound tax developments (including major regulatory projects), cross-border perspective from Canada and Mexico, and status of U.S. tax treaties.
- Transfer Pricing Report (optional) — Practical service providing news and analysis on U.S. and other governments’ tax policies regarding intercompany transfer pricing and helps companies structure their operations to avoid double taxation.
NOTE: This product is a component of the BNA Tax and Accounting Center. Your 15-day Web trial to the Center includes full access, allowing you to explore all areas of tax and accounting analysis, primary sources, practice tools and more. You can find more information on the Library here.
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Mario J. Andrade PerillaMario J. Andrade P., Universidad Autonoma de Mexico (LL.M. in Corporate Law; M.Sc. in Public Finance); Pontificia Universidad Javeriana (J.D.); Professor of Law, Pontificia Universidad Javeriana (Bogota); Adjunct Professor, Universidad de Nuestra Senora del Rosario (Bogota); member, Colombia Tax Law Institute; member, American Bar Association; Licensed to practice law in the Republic of Colombia; President of International Fiscal Association (IFA) — Colombian Chapter.
Business Operations Colombia (Portfolio 956) Abel Adolfo Atchabahian, Dr.Adolfo Atchabahian, Special Consultant to Tax Management, Doctor in Economic Science, University of Buenos Aires; former Judge of the National Tax Court in Argentina (1960-1967) and Professor of Public Finance and Tax Law at the University of Buenos Aires (1957-1967 and 1980-1983); tax expert and Director at the Office of Public Finance of the Organization of American States (1967-1976); former consultant at the U.N. Center on Transnational Corporations; consultant of the Inter-American Development Bank and the International Monetary Fund; member of the International Fiscal Association and former member of its Permanent Scientific Committee; member and former president of the Argentinean Association of Fiscal Studies; author of several books and many articles published in Argentina and abroad relating to economic, public accounting and tax matters; former chief editor of Derecho Fiscal and Derecho Tributario (1981-1998), monthly tax reviews, and Impuestos Nacionales, a loose-leaf publication updated fortnightly (1984-1998); Director of Periódico Económico Tributario, a fortnightly publication, published in Buenos Aires under the auspices of Editorial La Ley-Thomson (2003- ); and Professor of Tax Law in graduate courses for lawyers and certified public accountants in different public and private universities throughout Argentina.
A Strategic Approach to SEC Investigations (Portfolio 5504)Accounting Ethics: Sources and General Applications (Portfolio 5508)Accounting by Partnerships (Portfolio 5209)Accounting Policy & Practice SeriesBusiness Operations Argentina (Portfolio 950) Ernest F. Aud, Jr. Esq.Ernest F. Aud, Jr., B.B.A., University of Notre Dame (1965); J.D., Indiana University (1968); member, Indiana Bar; Certified Public Accountant (Illinois and Indiana); frequent lecturer and author of articles on international taxation and intercompany pricing, and member, World Trade Institute Tax Advisory Panel.
The Possessions Tax Credit Under Section 936 (Portfolio 933) Reuven S. Avi-YonahReuven S. Avi-Yonah (B.A., Hebrew University, 1983; Ph.D., Harvard University, 1986; J.D., Harvard Law School, 1989) is Assistant Professor of Law, Harvard Law School, where he teaches domestic and international taxation. Mr. Avi–Yonah is a member of the New York and Massachusetts bars and co–chairs the tax policy committee of the New York State Bar Association Tax Section. He participated in preparing the Tax Section's reports on proposed legislation on amortization of intangibles and has published several articles and comments on the leading Supreme Court case in this area, Newark Morning Ledger Co. v. United States, 113 S. Ct. 1670 (1993).
The Attribution Rules (Portfolio 554)Collapsible Corporations (Portfolio 793)Transfer Pricing: Judicial Strategy and Outcomes (Portfolio 888)
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Gregory L. Barton, Esq.Gregory L. Barton, University of Notre Dame, B.S. (1980); University of Southern California, M.S. (1981); University of Chicago, J.D. (1985); former attorney–advisor, Office of Management and Budget; law clerk, U.S. Court of Appeals for the Seventh Circuit, Judge Richard A. Posner (1985–86); former lecturer, World Trade Institute and University of Southern California Tax Institute; former panelist, Northwestern University Transfer Pricing Conference; member, American Bar Association, Section of Taxation, Committee on Foreign Activities of U.S. Taxpayers; admitted to practice, Illinois, U.S. District Court for the Northern District of Illinois, U.S. Court of Federal Claims, and U.S. Tax Court.
Transfer Pricing: Records and Information (Portfolio 891) David M. Benson, Esq.David M. Benson, B.B.A., George Washington University (1971); J.D., Brooklyn Law School (1974); member, District of Columbia Bar; former Chair, AICPA International Tax Committee; formerly Technical Advisor to Associate Chief Counsel (Technical), Internal Revenue Service, Washington, D.C.; regular contributor to Tax Management International Journal.
The Possessions Tax Credit Under Section 936 (Portfolio 933) Renato Berger, Esq.Renato Berger, consultant, TozziniFreire, Teixeira e Silva Advogados, São Paulo, Brazil; University of São Paulo School of Law (LL.B., 1995); Georgetown University Law Center (LL.M., 1997).
Business Operations Brazil (Portfolio 954) Thomas St. G. Bissell, Esq.Thomas St.G. Bissell, B.A., Harvard College (1964); LL.B., Columbia Law School (1967); LL.M. in Taxation, New York University (1971); Member, New York Bar; Certified Public Accountant, State of New Jersey; Member, Tax Management International Advisory Board, American Bar Association, American Institute of Certified Public Accountants, International Fiscal Association, Canadian Tax Foundation; former Attorney-Advisor, Office of International Tax Counsel, US Treasury Department, Washington, D.C.; retired tax partner, Coopers & Lybrand LLP; author of numerous articles in professional tax publications.
U.S. Income Taxation of Nonresident Alien Individuals (Portfolio 907)International Aspects of U.S. Withholding on Wages and Service Fees (Portfolio 916)International Aspects of U.S. Social Security and Unemployment Taxes (Portfolio 917)Aliens Who Invest the United States Through a Low-Tax Jurisdiction (Portfolio 944)Controlled Foreign Corporations — Section 956 (Portfolio 929) Marc P. Blum, Esq.Marc P. Blum, A.B., Yale 1964; L.L.B., Columbia Law, 1967; Ph. D., Columbia Business 1969; member Maryland Bar, ABA; CPA; Of Counsel, Gordon, Feinblatt, Rothman, Hoffberger & Hollander, LLC, Baltimore, Maryland; CEO, World Total Return Fund, LLLP; Committee/Board member, Davis Funds, Clinical Trials & Surveys Corp., Rodney Trust Company, Legg Mason Investment Counsel & Trust Co., The Associated: Jewish Community Federation of Baltimore, McDonogh School, Kennedy Krieger Institute, Latin American Studies Association, College of Notre Dame of Maryland, Commonfund Private Capital, LifeBridge Health, Baltimore Courthouse and Law Museum Foundation, Inc., Maryland Research Institute; several private foundations and private capital funds; author of various articles on tax issues and estate planning.
Reporting Requirements Under the Code for International Transactions (Portfolio 947) Slawomir BorucSlawomir Boruc graduated from the Department of Law and Administration at the University of Warsaw in 1992. He has been working for Baker & McKenzie since July 1992, specializing in resolving tax law problems. He has advised many firms, including firms in the IT, chemicals, and printing and textile industries, and one of the largest telecommunications companies in the world. He has represented clients before tax authorities and in tax cases before the Supreme Administrative Court. He is a member of the Warsaw District Chamber of Legal Advisors and of the National Chamber of Tax Advisors.
According to Practical Law Company (PLC 2005, 2006 and 2007), Slawomir Boruc is a recommended Tax Advisor. Chambers Global 2006 and 2007 refers to him as a co-head of the best tax group in Poland. Additionally, Legal 500 has listed him individually each year since 2003. According to European Legal Experts 2007, Slawomir Boruc is a leading tax advisor in Poland. In Practical Law Company 2007/2008, he was recognized as the best lawyer in tax law in Poland. He was also awarded by International Financial Law Review (IFLR1000) 2007/8 in tax advisory.
Business Operations Poland (Portfolio 979) Luis F. Briones, Esq.Luis Briones Fernández, born Madrid, Spain, 1954; admitted to Madrid Bar; education: Deusto University, Bilbao, Spain (Law Degree, 1976); ICADE, Madrid, Spain (MBA, 1978); Harvard University, USA (LL.M. and International Tax Program, 1986).
Business Operations Spain (Portfolio 984) Charles M. Bruce, Esq.Charles M. Bruce, B.A., Washington & Lee University; J.D., George Washington University Law Center; member, The District of Columbia Bar, American Bar Association (Section of Taxation, Committee on Foreign Activities of U.S. Taxpayers), International Fiscal Association, International Bar Association (Section of Business Law, Taxation Committee); formerly, Counsel, Senate Finance Committee, Attorney–Advisor, United States Tax Court, Adjunct Professor, Georgetown University Law Center, and Visiting Professor, Institut für Auslandishes und Internationales Finanz und Steuerwesen.
Foreign Sales Corporations (Portfolio 934) Frederick R. Burke, Esq.Frederick R. Burke is a managing partner of Baker & McKenzie LLP's Vietnam offices. He obtained his Bachelor of Arts Degree with Honors from Stanford University, his Juris Doctor Degree from Columbia University School of Law and his Masters Degree of International and Public Affairs from Columbia University School of International Affairs. He was admitted to practice in New York (1987) and Washington, D.C. (1988) and registered as a foreign lawyer in Vietnam since 1996. Fred Burke has almost twenty years' experience in the planning, negotiation and operation of foreign investment projects as well as in the related issues of trade, securities, finance, construction, taxation, regulatory compliance, labor, intellectual property and technology transfer. He is currently a Vice Chairman of the Executive Committee of Hong Kong Business Association in Vietnam, Co-Chairman of the Executive Committee of the Vietnam Business Forum and Senior Advisor, and Chairman of the Legal Committee of the American Chamber of Commerce in Vietnam. Languages: English, Mandarin, Vietnamese, French, German and Italian.
Business Operations Vietnam (Portfolio 994) Herbert BuzanichHerbert Buzanich, University of Vienna (Master of Laws 1998); Doctor of Jurisprudence (2001); LL.M. International Tax (NYU 2004); member, Austrian Bar; member, New York State Bar; member, International Fiscal Association.
Business Operations Austria (Portfolio 952)
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Massimo G. Calderan, Esq.Massimo G. Calderan, University of Zürich (lic. iur., 1986); admitted to bar (Zürich 1991, St. Gallen 1995 and Zug 1995); member, Swiss, Zürich and International Bar Association; Association Internationale des Jeunes Avocats (“AIJA”), Swiss-Italian Chamber of Commerce (Zürich), Swiss-Spanish Chamber of Commerce (Zürich).
Business Operations Switzerland (Portfolio 986) German CamposGermán Campos, Universidad de Santiago de Chile (Certified Public Accountant, 1989, and Commercial Engineer, 1992); Professor, Universidad de Chile, Pontificia, Universidad Católica de Chile, and Universidad de Santiago de Chile; Member, Instituto de Derecho Tributario and International Fiscal Association.
Business Operations Chile (Portfolio 997) John L. Carr, Jr. Esq.John L. Carr, Jr., B.S., Auburn University (1969); J.D., University of Georgia (1978); Editor, University of Georgia Law Review (1977-78); member, International Fiscal Association.
Indirect Foreign Tax Credits (Portfolio 902) Karen E. CederothKaren E. Cederoth, B.S., Eastern Illinois University; M.A., taxation, DePaul University; tax partner, International Tax Service Line, Deloitte Tax LLP, Chicago, Illinois; formerly with Arthur Andersen, Chicago; formerly with Container Corporation of America, responsible for international compliance; Instructor, DePaul University, Masters in Tax Program.
The Allocation and Apportionment of Deductions (Portfolio 906) Clark J. Chandler, Ph. D.Clark J. Chandler, Dickinson College, B.A. (1974); University of Michigan, M.A. and Ph.D., Economics (1978). Dr. Chandler is a principal with KPMG LLP's Washington national Tax/Economic Consulting Services practice. He has testified extensively and worked for both tax authorities and multinational corporations in the area of international transfer pricing.
Transfer Pricing: Economic, Managerial, and Accounting Principles (Portfolio 889) C. V. ChenC. V. Chen, Managing Partner, admitted 1975, Member of Taipei and Kaohsiung Bar Associations, R.O.C.; Education: S.J.D., Harvard Law School (1972); LL.M., Harvard & University of British Columbia; LL.B., National Taiwan University. Experience: Managing Partner and CEO, Lee and Li Attorneys-at-Law, Taipei, Taiwan; Member of the Committee of Taxation Policy and Regulation Consultation, Ministry of Finance, R.O.C.; Adjunct Professor of Law, National Chengchi University & Soochow University Graduate School of Law (1972–present), Taiwan; Lecture Professor of Law at the Management Schools of Peking University and Tsinghua University, China; President, (April 2000–present), The Red Cross Society of the Republic of China; Chairman, Taipei European School Foundation, Taiwan, Republic of China (1994–present); Director (December 1993–present), Vice Chairman (February 1992–December 1993), first-term Vice Chairman & Secretary General (November 1990–February 1992), Straits Exchange Foundation; Director, Lee and Li Foundation; President, The Chinese Society of International Law (January 2004–present); Board of Director, Yuan Ze University (Taiwan) (1990–present); Honorary President, Harvard Club of Republic of China on Taiwan (1989–present); Numerous articles on transnational legal problems.
Business Operations in the Republic of China (Taiwan) (Portfolio 958) Bernard ChesnaisBernard Chesnais obtained Master degrees in general law studies (University of Bretagne – Rennes, 1969), sociology (University of Bretagne – Rennes, 1970), and tax law (Ecole Nationale des Impôts), as well as a Diplôme d'Etudes Comptables Supérieures (Ecole Nationale des Impôts). He is a former tax inspector at the Direction des Vérifications Nationales et Internationales; partner, Salans.
Business Operations France (Portfolio 961) Robert T. Cole, Esq.Robert T. Cole, B.S., Wharton School of Finance, University of Pennsylvania (1953); LL.B., Harvard Law School (1956); Academic Postgraduate Diploma in Law, London School of Economics (1959); senior counsel in the Washington, D.C. office of Alston & Bird LLP; former member of Cole Corette & Abrutyn; former International Tax Counsel of the U.S. Treasury Department; editor and principal author of Practical Guide to U.S. Transfer Pricing.
Income Tax Treaties — Administrative and Competent Authority Aspects (Portfolio 940) Peter J. Connors, Esq.Peter J. Connors, B.A., Catholic University; J.D., University of Richmond; LL.M (in Taxation), New York University School of Law; Senior Tax Accountant, Arthur Andersen & Co.; Attorney, Tax Department, Bondy & Schloss; Tax Manager, J.C. Penney & Co.; Senior Manager, KPMG; Principal and Director of International Capital Markets Tax Services, Ernst & Young LLP; Tax Partner, Baker & McKenzie (1995 to 2001); CPA (New York).
The Mark-To-Market Rules of Section 475 (Portfolio 543)The Branch-Related Taxes of Section 884 (Portfolio 909) Joseph J. Czajkowski, Esq.Joseph J. Czajkowski, Georgetown University (B.A., 1971); studied in the Faculty of Law, University of Fribourg (Switzerland); Boston College Law School (J.D., 1975); Georgetown University Law Center (LL.M. Taxation, 1979); admitted to bar, District of Columbia (1976), Texas (1992); member, American Bar Association Section on Taxation, International Fiscal Association, and Tax Chapter Board of the Swiss-American Chamber of Commerce (Zürich).
Business Operations Switzerland (Portfolio 986)
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Roland S. Dahlman, Esq.Roland S. Dahlman, LL.B. 1970 and LL.D. 2006 (Stockholm), LL.M. 1974 (Harvard University); Advokat. Member of the Swedish Bar and of Dahlman Advokatbyrå, Stockholm, Sweden.
Business Operations Sweden (Portfolio 985) Bruce N. Davis, Esq.Bruce N. Davis, B.A., University of Virginia (high honors 1980, Phi Beta Kappa); J.D., Harvard Law School (1983); LL.M. (in taxation), Southern Methodist University (1987); Former Chairman, Subcommittee on §§338, 367 and 1491, Committee on Foreign Activities of U.S. Taxpayers, American Bar Association; Principal Special Assistant to the Associate Chief Counsel (International), Internal Revenue Service (1988-1991); member of board of advisors of various international tax publications, and frequent speaker and writer on international tax issues.
Outbound Transfers Under Section 367a (Portfolio 919)Other Transfers Under Section 367 (Portfolio 920) Mario A. de CastroMario A. de Castro, University of Miami School of Law (LL.M. in Taxation); Temple University of Law (J.D. 1994); Tulane University (B.A. 1990); member, American Bar Association; member, Florida Bar; Licensed to practice law in the State of Florida, U.S. Court of Appeals for the Eleventh Circuit, United States Tax Court; United States District Court for Southern District of Florida, and in the Republic of Colombia (pursuant to ICFES Resolution issued 1999).
Business Operations Colombia (Portfolio 956) Jocelyn Delsouiller, Esq.Jocelyne Delsouiller, graduated 1972 Geneva, Swtitzerland, admitted to the Geneva Bar 1974, legal counsel in Paris, 1979. admitted to the Paris Bar 1992. Corporate partner Campbell, Philippart, Laigo & Associes, Paris, France.
Business Operations France (Portfolio 961) Brett R. Dick, Esq.Brett R. Dick, B.A., University of Michigan (1967); J.D., University of Michigan Law School (1970); member, American Bar Association, Section of Taxation, Committee on U.S. Activities of Foreigners and Tax Treaties, Subcommittee on Source of Income; member, State Bar of California, Foreign Taxation Subcommittee; member, San Francisco Foreign Tax Club; member, San Francisco Tax Club; speaker at various conferences on international taxation.
U.S. Income Taxation of Foreign Governments, International Organizations and Their Employees (Portfolio 913) William G. DodgeWilliam G. Dodge, University of Georgia, Master of Accountancy (Tax) (1979); Walsh College, B.A. (1976); Director, Global Transfer Pricing Team; Co–Director, U.S. Transfer Pricing Team, Deloitte & Touche LLP, Washington, D.C. Formerly Partner–in–Charge, U.S. Corporate Tax Group, Deloitte & Touche, London, England. Member, Tax Management Advisory Board (Transfer Pricing). Mr. Dodge is regular speaker at seminars and has worked in New York, London, and Tokyo where he served many of Deloitte & Touche's largest U.S. and non–U.S. clients.
Transfer Pricing: Records and Information (Portfolio 891) D. Kevin Dolan, Esq.D. Kevin Dolan, B.A., University of Virginia; J.D., University of Michigan; Senior Vice President for Tax Policy, Merrill Lynch & Co.; former partner, Weil, Gotshal & Manges LLP; former Associate Chief Counsel (Technical and International), Internal Revenue Service; former partner, Arthur Young and Co., Washington, D.C.; former Attorney-Advisor, Office of International Tax Counsel, U.S. Treasury Department.
The Creditability of Foreign Taxes — General Issues (Portfolio 901) Carolyn M. DuPuy, Esq.Carolyn M. DuPuy, B.A., Mount Holyoke College; J.D. and M.L.T., Georgetown University Law Center; partner, Weil, Gotshal & Manges LLP; former Senior Technical Reviewer, Office of the Associate Chief Counsel (International), Internal Revenue Service.
The Creditability of Foreign Taxes — General Issues (Portfolio 901)
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Howard E. Engle, CPAHoward S. Engle, B.S., University of Illinois; M.S., taxation, DePaul University; partner, Deloitte Tax LLP, Chicago, Illinois; Visiting Lecturer, Graduate Tax Program, University of Illinois; frequent speaker on international tax issues; editor, International Tax Developments column, Journal of Corporate Taxation; author, numerous articles on international tax.
The Allocation and Apportionment of Deductions (Portfolio 906) Joseph M. Erwin, Esq.Joseph M. Erwin, University of Arkansas, B.A. (with honors), 1976; Southern Methodist University School of Law, J.D., 1979, LL.M. (Taxation), 1980. Member of the bars of Arkansas, Texas, U.S. Virgin Islands, U.S. Tax Court, U.S. Court of International Trade, U.S. Court of Appeals for the Third Circuit, U.S. Court of Appeals for the Eighth Circuit. Private law practice, Little Rock, Arkansas, 1980-1991. Assistant Attorney General (Tax), U.S. Virgin Islands Department of Justice, 1991-1994. Private law practice, St. Thomas, 1994-1996. Tax Manager, CSC Continuum Inc., 1996-1997. Senior Manager, International Corporate Services, KPMG LLP, Austin, Texas, 1997-1998, Dallas, Texas, 1998-2000 and 2002-2003; Senior Manager, KPMG Deutsche Treuhand-Gesellschaft AG, U.S. Corporate Tax Group, Frankfurt am Main, Germany, 2000-2002.
Business Operations in the Territories and Possessions of the United States (except Puerto Rico) (Portfolio 995)
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Pascal Faes, Esq.Pascal Faes, JD, University of Ghent (1984); Special Degree in Economics, University of Brussels (V.U.B.) (1987); Master in Tax Law, University of Brussels (U.L.B.) (1991).
Business Operations Belgium (Portfolio 953) Jayson L. FernandezJayson L. Fernandez, A.B. (1991) and J.D. (1995), second honors, Ateneo de Manila University; Senior Associate, specializing in taxation, Romulo, Mabanta, Buenaventura, Sayoc & de los Angeles and member, Tax Management Association of the Philippines.
Business Operations the Philippines (Portfolio 978) Jose Luis de Salles Freire, Esq.José Luis de Salles Freire, partner, TozziniFreire, Teixeira e Silva Advogados, São Paulo, Brazil; University of São Paulo School of Law (LL.B., 1971); Southwestern Legal Foundation (Academy of American and International Law, 1975) and New York University School of Law (M.C.J., 1976). Member of the Advisory Board of the International and Comparative Law Center of the Southwestern Legal Foundation.
Business Operations Brazil (Portfolio 954)
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James M. Gannon, CPAJames Gannon, B.S., University of Illinois; B.A., accountancy, M.A., public accounting-tax, University of Texas at Austin; tax partner, Washington International Tax Group, Deloitte Tax LLP, 2002–present; partner, Arthur Andersen, 1998-2002, staff, Arthur Andersen, 1987-1998; member, AICPA and Illinois Society of CPAs.
The Allocation and Apportionment of Deductions (Portfolio 906) Marc D. Ganz, J. D. LL. M.Marc D. Ganz, B.A., University of Wisconsin - Madison (1991); J.D., A.C. in International Affairs, Washington University (1994); LL.M. in Taxation, New York University (1995); formerly Attorney-Advisor to the Honorable William M. Fay, U.S. Tax Court, Washington, D.C.; Member of the New York Bar; Member of the Telecommunications Tax Forum.
U.S. International Taxation of Telecoms (Portfolio 946) Brian S. Gleicher, Esq.Brian S. Gleicher, B.S., University of Florida, Fisher School of Accounting (with high honors, 1992); J.D., Georgetown University Law Center (cum laude, 1995). Lead Articles Editor, Tax Lawyer (1995); Chairman of the Federal Bar Association Section of Taxation (2002-2003); Chairman of the Federal Bar Association Section of Taxation's 26th Annual Tax Law Conference (2001); Editor-in-Chief of the Federal Bar Association Section of Taxation Tax Report (1997-2000); Member of the American Bar Association and the District of Columbia and Florida Bars.
IRS Procedures: Examinations and Appeals (Portfolio 623)Transfer Pricing: Records and Information (Portfolio 891) Peter A. Glicklich, Esq.Peter A. Glicklich is a partner resident in the New York office of Davies, Ward, Phillips & Vineberg LLP. His practice is concentrated on the taxation of corporate and international transactions. He advises public and closely held corporations in connection with mergers and acquisitions, cross-border financings, restructurings, reorganizations, spin-offs and intercompany pricing. Mr. Glicklich has dealt with companies in diverse fields, including chemicals, consumer products, real estate, biotechnology, software, telecommunications, pharmaceuticals and finance. As well he has worked with venture funds, investment banks, hedge funds, commodities and securities dealers and insurance companies. He is a contributing editor of the Tax Management International Journal, the Canadian Tax Journal, the Journal of Taxation of Global Transactions, and the International Tax Review, and is a former contributing editor of the Journal of Real Estate Taxation.
Mr. Glicklich has written numerous articles on cross-border financing, net loss carryovers, bankruptcy restructurings, the use of conduits, transfer pricing, loss importation, and taxation of internet activities. He also speaks frequently on international and corporate tax topics. Mr. Glicklich presently serves as the New York Regional Vice-President and an Executive Committee member of the USA Branch of the International Fiscal Association, and he is a past Secretary of that Committee. He is also a member of numerous bar associations. Mr. Glicklich received an honors degree from the University of Wisconsin - Madison in 1977 and received his J.D. cum laude from Harvard Law School in 1981.
U.S. Taxation of International Shipping and Air Transport Activities (Portfolio 945) Joseph R. Goeke, Esq.Joseph R. Goeke, Xavier University, B.S. (1972); University of Kentucky, J.D. (1975); former Special International Trial Attorney, Internal Revenue Service; frequent lecturer, including Tax Executives' Institute, World Trade Institute, Georgetown University Law Center, National Foreign Trade Council, and International Fiscal Association; member, American Bar Association, Section of Taxation; admitted to practice, Kentucky, Illinois, U.S. District Court for the Northern District of Illinois, U.S. Court of Federal Claims, and U.S. Tax Court.
Transfer Pricing: Records and Information (Portfolio 891) Sandra M. GoldbergSandra Goldberg, LL.B., University of Ottawa, 1982; Associate Partner, Deloitte & Touche LLP, Ottawa, Ontario; member Law Society of Upper Canada since 1984, Canadian Tax Foundation, International Fiscal Association; speaker on transfer pricing issues; author, articles on transfer pricing, competent authority and permanent establishments; named in Euromoney’s 2008 list of World’s Leading Transfer Pricing Advisors.
U.S. Income Tax Treaties — Competent Authority Functions and Procedures of Selected Countries (Portfolio 941) Murray L. Gordon, Esq.Murray L. Gordon, B.A. (cum laude), Brandeis University (1970); J.D., Loyola University (1975); LL.M. (Taxation), New York University (1976); member, Illinois Bar; Certified Public Accountant (Illinois); frequent lecturer on domestic and international corporate taxation, and member, World Trade Institute Tax Advisory Panel.
The Possessions Tax Credit Under Section 936 (Portfolio 933) Richard A. Gordon, Esq.Richard A. Gordon, B.A., New York University, 1964; LL.B., Duke University, 1967; tax principal, Washington International Tax Group, Deloitte Tax LLP, 2002-2005 (retired); tax partner, Director of International Specialty, Arthur Andersen, Washington, D.C., 1985-2002; Deputy Chief of Staff and International Tax Counsel, Joint Committee on Taxation, United States Congress, 1981-1985; Special Counsel for International Taxation, Internal Revenue Service, and Assistant to the Commissioner of Internal Revenue Service, Washington, D.C., 1979-1981; Associate, White & Case, Washington, D.C., 1976-1979; Attorney-Advisor, Office of International Tax Counsel, Office of Assistant Secretary of the Treasury (Tax Policy), 1972-1976; Attorney-Advisor, Legislation and Regulations Division, Office of the Chief Counsel, Internal Revenue Service, 1970-1972; Associate, Reynolds, Richards, LaVenture, Hadley & Davis, New York, 1967-1970; member, ABA; author and speaker on international tax issues.
The Allocation and Apportionment of Deductions (Portfolio 906)Foreign Corporation Earnings and Profits (Portfolio 932) Bruno GouthiereBruno Gouthiere, Ecole Nationale d´Administration, the University of Paris, Master in Law and BS in Economics, and the Institut d'Etudes Politiques of Paris; partner with CMS Bureau Francis Lefebvre, international tax department, since 1989; previously, he was acting as Chief of Staff, International Tax Relations, Tax Policy Department, Ministry of Finance; author of reference books in international tax law, such as “Les Impôts dans les affaires internationales”, "Les Holdings", "Transfer Pricing Rules and Practice in France" (Tax Management, BNA), "Advance Rulings in France" (IBFD), "The International Guide to Holding Companies" (IBFD), co-author of various books on “Wealth” (Memento du Patrimoine), “Civil Companies” (Memento Sociétés Civiles), and of numerous articles in French and foreign legal, tax and financial reviews; member of various associations of tax practitioners such as the International Fiscal Association (“IFA”) and the Fiscal Committee of the European Fiscal Confederation (“CFE”).
Transfer Pricing: European Rules and Practice (Portfolio 895) Corrado GuerraCorrado Guerra, Law Degree, University “La Sapienza” (1996); LL.M. (International, European and Comparative Law), Vrije Universiteit Brussel (2000); previously associated with Morgan, Lewis & Bockius, Lovells Boesebeck Droste and Jones Day, Brussels, Belgium.
Business Operations the European Union (Portfolio 999)
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Steven P. Hannes, Esq.Steven P. Hannes, Amherst College, B.A. (1967); New York University School of Law, J.D. (1970); formerly Associate International Tax Counsel, Department of the Treasury; Group Chief, Corporation Tax Branch, Internal Revenue Service; Member of National Council and Vice President (Washington Region), International Fiscal Association; member, District of Columbia Bar Association, American Bar Association, Tax Committee of National Foreign Trade Council.
Bertrand M. Harding, Jr. Esq.Bertrand M. Harding, Jr., Duke University (1968); J.D., The George Washington University National Law Center (1975); former Tax Law Specialist, Internal Revenue Service Exempt Organizations Division (1972-1975); former attorney-advisor to Judge Bruce M. Forrester, United States Tax Court (1975-1977); former tax partner, Baker & McKenzie, Washington, D.C. office (1984-1996); lecturer on college and university tax matters; author, The Tax Law of Colleges and Universities, 2d ed., published by John Wiley & Sons, Inc.
U.S. Income Taxation of Foreign Students, Teachers, and Researchers (Portfolio 914) Kenneth L. Harris, Esq.Kenneth L. Harris, A.B. Hamilton College (summa cum laude 1982, Phi Beta Kappa); J.D. University of Chicago Law School (1985); LL.M. New York University School of Law (1988, Graduate Editor, Tax Law Review); Member of Committee on U.S. Activities of Foreign Taxpayers and Standards of Tax Practice; co-author of Standards of Tax Practice (4th Ed. 1997); frequent speaker and writer on federal tax issues.
Partners and Partnerships — International Tax Aspects (Portfolio 910) Sandra HazanSandra Hazan graduated from the University of Paris II (Maîtrise de Droit des Affaires et Fiscalité, 1990), the University of Paris I (DEA Droit Anglais et Nord-Américain des Affaires, 1991) and attended the LLM course at Queen Mary & Westfield College, London (1993); partner, Salans.
Business Operations France (Portfolio 961) Thijs J. M. HeijenrathThijs Heijenrath, University of Tilburg, Master’s in tax law; certified tax advisor and member of the Dutch Tax Advisors Association (NOB); member of the Global Transfer Pricing Strategy board of Deloitte; international tax partner with Deloitte Belastingadviseurs BV, Netherlands affiliate of Deloitte Touche Tohmatsu, based in Rotterdam. Mr. Heijenrath leads Deloitte's Transfer Pricing / Tax-Aligned Supply Chain group in the Netherlands and is an active member of the Global Transfer Pricing Strategy board of Deloitte.
U.S. Income Tax Treaties — Competent Authority Functions and Procedures of Selected Countries (Portfolio 941) Francisco R. Hernández-Ruiz, Esq.Francisco Hernández-Ruiz, B.S.B.A., Boston College (1962); L.L.B. University of Puerto Rico School of Law (1965); L.L.M. (in Taxation), New York University Law School (1972); Assistant Professor of Tax Law, Interamerican University School of Law (1984–1988); Assistant Professor of Taxation, University of Phoenix (1994–1995); Member of the Board of Bar Examiners (1985–1986); Member of the Evaluating Committee of the Council of Higher Education for the Accreditation of the Graduate Law Program of Catholic University; Member of the Puerto Rico Bar Association; Member of Tax Committee of the Puerto Rico Chamber of Commerce; Member of the Tax Committee of the Puerto Rico Manufacturing Association; frequent lecturer on tax issues; author of various articles on tax laws.
Business Operations Puerto Rico (Portfolio 2650)Business Operations Puerto Rico (Portfolio 980) James Hickey, Esq.James P. Hickey, B.B.A., Western Illinois University; MST, DePaul University; member, American Institute of Certified Public Accountants; Illinois and Ohio CPA Societies; Adjunct Professor of Taxation, DePaul University Graduate School of Business, College of Commerce.
Foreign Sales Corporations (Portfolio 934) Robert F. Hudson, Jr. Esq.Robert F. Hudson, LL.M. (Taxation), New York University (1972); J.D., University of Florida (1971); B.S.B.A., Economics, University of Florida (1968); member, Florida and New York Bars; Chairman, S.E. Region, U.S.A. Branch of International Fiscal Assoc. (1984); Chairman, Foreign Tax Advisory Committee of Florida Bar, Tax Section (1983–1985); project chairman and a principal author of the Florida Bar's “Proposed Revisions of Pending FIRPTA Withholding Tax Bill (Feb. 10, 1984)” which was essential basis of Code Section 1445 enacted as part of the Deficit Reduction Act of 1984; Contributor to: Tax Management International Journal, Tax Management Real Estate Journal, Tax Planning International Review, Lawyer of Americas, American Bar Journal, Florida Bar Journal, Florida Bar International Law Quarterly; Speaker, World Trade Institute, International Fiscal Association — U.S.A. Branch, International Tax Planning Association, Florida Bar, Florida Institute of CPAs, Quebec Bar Assoc., University of Florida, University of Miami, Universite Laval, University of Netherlands Antilles, and University of Barbados.
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Geraldine Josephina, Esq.Geraldine C. Josephina, graduated in Dutch tax law from the University of Leiden, The Netherlands (1990); senior tax law practitioner, Loyens & Loeff, Curaçao, rendering advice on Netherlands Antilles and Aruba tax matters.
Business Operations The Netherlands Antilles (Portfolio 974)
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Akemi Kawano, Esq.Akemi Kawano, B.M., The Julliard School (1989), M.M., The Julliard School (1991), D.M.A., Manhattan School of Music (1999), J.D., with Honors, George Washington University Law School (2002); associate in the Washington, D.C. office of Alston & Bird LLP; serves as general counsel of the Japan America Society of Washington, D.C.
Income Tax Treaties — Administrative and Competent Authority Aspects (Portfolio 940) Larry R. Kemm, Esq.Larry R. Kemm, B.S. (1984), University of Missouri – Kansas City; J.D. (1992, summa cum laude), Indiana University School of Law; Associate Editor, Indiana Law Review; Certified Public Accountant (Texas); Board Certified, Tax Law, Texas Board of Legal Specialization (1997–2002); past Chair, Controlled Group Subcommittee, ABA Tax Section, Affiliated and Related Corporations Committee; frequent speaker on international tax subjects at various institutes and seminars; Treasurer and member of Steering Committee, Midwest Region, International Fiscal Association; admitted to practice, Texas, Illinois, U.S. Tax Court, and U.S. District Court for the Northern District of Texas.
CFCs — Sections 959-965 and 1248 (Portfolio 930) Lee Khvat, Esq.Lee Khvat is an associate in the law firm of McDermott Will & Emery UK LLP, based in its London office. He is a member of the Tax Department, where his practice focuses on a range of corporate tax matters.
Business Operations the United Kingdom (Portfolio 989) Woo Taik Kim, Esq.Woo Taik Kim, Seoul National University (B.A., 1970); Columbia University (M.B.A., 1972); tax partner, Kim & Chang, Seoul; Member, Korean Institute of Tax Attorneys, Korean Institute of Certified Public Accountants, New York State Society of Certified Public Accountants, International Fiscal Association.
Transfer Pricing: Foreign Rules and Practice Outside of Europe, Part 2 (Portfolio 898)Business Operations the Republic of Korea (Portfolio 970) Martha A. Klasing, CPAMartha A. Klasing, B.S., Southern Illinois University — Carbondale; Master of Accounting (Taxation), University of Missouri – St. Louis; Partner, KPMG LLP; Certified Public Accountant; member, American Institute of Certified Public Accountants; contributor: Tax Management International Journal; International HR Journal; Tax Management Compensation Planning Journal; frequent speaker on international tax issues and developments.
Section 911 and Other International Tax Rules Relating to U.S. Citizens and Residents (Portfolio 918) Adil K. KotwalAdil K. Kotwal, B.Com, F.C.A., Bachelor of Commerce, University of Bombay (1978), Fellow of the Institute of Chartered Accountants of India. He joined the firm in 1978 and is currently the Managing Partner and partner responsible for the firm's international and corporate finance practice. He has served as visiting faculty with the University of Bombay teaching Accountancy and Taxation.
Business Operations India (Portfolio 966) Kenneth J. Krupsky, Esq.Kenneth J. Krupsky, Tax Partner, Jones Day (Washington, DC); Columbia Law
School (J.D. 1972; Harlan Fiske Stone Scholar; International Fellow;
Columbia Law Review; Comments and Case Notes Editor, Columbia Journal of
Transnational Law); Columbia College (B.A. in Philosophy 1969; National
Merit Scholar). Served as Deputy Assistant Secretary of the Treasury for
Tax Policy, U.S. Treasury Department in President Clinton's second term,
Chair of the International Tax Committee of the District of Columbia Bar
Association, and Adjunct Professor at Georgetown University Law Center.
Member of Tax Management International Journal's "Panel of Leading
Practitioners" and regularly contributes to that journal. Other
publications include: Joint Ventures with International Partners (coauthor, Butterworth 1994); and International Joint Ventures coauthor, Federal Publications 1986; 2d ed. 1988). Regularly
listed as a leading tax lawyer in Chambers USA, Euromoney's International
Tax Review (one of the "world's leading tax advisers" and "world's leading
transfer pricing advisers"), and Super Lawyers.
Transfer Pricing: Alternative Practical Strategies (Portfolio 890) Kalle KylakallioKalle Kyläkallio, LL.B., 1993 (University of Lapland), Varatuomari, 1995 (“lawyer trained in the court”),Address: Susiluoto Attorneys-at-Law Ltd, Uudenmaankatu 16 B, 00120 Helsinki, Finland, Tel:+358 9 6869 110, Fax: +358 9 6869 1169
Business Operations Finland (Portfolio 960)
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Daniel S. LangeDaniel S. Lange, B.B.A., 1981, M.S., taxation, 1983, University of Wisconsin; managing partner, U.S. International Tax practice, Deloitte Tax LLP, 2002–present; tax partner, International Tax Specialty Team, Arthur Andersen, Milwaukee, Wisconsin, 1992-2002, manager, 1986-1991, staff, 1983-1985; member AICPA, WICPA; speaker, international tax issues; author, numerous articles on international tax issues.
The Allocation and Apportionment of Deductions (Portfolio 906)Foreign Corporation Earnings and Profits (Portfolio 932) Werner LedererWerner Lederer, University of Zürich (lic. iur., 1988); Swiss Certified Tax Consultant; member, Swiss Institute of Certified Accountants and Tax Consultants, International Fiscal Association, International Bar Association.
Business Operations Switzerland (Portfolio 986) Howard J. Levine, Esq.Howard J. Levine, B.A., Hunter College (1969); J.D., State University of New York at Buffalo (cum laude, 1972); LL.M. (Taxation), Georgetown University Law Center (1976); attorney and assistant branch chief, Office of Chief Counsel, Internal Revenue Service (1972-1976); adjunct lecturer in Real Estate Taxation, American University Law School (1980-1982); adjunct professor, The George Washington University Law School and Georgetown University Law Center LL.M. Tax Programs (1982-1993); contributing editor, The Journal of Real Estate Taxation; Tax Management Distinguished Author (2000); member, Advisory Board, Tax Management International Journal; member, Advisory Board, CCH Journal of Taxation of Global Transactions; author, 936 T.M., U.S. Income Tax Treaties — The Limitation on Benefits Article; partner, Roberts & Holland LLP, Washington, D.C. and New York, N.Y.; member, American Bar Association (Chairman, Committee on Sales, Exchanges and Basis, and Subcommittee Chairman, Like Kind Exchanges, Tax Section 1990-1994), New York Bar, District of Columbia Bar, International Fiscal Association.
U.S. Income Tax Treaties — The Limitation on Benefits Article (Portfolio 936) Edward H. Lieberman, Esq.Edward H. Lieberman, B.A., C.C.N.Y.; J.D., Brooklyn Law School; LL.M., London School of Economics; member, The District of Columbia and New York Bars and the American and International Bar Associations; formerly, Tax Law Specialist, IRS Corporation Tax Branch; author: “The Foreign Sales Corporation Issues and Answers Under the Temporary Regulations,” Tax Mgmt. Intl. J., March, 1985; “Analysis of the Foreign Sales Corporation — Temporary Regulations,” Tax Mgmt. Memo., February, 1986; “Foreign Sales Corporations — The Shape of Regs. to Come,” Tax Mgmt. Intl. J., January, 1987; and “Foreign Sales Transactions: A Prognosis for 1987,” Tax Mgmt. Memo., February, 1987. Member, IRS Commissioner's Advisory Group 1995–1996.
Foreign Sales Corporations (Portfolio 934) Howard M. Liebman, Esq.Howard M. Liebman, A.B. (summa cum laude), Colgate University (1974); A.M. (with distinction), Colgate University (1975); J.D. (cum laude) Harvard Law School (1977); Member, District of Columbia Bar and “B” List of the French-speaking Brussels Bar; Belgian Member, Tax Management International Forum; Contributing Editor, European Taxation; Editorial Advisory Board, Practical European Tax Strategies; Chairman, Legal & Taxation Committee, American Chamber of Commerce in Belgium.
Business Operations the European Union (Portfolio 999) Gregory P. Lubkin, Esq.Gregory P. Lubkin, University of Edinburgh (U.K.) (M.A. 1975); University of California, Berkeley (Ph.D. 1982); Harvard University (J.D. 1996); member, District of Columbia Bar and Section of Taxation of American and District of Columbia Bar Associations; contributor: Tax Management International Journal.
Source of Income Rules (Portfolio 905)
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Ewing W. Madole, Esq.Ewing W. Madole, B.A., M.B.A. Mississippi State University (1973, 1975); J.D., Columbia University School of Law (1985); LL.M. in Taxation, New York University (1990); Member of the New York Bar; Certified Public Accountant, Tennessee (1977).
Controlled Foreign Corporations — Section 956 (Portfolio 929) Jacques Malherbe, Esq.Jacques Malherbe, JD, University of Louvain (1962); LL.M., Harvard University (1964); Professor, University of Louvain; Visiting Professor, Universities of Paris II, Paris XII, Dijon, Vienna, Hamburg.
Business Operations Belgium (Portfolio 953) Petri ManninenPetri Manninen, LL.B., 1993 (University of Helsinki), Varatuomari, 1995 (“lawyer trained in the court”), LL.M. in European Community Law (University of Leiden), 1996.
Business Operations Finland (Portfolio 960) Patrick MarleyPatrick Marley, B.Comm., Queen's University; LL.B., University of Western Ontario; LL.M., New York University; Barrister and Solicitor of the Bars of Ontario and New York; Tax Partner, Osler, Hoskin & Harcourt LLP.
Business Operations Canada (Portfolio 955) Joel M. McDonaldJoel M. McDonald, B.S., summa cum laude, University of Alabama (1984); J.D., University of Virginia (1987); Advisor to the Russian Government on Tax Reform (1994-1997).
Business Operations Russia (Portfolio 981) Michael J. Miller, Esq.Michael J. Miller is a partner in the New York office of Roberts & Holland LLP. He counsels foreign-and-U.S. based multinationals regarding a wide range of tax issues pertaining to their cross-border activities. Michael co-authored 945 T.M., U.S. Taxation of International Shipping and Air Transport Activities, and has written numerous articles on international tax issues for the Tax Management International Journal, CCH Journal of Taxation of Global Transactions, and the Canadian Tax Journal. Michael is an active member of the U.S. Activities of Foreign Taxpayers and Tax Treaties Committee of the American Bar Association Tax Section. He received his B.A. cum laude from Columbia College in 1988 and his J.D. from New York University in 1991. He clerked on the U.S. Tax Court for the Honorable James S. Halpern from 1991-1993.
U.S. Income Tax Treaties — The Limitation on Benefits Article (Portfolio 936)U.S. Taxation of International Shipping and Air Transport Activities (Portfolio 945) Luis Fernando MirandaLuis Fernando Miranda, Universidad Central de Venezuela (Public Accounting, 1986); Columbia University (Professional Extension Program); Professor, Universidad Central de Venezuela; member, Tax Committee of Venamcham; former member, Committee of Coindustria.
Business Operations Venezuela (Portfolio 993) Jerrie V. Mirga Jerrie Varrone Mirga, College of William & Mary, B.A. (1979); George Washington University, MBA (1985) and post-MBA Certificate (2001); Vice President, Economic Consulting Services, LLC. Ms. Mirga advises clients on transfer pricing issues involving tangible and intangible property for planning, documentation and audit purposes.
Transfer Pricing: Economic, Managerial, and Accounting Principles (Portfolio 889) Michael C. Moetell, Esq.Michael C. Moetell, B.S. (cum laude), Villanova University (1982); J.D. (cum laude), Harvard Law School (1985); member, International Fiscal Association, American Bar Association's Section of Taxation, D.C. Bar Association's Tax Section.
Indirect Foreign Tax Credits (Portfolio 902) Gianmarco MonsellatoGianmarco Monsellato; graduate of the HEC Group, International Management School France; recognized as “Lead Tax Adviser” and “Lead Transfer Pricing Advisor” in all Euromoney Legal Media Group Surveys. Co-founder of the Transfer Pricing worldwide Deloitte team, his service line has been quoted n°1 Transfer Pricing Team in France, by the International Tax Review; co-author of the first French book on transfer pricing: Les prix de Transfert; wrote the French chapter in Transfer Pricing – an International Guide; author of numerous articles on international tax and transfer pricing in French and international reviews; is a member of the global transfer pricing task force of the International Chamber of Commerce; member of the IFA; member of the French-US Chamber of Commerce; has substantial experience in strategic tax planning, tax controversies, Advance Transfer Pricing Agreements and Competent Authority Procedures; is currently the Managing Partner (CEO) of Taj, an international tax and law firm in France, member of Deloitte Touche Tohmatsu and advises leading European, Japanese, Korean and US multinational companies in transfer pricing and international tax strategies.
U.S. Income Tax Treaties — Competent Authority Functions and Procedures of Selected Countries (Portfolio 941) Clifford E. Muller, Esq.Clifford E. Muller, B.S., B.A., Bucknell University (magna cum laude 1978), Delta Mu Delta; J.D., George Washington University (with high honors 1981), Order of the Coif; Professional Lecturer in Law, George Washington University Law School, 1987–1990. Member, District of Columbia Bar Association; member, American Bar Association, Section of Taxation; Chairman, Subcommittee on International Financial Transactions; member, Committee on Foreign Activities of U.S. Taxpayers, Foreign Currency Subcommittee. Lecturer: World Trade Institute, New York, “Taxation of Foreign Currency” and “Foreign Currency Exposure Management.”
Tax Aspects of Foreign Currency (Portfolio 921) Michael Mulroney, Esq.Michael Mulroney, B.S.C., University of Iowa (1954); J.D., Harvard Law School (1959); Order of Coif; Professor of Law, Director, Graduate Tax Program, Villanova School of Law (1988-present); Adjunct Professor, Georgetown University Graduate Tax Program (1986-present); Partner, Lee, Toomey & Kent, Washington, D.C. (1969-1988) (Associate 1965-1969); Appellate Attorney, Tax Division, U.S. Department of Justice, Washington, D.C. (1961-1965); Attorney Advisor, U.S. Tax Court (1959-1961). Teacher: Federal taxation; professional responsibility; faculty advisor, Villanova Law School Tax Clinic. Admitted to practice: District of Columbia; Iowa; U.S. Supreme Court; Iowa Supreme Court; U.S. Circuit Courts of Appeal for the Second, Third, Fourth, Fifth, Sixth, Seventh, Eighth, Ninth and Tenth Circuits; U.S. Tax Court; U.S. District Court for the District of Columbia; District of Columbia Court of Appeals. Professional organizations: District of Columbia Bar; Iowa State Bar Association; Federal Bar Association; American Bar Association, Section of Taxation (Tax Lawyer Committee, former Managing Editor, The Tax Lawyer, Chair Annual Reports Subcommittee; Court Procedure Committee; Standards of Practice Committee; Teaching Taxation Committee; Committee on Government Submissions), Section of Legal Education and Admissions to the Bar; District of Columbia Bar (Tax Section); Federal Bar Association (Tax Section); Iowa Bar Association (Tax Section); Fellow, American College Tax Counsel; J. Edgar Murdock American Inn of Court (Founding Master); American Association of Law Schools (Tax Section); International Fiscal Association (U.S.A. Director); Washington Tax Lawyers' Study Group; Philadelphia Tax Conference (Director, Executive Committee); Reporter, Invitational Conference on Professionalism in Tax Practice (1993); Commentator, Statute of the Bar of the Republic of Belarus (CEELI); author of various books and tax articles. Competition license holder, Sports Car Club of America.
Tax Aspects of Foreign Currency (Portfolio 921)
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Andrew C. Newman, CPAAndrew C. Newman, B.B.A., University of Wisconsin, 1980; tax partner, International Tax Service Line, Deloitte Tax LLP, Chicago, Illinois, 2002-present; Arthur Andersen, 1980-2002; member, AICPA, Illinois CPA Society, International Fiscal Association, Chicago Counsel on Foreign Relations; author, numerous articles on international tax matters; frequent speaker at seminars on international tax issues.
The Allocation and Apportionment of Deductions (Portfolio 906) Thanh Vinh NguyenThanh Vinh Nguyen holds his Bachelor of Arts Degree in English from the University of Ho Chi Minh City and his LL.B. from the College of Law of Ho Chi Minh City. Mr. Nguyen worked for two international accounting firms for eight years before joining the Ho Chi Minh City office of Baker & McKenzie in 2004. His principal practice areas are tax advice and planning, finance and banking, and general corporate matters. He is fluent in English as well as his native Vietnamese.
Business Operations Vietnam (Portfolio 994) Peter M. W. Nias, Esq.Peter Nias is a partner in the law firm of McDermott Will & Emery UK LLP, based in its London office. He is Head of the London office Tax Department, where his practice focuses on direct and indirect tax advice on a broad range of corporate and commercial business activities, including acquisitions and disposals, and corporate structures for UK and international business investments. Peter also advises on general corporate commercial tax matters for companies and advises individuals on wealth preservation techniques.
Business Operations the United Kingdom (Portfolio 989) Lionel B. NobreLionel Bonner Nobre, Director of BDO Seidman LLP's Brazilian Consulting Services in Miami; Pontifical University of São Paulo, Brazil (LLB, 1992 and LLM, 2000); Member, Brazilian Bar, Brazilian Institute of Certified Financial Planners (“Instituto Brasiliro de Certificação de Planejadores Financeiros – IBCPF”), Brazilian Association of Tax Consultants (“Associação Brasileira de Consultores Tributários – ABCT”), Academy of Brazilian Tax Law (Academia Brasileira de Direito Tributário – ABDT”), and the Brazilian Tax Planning Institute (“Instituto Brasileiro de Planejamento Fiscal – IBPT”).
Transfer Pricing: Foreign Rules and Practice Outside of Europe, Part 2 (Portfolio 898)
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Christopher Ocasal, Esq.Christopher (Chris) Ocasal is an international tax partner with Sutherland, Asbill & Brennan. Mr. Ocasal has extensive experience in advising clients with regard to their international tax issues and has substantial expertise in international insurance tax issues. Mr. Ocasal has worked with major U.S. multinationals with significant international operations and major foreign multinationals with significant U.S. operations. He advises on structuring joint ventures, domestic and international reorganizations, mergers and acquisitions, financial products, foreign currency transactions, anti-deferral regimes, withholding tax issues, foreign tax credit planning, and U.S. tax treaties. Prior to joining Sutherland, Mr. Ocasal was a principal in the PricewaterhouseCoopers LLP Washington National Tax Services office for nearly a decade. Additionally, prior to joining PricewaterhouseCoopers, Mr. Ocasal was a member of the Washington, D.C. office of Baker & McKenzie. Chris Ocasal received a J.D. from George Washington University Law School and an LL.M. from Georgetown University. He is a member of the New York and Virginia bar. Mr. Ocasal is also the co-author of a new BNA tax management portfolio, to be published, on Financial Instruments in which he reviews the taxation of notional principal contracts.
State Tax Appeal Systems (Portfolio 1700)U.S. Income Taxation of International Insurance Activities(Portfolio 931) Margaret Peg O'Connor, Esq.Margaret O’Connor, A.B. Bryn Mawr College; J.D. University of Maryland; M.L.T. from Georgetown University; International Tax Services Principal, Ernst & Young LLP, Washington, DC; member District of Columbia Bar, Maryland Bar, ABA; speaker on international tax issues; author of numerous articles relating to international tax.
Reporting Requirements Under the Code for International Transactions (Portfolio 947) Thomas A. O'Donnell, Esq.Thomas A. O'Donnell, Esq., B.A., Swarthmore College (1969); Ph.D., Rutgers University (1979); J.D., University of Cincinnati College of Law (1983); member, American Bar Association, District of Columbia Bar Association.
PFICs (Portfolio 923) Michael A. Olesnicky, Esq.Michael Olesnicky holds a BA and LLB from Adelaide University in Australia. He also holds an LLM from Columbia University in New York. He practiced from 1979–82 with Baker & McKenzie's office in Sydney. In 1988, he rejoined Baker & McKenzie's office in Hong Kong, and became a partner in 1989 in the International Tax Group. His chief specialty is Hong Kong and regional tax advisory work as well as estate duty planning. He is the Chairman of the Joint Liaison Committee on Taxation, which is a quasi-governmental committee that interfaces between tax practitioners and the Inland Revenue Department. He is a past chairman of the tax committee of the Australian Chamber of Commerce. He was a member of the Inland Revenue Board of Review (the lowest-level tax court in Hong Kong) between 1985 and 1994. He was Chief Editor of the Hong Kong Law Journal for five years. He writes and speaks frequently on Hong Kong tax matters.
Business Operations Hong Kong (Portfolio 964) Ricardo Gonzales OrtaRicardo Gonzalez Orta; graduate of the Universidad Iberoamericano; has significant experience in transfer pricing matters and coordinates the Deloitte Mexico and Latin America region Transfer Pricing practices; spent eight years in a number of top executive posts with the Ministry of Finance (Secretaría de Hacienda y Crédito Público -SHCP-) and the Tax Administration Service (Servicio de Administración Tributaria -SAT-), most recently as Director General of Tax Policy and, as Director General of International Fiscal Affairs, in these positions he was in charge of Mexico's tax and customs policy and the negotiation of double taxation treaties; is a frequent speaker in different domestic and international forums; writes periodically on Mexican tax and transfer pricing issues in the Tax Management International Journal; is currently a partner at Galaz, Yamazaki, Ruiz Urquiza SC, Deloitte Touche Tohmatsu´s Mexico affiliate, where he advises multinational companies on tax-related matters, including structuring new businesses, acquisitions, reorganizations, joint ventures, double taxation issues, and transfer pricing.
U.S. Income Tax Treaties — Competent Authority Functions and Procedures of Selected Countries (Portfolio 941)
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Michael F. Patton, Esq.Michael F. Patton; University of Maryland (B.A. and J.D. with honors, Order of the Coif), Georgetown University Law Center (LL.M., Taxation); was editor and a major contributor to the Treasury/IRS Transfer Pricing White Paper; was a member of the Treasury/IRS study group to revise the competent authority function; worked extensively on the OECD Multilateral Treaty on Mutual Administrative Assistance in Tax Matters and the U.S.-Bermuda Tax Convention; was the lead U.S. Treasury negotiator in many negotiations with foreign governemnts for tax information exchange agreements under the Caribbean Basin Initiative; named one of the Best of the Best U S transfer pricing advisors as well as one of the leading Asia Pacific tax advisors by Euro Money and the International Tax Review; has been named as a “Highly Recommended” tax advisor by the International Tax Review; member, Editorial Advisory Board of Tax Management, Inc; contributor to the Tax Management International Tax Journal, the Transfer Pricing Reporter, and other publications; is a Principal with Ernst & Young, a member of the International Tax Services Group in the National Tax Department.
Transfer Pricing: Alternative Practical Strategies (Portfolio 890) Josephine Y. K. Peng Josephine Y. K. Peng, Member of Taiwan CPA Association and Taipei Certified Public Accountant Association (since 1985); CPA, New Jersey, USA (since 1982); Senior CPA and Senior Counselor, Lee and Li, Attorneys-at-Law, Taipei (2000–present); Managing Partner, Intellects & Co., CPAs, Taipei (1989–2000); Columbia University, USA (Accounting Doctoral Program, 1981); Central State University of Oklahoma, USA (MBA, 1980); National Chung Hsing University, Taipei (B.B.A., 1977). Named by International Tax Review in 2006 as the most sought after tax adviser in Taiwan; and by The Tax Directors Handbook 2009 as one of the three best tax advisers in Taiwan; leads the Tax Practice Group of Lee and Li, Attorneys-at-Law, which was voted by International Tax Review in 2006 and 2007 as Taiwan Tax Firm of the Year; an active member on the tax committees of the American Chamber of Commerce in Taipei and the European Chamber of Commerce in Taipei; and a regular contributor of articles on various tax issues.
Business Operations in the Republic of China (Taiwan) (Portfolio 958) Charles T. Plambeck, Esq.Charles T. Plambeck, A.B. University of North Carolina (1983); J.D. University of North Carolina School of Law (1986); Office of the Associate Chief Counsel (International), Internal Revenue Service (1988-1990); Special Counsel of the Chief Counsel, Internal Revenue Service (1990-1992); Of Counsel and Partner, Caplin & Drysdale (1992-1997); Managing Director and Tax Counsel, Bankers Trust Company and Deutsche Bank (1997-2001).
U.S. Income Taxation of Foreign Corporations (Portfolio 908) Irving H. PlotkinIrving H. Plotkin, Wharton School, University of Pennsylvania, B.S.; Massachusetts Institute of Technology, Ph.D. in mathematical economics. Dr. Plotkin is Managing Director of the Boston Tax practice of PricewaterhouseCoopers; for many years previous, he was Vice-President for Forensic Economics at Arthur D. Little, Inc. Dr. Plotkin has designed and conducted research studies on various topics including the effects of government regulation, self-regulation, industry efficiency and risk taking. Dr. Plotkin lectures frequently on economic and regulatory issues, and based on his research work, has presented expert testimony in the Tax Claims, U.S. District, and State Courts on behalf of taxpayers and the IRS in a number of high-profile tax disputes (including Du Pont, UPS, DHL, ACM, Bausch and Lomb, The Limited, Dow, and the captive cases) and has testified before U.S. congressional committees and federal and state commissions.
Transfer Pricing: Economic, Managerial, and Accounting Principles (Portfolio 889) Dirk PohlDr. Dirk Pohl, University of Tax Administration, Northrhine-Westfalia (1987), University of Bonn (First State Law Examination 1993, Second State Law Examination 1997); Doctor of Jurisprudence (1997); member, German Bar for lawyers (Rechtsanwälte) and for tax consultants (Steuerberater); member, International Fiscal Association.
Business Operations Germany (Portfolio 962) G. Garner Prillaman, Jr. Esq.G. Garner Prillaman, Jr., B.S., Virginia Polytechnic Institute and State University (1975); M.B.A., Virginia Polytechnic Institute and State University (1976); J.D., Wake Forest University (1981); LL.M. in Taxation, New York University (1985). Member, District of Columbia Bar Association; member, American Bar Association, Section of Taxation; member, Committee on Foreign Activities of U.S. Taxpayers, Controlled Foreign Corporations Subcommittee; Certified Public Accountant, North Carolina; Lecturer: World Trade Institute, New York, “Foreign Currency Exposure Management.”
Tax Aspects of Foreign Currency (Portfolio 921) Timothy J. Pronley, Esq.Timothy J. Pronley, B.B.A., University of Wisconsin – Madison, 1990; J.D., University of Minnesota, 1993; Tax Senior Manager, Deloitte Tax LLP, Minneapolis, Minnesota; member Wisconsin Bar, ABA, WICPA; speaker on international tax issues; author, articles on international taxation, including contributions to Practicing Law Institute and American Bar Association publications.
Foreign Corporation Earnings and Profits (Portfolio 932)
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Amnon RafaelDr. Amnon Rafael, member of the Israeli and New York Bars (Advocate); LL.M. graduate of New York University (Taxation); J.S.D. graduate of New York University (Doctoral thesis on Tax Aspects of American Investments in Israel); member of the International Fiscal Association.
Business Operations Israel (Portfolio 967) Diane L. Renfroe, Esq.Diane L. Renfroe, B.A., Wellesley College, 1968; J.D., Boston College Law School, 1977; admitted to Bar, Massachusetts, District of Columbia; Adjunct Professor, LLM International Tax Program, Georgetown University Law Center, 2004–present; tax principal, Washington International Tax Group, Deloitte Tax LLP, 2002–present; tax partner, International Tax Specialty Team, Arthur Andersen, Washington, D.C., 1988-2002; manager, Arthur Andersen, 1983-1988; formerly Assistant Branch Chief/Attorney-Advisor, Legislation and Regulations Division, Office of Chief Counsel, Internal Revenue Service, 1977-1982; member, Commissioner's Advisory Group, 1990-1992; author, numerous articles on international tax issues and developments; frequent speaker at seminars on international tax issues.
The Allocation and Apportionment of Deductions (Portfolio 906) Diane M. RingDiane M. Ring, A.B. Harvard College (1986); J.D. Harvard Law School (1990); Caplin & Drysdale (1991-1994); Assistant Professor of Law, Harvard Law School (1994-2004); Associate Professor of Law, University of Florida (2004-2005); U.S. National Reporter to IFA (2003-2004).
U.S. Income Taxation of Foreign Corporations (Portfolio 908) Jennifer Roeleveld, CA(SA)Professor Jennifer Roeleveld, B.Compt (Hon)(SA), B.Com (Honours) (Taxation), LLM University of Cape Town; CA(SA), member of the South African Institute of Chartered Accountants (SAICA); member of the International Fiscal Association. Executive board member of the South African Fiscal Association; member of the National Tax Committee of SAICA and Integritax; head of taxation, Faculty of Commerce, University of Cape Town and registered tax practitioner.
Business Operations South Africa (Portfolio 982) Ricardo J. Romulo, Esq.Ricardo J. Romulo, B.S., cum laude, Georgetown University (1955); J.D., Harvard Law School (1958); Senior Partner, specializing in foreign investments and taxation, Romulo, Mabanta, Buenaventura, Sayoc & de los Angeles; Chairman, Makati Business Club and member, Philippine-United States Business Council; member, 1986 Constitutional Commission, which drafted the present Constitution of the Philippines; former President, Philippine Bar Association.
Business Operations the Philippines (Portfolio 978) Howard D. Rosen, Esq.Howard D. Rosen, B.B.A., University of Miami (1969, magna cum laude); J.D., University of Miami (1973, summa cum laude); member, Editorial Board, University of Miami Law Review; Certified Public Accountant, Florida; member, Florida Bar; member, Tax and International Law Sections of the Florida Bar; Adjunct Professor of Law, University of Miami School of Law (1990- ); member, Board of Governors of the Florida Institute of Certified Public Accountants (1997-1999), member, Florida Institute of Certified Public Accountants, past president and director of the South Dade Chapter of the Florida Institute of Public Accountants.
Asset Protection Planning (Portfolio 810)U.S. Taxation of Foreign Estates, Trusts and Beneficiaries (Portfolio 854)U.S. Taxation of Foreign Estates, Trusts and Beneficiaries (Portfolio 911) Charles D. Rubin, Esq.Charles D. Rubin, Esq., University of Florida (1983); B.A. (Political Science), Northwestern University (1980); member, Florida Bar; Vice–chairman, Foreign Tax Advisory Committee of Florida Bar, Tax Section (1988); Author, “The FIRPTA Manual — Compliance and Planning Guide to the Foreign Investment in Real Property Tax Act” (Maxwell McMillan); Author, “Florida Sales and Use Taxes on Boats — Compliance and Planning Manual” (Florida Tax Publications); Contributor to: University of Florida Law Review, Journal of Bank Taxation, Marine Business Journal, Tax Ideas, Tax Management Estates, Gifts and Trusts Journal, Tax Notes, Journal of Taxation, Callaghan & Co. publications, Bureau of National Affairs publications; Adjunct Professor, University of Miami School of Law, Graduate Program in Taxation and Graduate Program in Estate Planning (1991–present).
Risto Rytohonka, Esq.Risto Rytöhonka, LL.B., 1978 (University of Helsinki), Diploma in European Integration, 1981 (University of Amsterdam), Varatuomari, 1984 (“lawyer trained in the court”), LL.M. in Taxation, 1992 (University of Miami); member of the international lawyers’ organization, The Nordlund Group.
Business Operations Finland (Portfolio 960)
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Ozzie A. Schindler, Esq.Ozzie A. Schindler, Esq., B.S. in Accounting, University of Florida (1990); J.D., University of Florida (1993); LL.M., New York University (1995); member, Florida Bar Association.
PFICs (Portfolio 923) Kristine K. SchlamanKristine K. Schlaman, B.A., University of Northern Colorado (1977); J.D., Washburn University (1983); M.L.T. with Distinction, Georgetown University (1989); KPMG, LLP, International Corporate Services Tax Practice; Attorney-Adviser, Office of Associate Chief Counsel (International) (1989–1996); Attorney, Schroeder, Heeney, Groff and Coffman, P.A., Topeka, Kansas (1984–1988).
Income Tax Treaties — Administrative and Competent Authority Aspects (Portfolio 940) Jeffrey A. SchoenblumJeffrey A. Schoenblum, A.B., Johns Hopkins University (1970); J.D., Harvard Law School (1973); professor, Vanderbilt University Law School (1977-present); author, “Reaching for the Sky or Pie in the Sky: Is U.S. Onshore Trust Reform an Illusion?” in Extending the Boundaries of Trusts and Other Ring-Fenced Funds in the Twenty-First Century (Kluwer); author, Multistate and Multinational Estate Planning, 2 vols. (Aspen 1999 & 2002 Supp.); author, Page on Wills: Annual Supplement (Anderson); author, Multistate Guide to Estate Planning (Aspen 2003); author, “Fiduciary Duty and the Direct-Derivative Distinction in the Takeover/Merger Context” in L'Alambicco Del Comparatista: Amministratori: Fiduciari—Ma Di Chi? (2001); editor, A Guide to International Estate Planning (ABA 2000); author, “Conflict of Laws; Trusts and Civil Law; Situs Wills—The American Perspective” in International Estate Planning (1996); author, Preface, Global Estate Planning (Kluwer 1995); author, “The Use of Offshore Trusts by Residents or Nationals of Civil Law Jurisdictions” and “Property Ownership and Succession Planning for the Foreign National: Conflicts of Law; Recognition of Trusts and Testamentary Dispositions; Marital Property Rights and Forced Heirship” in International Wealth Transfer Techniques—1990s and Beyond (1995); co-editor, International Estate Planning (ABA 1991) (with D. Kozusko); author, “The Adaptation of the Asset Protection Trust for Use by the Multinational Corporation—The American Perspective” in Commercial Aspects of Trusts and Fiduciary Obligations (Clarendon 1992).
Bilateral Transfer Tax Treaties (Portfolio 851)Bilateral Transfer Tax Treaties (Portfolio 939) Ching-Ling SeahChing Ling Seah, L.L.B. (Hons), National University of Singapore, 2002; Advocate & Solicitor, Supreme Court of Singapore; Associate Director, Tax & Private Clients Services, Drew & Napier LLC, Singapore.
Business Operations Singapore (Portfolio 983) Michael SedlaczekMichael Sedlaczek, Universities of Vienna and Innsbruck (Master of Laws 1988); Doctor of Jurisprudence (1992); member, Austrian Bar; member, International Academy of Estate and Trust Law; International Fiscal Association; and International Bar Association.
Business Operations Austria (Portfolio 952) Rajiv G. ShahRajiv G. Shah, B.Com, F.C.A., University of Bombay (1980), Fellow of the Institute of Chartered Accountants of India, Member of International Taxation and Taxation Committee of Bombay Chartered Accountants’ Society, Member of Taxation and International Trade Committee of Bombay Chamber of Commerce and Industry, contributor and speaker at seminars on taxation. Partner responsible for firm's taxation practice.
Business Operations India (Portfolio 966) Stanley G. Sherwood, Esq.Stanley G. Sherwood, Bryant College, B.S.B.A. (1968); Suffolk University Law School, J.D. (1971); New York University Graduate School of Law, LL.M. (1979); Member of the Bar of the State of New York; Certified Public Accountant (New York); Member of the Board, Institute of International Taxation; Member, International Fiscal Association, American Bar Association Tax Committee, New York State Bar Association Committee on Foreign Investment in the U.S.
Steven R. Sieker, Esq.Steven Sieker holds a BA (Honors) from the University of Alberta and an LLB from Dalhousie University (both in Canada). He is a former law clerk to the Supreme Court of Canada and joined Baker & McKenzie's office in Hong Kong in 1998. His specialties are Hong Kong and regional tax advisory work and litigation as well as Canadian tax planning. He has been a member of the Inland Revenue Board of Review and a part-time lecturer in Revenue Law at City University and Hong Kong University. He writes and speaks frequently on tax matters.
Business Operations Hong Kong (Portfolio 964) Stuart Sinclair, Esq.Stuart Sinclair is a partner in the law firm of McDermott Will & Emery UK LLP, based in its London office. He is a member of the Tax Department, where his practice focuses on a range of corporate tax matters, specializing in tax-based structured finance transactions, capital markets, financial instruments, mergers and acquisitions, reorganizations and tax insurance.
Business Operations the United Kingdom (Portfolio 989) Paul A. Smith, Esq.Paul A. Smith, CPA; B.S. (Accounting), Rollins College; M.S. (Taxation), University of Denver; Certified Public Accountant, State of Florida and Washington, D.C.; formerly associated with Ernst & Young, LLP as Director of Tax Accrual Services in the National Tax Department in Washington, D.C.; frequent lecturer on the international tax aspects of accounting for income taxes. Mr. Smith is Vice President of Global Tax at Levi, Strauss & Co. in San Francisco, California.
U.S. Tax-Related Accounting Issues of Multinational Corporations (Portfolio 948) George H. Soba, Esq.George H. Soba, Esq., New York University School of Law, LL.M. (Taxation) (1982); University of Toledo College of Law, J.D. (cum laude) (1981); Franklin and Marshall College, B.A. (1978); formerly IRS Tax Counsel, Brooklyn District Counsel Office and Senior Attorney–Advisor in the Office of Associate Chief Counsel (International).
Transfer Pricing: Records and Information (Portfolio 891) Phillip A. Stoffregen, Esq.Philip A. Stoffregen, B.A. Earlham College (honors 1973); Ph.D. University of Chicago (Mrs. Giles Whiting Fellow 1979); J.D. University of Chicago Law School (honors 1982); Law Clerk, The Honorable Bruce M. Forester, United States Tax Court; frequent speaker and writer on international tax subjects.
Partners and Partnerships — International Tax Aspects (Portfolio 910) Dirk J. J. Suringa, Esq.Dirk Suringa is a Partner in the Washington, D.C. law firm of Covington & Burling LLP, practicing in the areas of international and corporate taxation. Mr. Suringa graduated from Princeton University (B.A. 1992, departmental honors, Phi Beta Kappa) and Harvard Law School (J.D. 1996, magna cum laude), where he served as editor of the Harvard Law Review. Mr. Suringa clerked for the Honorable Gerald B. Tjoflat, Chief Judge of the U.S. Court of Appeals for the Eleventh Circuit, from 1996 to 1997. Mr. Suringa served as Attorney-Advisor in the Office of International Tax Counsel of the Department of the Treasury, from 2000 to 2003. Mr. Suringa is a member of the Florida Bar and the District of Columbia Bar, the American Bar Association, and the International Fiscal Association.
The Foreign Tax Credit Limitation Under Section 904 (Portfolio 904)Foreign Personal Holding Companies (Portfolio 922)
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Shimon Takagi, Esq.Shimon Takagi, Osaka City University (LL.B. 1988); New York University School of Law (LL.M. in Taxation 1995); admitted to Japanese Bar (1990); member, Tokyo Bar Association, New York State Bar and International Fiscal Association.
Business Operations Japan (Portfolio 969) Carol P. Tello, Esq.Carol P. Tello, B.A., College of William and Mary, J.D., University of Maryland School of Law, and M.L.T., Georgetown University Law Center; lecturer on international tax topics; author of numerous articles on international taxation; member of the Tax Management Foreign Income Advisory Board; member, U.S. Branch Council, International Fiscal Association and Foreign Activities of U.S. Taxpayers and U.S. Activities of Foreigners and Tax Treaties Subcommittees of the ABA Section of Taxation; former attorney-advisor, Office of Associate Chief Counsel (International) and Technical Advisor to the Assistant Commissioner (International).
U.S. Withholding and Reporting Requirements for Payments of U.S. Source Income to Foreign Persons (Portfolio 915) Gary M. Thomas, Esq.Gary M. Thomas, B.A., University of Washington, 1973; J.D., Harvard Law School, 1977; Asia University, Masters of Japanese Law/Taxation (1989) and Masters of Japanese Accounting (1994); Partner, White & Case LLP, Tokyo, Japan; admitted in Japan as licensed tax attorney (zeirishi); member of Tokyo Zeirishi Association, California State Bar Association, and Dai-ni Tokyo Bar Association; speaker on Japanese international tax issues; author, articles on Japanese taxation in the United States, Japan and Europe.
Transfer Pricing: Foreign Rules and Practice Outside of Europe (Portfolio 897) Syllas Tozzini, Esq.Syllas Tozzini, partner, TozziniFreire, Teixeira e Silva Advogados, São Paulo, Brazil; University of São Paulo School of Law (LL.B., 1972); Parker School of Foreign and Comparative Law, Columbia University (1987).
Business Operations Brazil (Portfolio 954) Richard G. Tremblay, Esq.Richard Tremblay, B.Sc., McGill; LL.B., Osgoode Hall; LL.M., New York University; Barrister and Solicitor of the Bar of Ontario; Tax Partner, Osler, Hoskin & Harcourt LLP.
Business Operations Canada (Portfolio 955)
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Priscilla B. ValerPriscilla B. Valer, B.S., cum laude, University of Sto. Tomas (1985); J.D., second honors, Ateneo de Manila University (1992); Partner, specializing in taxation, Romulo, Mabanta, Buenaventura, Sayoc & de los Angeles and Director, Tax Management Association of the Philippines.
Business Operations the Philippines (Portfolio 978) H. Tom van der Meer, Esq.Tom van der Meer is a graduate of Leiden law school and is a partner at Loyens & Loeff. He has worked for the Curaçao, New York and Amsterdam offices of the firm and is currently responsible for the Luxembourg office. He has made numerous speeches for large organizations on Netherlands, Luxembourg and international tax issues and is an active member of the International Bar Association and the European American Tax Institute.
Business Operations Luxembourg (Portfolio 971) Kees van Raad, Esq.Kees van Raad, Master of Laws, University of Leiden, The Netherlands (1969); M.C.L., Georgetown University, Washington D.C. (1970); Doctor of Laws, University of Leiden, The Netherlands (1986); Visiting Professor of Law, University of Florida, USA (1982, 1997, 2003); Universities of Stockholm and Uppsala, Sweden (1987); University of London, UK (1990); Emory University, USA (1991), New York University, USA (1992, 2002, 2004, 2006); Bocconi University, Italy (1993, 1994, 2002); University of California (Hastings College of the Law (1996, 2008)); the Free University of Brussels (1997); University of Sydney (1998, 2005); Xiamen University, China (2004); Peking University (PKU) Law School, China (2005, 2006, 2007); and National Taiwan University (2007, 2008). Associate Judge at the Court of Appeal of ‘s-Hertogenbosch. Recipient of the 1982 Netherlands Biannual Award for Publications on Taxation; Chairman of the Board of the Association of European Tax Professors; author of books and articles on international tax law; and frequent speaker at international conferences, seminars and symposia.
Business Operations The Netherlands (Portfolio 973)
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A. Duane Webber, Esq.A. Duane Webber, Kansas State University (B.A., B.S. 1981); Georgetown University (J.D. 1984); Member, Section of Taxation (Court Procedure Committee) and Section of Litigation of the American Bar Association; Member, Taxation Section of the Federal Bar Association; Member, J. Edgar Murdock American Inn of Court.
Transfer Pricing: Judicial Strategy and Outcomes (Portfolio 888) Francis J. Wirtz, Esq.Francis J. Wirtz, B.S. (accountancy) University of Illinois (with honors 1975); J.D. University of Michigan Law School (cum laude 1979); certified public accountant; Chairman of Subcommittee on International Taxation of Partnerships, S Corporations and Trusts, Committee on Foreign Activities of U.S. Taxpayers; frequent speaker and writer on federal tax issues.
Partners and Partnerships — International Tax Aspects (Portfolio 910) Steven C. Wrappe, Esq.Steven C. Wrappe, Esq., New York University School of Law, LL.M. (Taxation) (1988); University of Texas School of Law, J.D. (1985); University of Notre Dame, Bachelor of Business Administration (1980). Member, State Bar of Texas; Certified Public Accountant. Partner, National Transfer Pricing Team, Deloitte & Touche LLP, Washington, D.C. Formerly, IRS APA Program attorney. Internationally–recognized speaker on the resolution of transfer pricing disputes, with speeches before the Tax Executives Institute, American Bar Association, and Federal Bar Association. Adjunct faculty member at George Mason University Law School, teaching International Tax, and guest lecturer in the LL.M. Program at New York University School of Law.
Transfer Pricing: Records and Information (Portfolio 891)
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Sophia H. H. YehSophia H. H. Yeh, National Taiwan University, Taipei (LL.B., 1980); University of Pennsylvania Law School (LL.M., 1987); senior counselor at Lee and Li, Attorneys-at-Law (1981–present ); co-leader of projects for Amendments to the Company Act, Amendments to Mechanisms for Merger and Acquisition and Share Swap, Knowledge-based Economy Related Legal Framework Research, Strategy Planning for Establishing Taiwan as a Global or Asian Resource Integrator, Securitization of Assets; Co-writer of the Taxation of Income Derived from the Supply of Technology (IFA), Model Acquisition Asset Purchase Agreement (ABA).
Business Operations in the Republic of China (Taiwan) (Portfolio 958) Dong Jun YeoDong Jun Yeo, Tax Attorney, Kim & Chang; Seoul National University, College of Social Science, International Economics (B.A., 1980); University of Illinois, Urbana-Champaign (M.A. in Accounting, 1987); Employment, Tax practice in Korea (1981-1985), tax practice, New York (1987-1992); Member, Korean Institute of Certified Public Accountants, American Institute of Certified Public Accountants. Languages: Korean and English.
Transfer Pricing: Foreign Rules and Practice Outside of Europe, Part 2 (Portfolio 898) Lowell D. Yoder, Esq.Lowell D. Yoder, B.A. (1979, with highest distinction) and J.D. (1982, magna cum laude), University of Illinois; Order of the Coif; Law Review Editor; Law Clerk, The Honorable James M. Sprouse, Federal Court of Appeals for the Fourth Circuit; frequent lecturer on international tax topics; author of numerous articles on international taxation; member of the Tax Management International Journal Advisory Board, member of the Editorial Board of the Journal of International Taxation, and member of the University of Chicago Law School's Federal Tax Conference Planning Committee; Adjunct Professor of Law at Chicago-Kent College of Law, teaching International Taxation.
CFCs — Foreign Personal Holding Company Income (Portfolio 927)Subpart F—General (Portfolio 926)CFCs — Foreign Base Company Income Other than FPHCI (Portfolio 928)CFCs — Sections 959-965 and 1248 (Portfolio 930)
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Howard M. Zaritsky, Esq.Howard M. Zaritsky, B.A., Emory University (1970); J.D., Stetson University College of Law (1973); LL.M. (Taxation), Georgetown University Law Center (1976); Consulting Counsel; member, Virginia State Bar; BNA Tax Management Advisory Board on Estates, Gifts and Trusts; University of Miami (Heckerling) Estate Planning Institute Advisory Committee; author or co-author, numerous articles and several treatises, including: Tax Planning for Family Wealth Transfers, Generation-Skipping Transfer Taxes: Analysis with Forms (with Carol Harrington & Lloyd Leva Plaine); Structuring Buy-Sell Agreements (with Farhad Aghdami & Mary Ann Mancini); Structuring Estate Freezes After Chapter 14 (with Ron Aucutt); Federal Income Taxation of Estates and Trusts (with Robert Danforth & Norman Lane); Tax Planning With Life Insurance (with Stephan Leimberg) — all published by Warren, Gorham & Lamont/RIA Group; tax editor, Probate Practice Reporter; Fellow, the American College of Trust and Estate Counsel and American College of Tax Counsel; former Chair, Virginia Bar Association Section on Wills, Trusts & Estates; lecturer, numerous Tax and Estate Planning Institutes, including Institutes of the University of Miami (Heckerling Institute), New York University, Georgetown University, Duke University, and the University of Southern California.
Grantor Trusts: Sections 671-679 (Portfolio 858)Revocable Inter Vivos Trusts (Portfolio 860)U.S. Taxation of Foreign Estates, Trusts and Beneficiaries (Portfolio 854)U.S. Taxation of Foreign Estates, Trusts and Beneficiaries (Portfolio 911)
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Mario J. Andrade PerillaMario J. Andrade P., Universidad Autonoma de Mexico (LL.M. in Corporate Law; M.Sc. in Public Finance); Pontificia Universidad Javeriana (J.D.); Professor of Law, Pontificia Universidad Javeriana (Bogota); Adjunct Professor, Universidad de Nuestra Senora del Rosario (Bogota); member, Colombia Tax Law Institute; member, American Bar Association; Licensed to practice law in the Republic of Colombia; President of International Fiscal Association (IFA) — Colombian Chapter.
Business Operations Colombia (Portfolio 956) Abel Adolfo Atchabahian, Dr.Adolfo Atchabahian, Special Consultant to Tax Management, Doctor in Economic Science, University of Buenos Aires; former Judge of the National Tax Court in Argentina (1960-1967) and Professor of Public Finance and Tax Law at the University of Buenos Aires (1957-1967 and 1980-1983); tax expert and Director at the Office of Public Finance of the Organization of American States (1967-1976); former consultant at the U.N. Center on Transnational Corporations; consultant of the Inter-American Development Bank and the International Monetary Fund; member of the International Fiscal Association and former member of its Permanent Scientific Committee; member and former president of the Argentinean Association of Fiscal Studies; author of several books and many articles published in Argentina and abroad relating to economic, public accounting and tax matters; former chief editor of Derecho Fiscal and Derecho Tributario (1981-1998), monthly tax reviews, and Impuestos Nacionales, a loose-leaf publication updated fortnightly (1984-1998); Director of Periódico Económico Tributario, a fortnightly publication, published in Buenos Aires under the auspices of Editorial La Ley-Thomson (2003- ); and Professor of Tax Law in graduate courses for lawyers and certified public accountants in different public and private universities throughout Argentina.
A Strategic Approach to SEC Investigations (Portfolio 5504)Accounting Ethics: Sources and General Applications (Portfolio 5508)Accounting by Partnerships (Portfolio 5209)Accounting Policy & Practice SeriesBusiness Operations Argentina (Portfolio 950) Ernest F. Aud, Jr. Esq.Ernest F. Aud, Jr., B.B.A., University of Notre Dame (1965); J.D., Indiana University (1968); member, Indiana Bar; Certified Public Accountant (Illinois and Indiana); frequent lecturer and author of articles on international taxation and intercompany pricing, and member, World Trade Institute Tax Advisory Panel.
The Possessions Tax Credit Under Section 936 (Portfolio 933) Reuven S. Avi-YonahReuven S. Avi-Yonah (B.A., Hebrew University, 1983; Ph.D., Harvard University, 1986; J.D., Harvard Law School, 1989) is Assistant Professor of Law, Harvard Law School, where he teaches domestic and international taxation. Mr. Avi–Yonah is a member of the New York and Massachusetts bars and co–chairs the tax policy committee of the New York State Bar Association Tax Section. He participated in preparing the Tax Section's reports on proposed legislation on amortization of intangibles and has published several articles and comments on the leading Supreme Court case in this area, Newark Morning Ledger Co. v. United States, 113 S. Ct. 1670 (1993).
The Attribution Rules (Portfolio 554)Collapsible Corporations (Portfolio 793)Transfer Pricing: Judicial Strategy and Outcomes (Portfolio 888)
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Gregory L. Barton, Esq.Gregory L. Barton, University of Notre Dame, B.S. (1980); University of Southern California, M.S. (1981); University of Chicago, J.D. (1985); former attorney–advisor, Office of Management and Budget; law clerk, U.S. Court of Appeals for the Seventh Circuit, Judge Richard A. Posner (1985–86); former lecturer, World Trade Institute and University of Southern California Tax Institute; former panelist, Northwestern University Transfer Pricing Conference; member, American Bar Association, Section of Taxation, Committee on Foreign Activities of U.S. Taxpayers; admitted to practice, Illinois, U.S. District Court for the Northern District of Illinois, U.S. Court of Federal Claims, and U.S. Tax Court.
Transfer Pricing: Records and Information (Portfolio 891) David M. Benson, Esq.David M. Benson, B.B.A., George Washington University (1971); J.D., Brooklyn Law School (1974); member, District of Columbia Bar; former Chair, AICPA International Tax Committee; formerly Technical Advisor to Associate Chief Counsel (Technical), Internal Revenue Service, Washington, D.C.; regular contributor to Tax Management International Journal.
The Possessions Tax Credit Under Section 936 (Portfolio 933) Renato Berger, Esq.Renato Berger, consultant, TozziniFreire, Teixeira e Silva Advogados, São Paulo, Brazil; University of São Paulo School of Law (LL.B., 1995); Georgetown University Law Center (LL.M., 1997).
Business Operations Brazil (Portfolio 954) Thomas St. G. Bissell, Esq.Thomas St.G. Bissell, B.A., Harvard College (1964); LL.B., Columbia Law School (1967); LL.M. in Taxation, New York University (1971); Member, New York Bar; Certified Public Accountant, State of New Jersey; Member, Tax Management International Advisory Board, American Bar Association, American Institute of Certified Public Accountants, International Fiscal Association, Canadian Tax Foundation; former Attorney-Advisor, Office of International Tax Counsel, US Treasury Department, Washington, D.C.; retired tax partner, Coopers & Lybrand LLP; author of numerous articles in professional tax publications.
U.S. Income Taxation of Nonresident Alien Individuals (Portfolio 907)International Aspects of U.S. Withholding on Wages and Service Fees (Portfolio 916)International Aspects of U.S. Social Security and Unemployment Taxes (Portfolio 917)Aliens Who Invest the United States Through a Low-Tax Jurisdiction (Portfolio 944)Controlled Foreign Corporations — Section 956 (Portfolio 929) Marc P. Blum, Esq.Marc P. Blum, A.B., Yale 1964; L.L.B., Columbia Law, 1967; Ph. D., Columbia Business 1969; member Maryland Bar, ABA; CPA; Of Counsel, Gordon, Feinblatt, Rothman, Hoffberger & Hollander, LLC, Baltimore, Maryland; CEO, World Total Return Fund, LLLP; Committee/Board member, Davis Funds, Clinical Trials & Surveys Corp., Rodney Trust Company, Legg Mason Investment Counsel & Trust Co., The Associated: Jewish Community Federation of Baltimore, McDonogh School, Kennedy Krieger Institute, Latin American Studies Association, College of Notre Dame of Maryland, Commonfund Private Capital, LifeBridge Health, Baltimore Courthouse and Law Museum Foundation, Inc., Maryland Research Institute; several private foundations and private capital funds; author of various articles on tax issues and estate planning.
Reporting Requirements Under the Code for International Transactions (Portfolio 947) Slawomir BorucSlawomir Boruc graduated from the Department of Law and Administration at the University of Warsaw in 1992. He has been working for Baker & McKenzie since July 1992, specializing in resolving tax law problems. He has advised many firms, including firms in the IT, chemicals, and printing and textile industries, and one of the largest telecommunications companies in the world. He has represented clients before tax authorities and in tax cases before the Supreme Administrative Court. He is a member of the Warsaw District Chamber of Legal Advisors and of the National Chamber of Tax Advisors.
According to Practical Law Company (PLC 2005, 2006 and 2007), Slawomir Boruc is a recommended Tax Advisor. Chambers Global 2006 and 2007 refers to him as a co-head of the best tax group in Poland. Additionally, Legal 500 has listed him individually each year since 2003. According to European Legal Experts 2007, Slawomir Boruc is a leading tax advisor in Poland. In Practical Law Company 2007/2008, he was recognized as the best lawyer in tax law in Poland. He was also awarded by International Financial Law Review (IFLR1000) 2007/8 in tax advisory.
Business Operations Poland (Portfolio 979) Luis F. Briones, Esq.Luis Briones Fernández, born Madrid, Spain, 1954; admitted to Madrid Bar; education: Deusto University, Bilbao, Spain (Law Degree, 1976); ICADE, Madrid, Spain (MBA, 1978); Harvard University, USA (LL.M. and International Tax Program, 1986).
Business Operations Spain (Portfolio 984) Charles M. Bruce, Esq.Charles M. Bruce, B.A., Washington & Lee University; J.D., George Washington University Law Center; member, The District of Columbia Bar, American Bar Association (Section of Taxation, Committee on Foreign Activities of U.S. Taxpayers), International Fiscal Association, International Bar Association (Section of Business Law, Taxation Committee); formerly, Counsel, Senate Finance Committee, Attorney–Advisor, United States Tax Court, Adjunct Professor, Georgetown University Law Center, and Visiting Professor, Institut für Auslandishes und Internationales Finanz und Steuerwesen.
Foreign Sales Corporations (Portfolio 934) Frederick R. Burke, Esq.Frederick R. Burke is a managing partner of Baker & McKenzie LLP's Vietnam offices. He obtained his Bachelor of Arts Degree with Honors from Stanford University, his Juris Doctor Degree from Columbia University School of Law and his Masters Degree of International and Public Affairs from Columbia University School of International Affairs. He was admitted to practice in New York (1987) and Washington, D.C. (1988) and registered as a foreign lawyer in Vietnam since 1996. Fred Burke has almost twenty years' experience in the planning, negotiation and operation of foreign investment projects as well as in the related issues of trade, securities, finance, construction, taxation, regulatory compliance, labor, intellectual property and technology transfer. He is currently a Vice Chairman of the Executive Committee of Hong Kong Business Association in Vietnam, Co-Chairman of the Executive Committee of the Vietnam Business Forum and Senior Advisor, and Chairman of the Legal Committee of the American Chamber of Commerce in Vietnam. Languages: English, Mandarin, Vietnamese, French, German and Italian.
Business Operations Vietnam (Portfolio 994) Herbert BuzanichHerbert Buzanich, University of Vienna (Master of Laws 1998); Doctor of Jurisprudence (2001); LL.M. International Tax (NYU 2004); member, Austrian Bar; member, New York State Bar; member, International Fiscal Association.
Business Operations Austria (Portfolio 952)
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Massimo G. Calderan, Esq.Massimo G. Calderan, University of Zürich (lic. iur., 1986); admitted to bar (Zürich 1991, St. Gallen 1995 and Zug 1995); member, Swiss, Zürich and International Bar Association; Association Internationale des Jeunes Avocats (“AIJA”), Swiss-Italian Chamber of Commerce (Zürich), Swiss-Spanish Chamber of Commerce (Zürich).
Business Operations Switzerland (Portfolio 986) German CamposGermán Campos, Universidad de Santiago de Chile (Certified Public Accountant, 1989, and Commercial Engineer, 1992); Professor, Universidad de Chile, Pontificia, Universidad Católica de Chile, and Universidad de Santiago de Chile; Member, Instituto de Derecho Tributario and International Fiscal Association.
Business Operations Chile (Portfolio 997) John L. Carr, Jr. Esq.John L. Carr, Jr., B.S., Auburn University (1969); J.D., University of Georgia (1978); Editor, University of Georgia Law Review (1977-78); member, International Fiscal Association.
Indirect Foreign Tax Credits (Portfolio 902) Karen E. CederothKaren E. Cederoth, B.S., Eastern Illinois University; M.A., taxation, DePaul University; tax partner, International Tax Service Line, Deloitte Tax LLP, Chicago, Illinois; formerly with Arthur Andersen, Chicago; formerly with Container Corporation of America, responsible for international compliance; Instructor, DePaul University, Masters in Tax Program.
The Allocation and Apportionment of Deductions (Portfolio 906) Clark J. Chandler, Ph. D.Clark J. Chandler, Dickinson College, B.A. (1974); University of Michigan, M.A. and Ph.D., Economics (1978). Dr. Chandler is a principal with KPMG LLP's Washington national Tax/Economic Consulting Services practice. He has testified extensively and worked for both tax authorities and multinational corporations in the area of international transfer pricing.
Transfer Pricing: Economic, Managerial, and Accounting Principles (Portfolio 889) C. V. ChenC. V. Chen, Managing Partner, admitted 1975, Member of Taipei and Kaohsiung Bar Associations, R.O.C.; Education: S.J.D., Harvard Law School (1972); LL.M., Harvard & University of British Columbia; LL.B., National Taiwan University. Experience: Managing Partner and CEO, Lee and Li Attorneys-at-Law, Taipei, Taiwan; Member of the Committee of Taxation Policy and Regulation Consultation, Ministry of Finance, R.O.C.; Adjunct Professor of Law, National Chengchi University & Soochow University Graduate School of Law (1972–present), Taiwan; Lecture Professor of Law at the Management Schools of Peking University and Tsinghua University, China; President, (April 2000–present), The Red Cross Society of the Republic of China; Chairman, Taipei European School Foundation, Taiwan, Republic of China (1994–present); Director (December 1993–present), Vice Chairman (February 1992–December 1993), first-term Vice Chairman & Secretary General (November 1990–February 1992), Straits Exchange Foundation; Director, Lee and Li Foundation; President, The Chinese Society of International Law (January 2004–present); Board of Director, Yuan Ze University (Taiwan) (1990–present); Honorary President, Harvard Club of Republic of China on Taiwan (1989–present); Numerous articles on transnational legal problems.
Business Operations in the Republic of China (Taiwan) (Portfolio 958) Bernard ChesnaisBernard Chesnais obtained Master degrees in general law studies (University of Bretagne – Rennes, 1969), sociology (University of Bretagne – Rennes, 1970), and tax law (Ecole Nationale des Impôts), as well as a Diplôme d'Etudes Comptables Supérieures (Ecole Nationale des Impôts). He is a former tax inspector at the Direction des Vérifications Nationales et Internationales; partner, Salans.
Business Operations France (Portfolio 961) Robert T. Cole, Esq.Robert T. Cole, B.S., Wharton School of Finance, University of Pennsylvania (1953); LL.B., Harvard Law School (1956); Academic Postgraduate Diploma in Law, London School of Economics (1959); senior counsel in the Washington, D.C. office of Alston & Bird LLP; former member of Cole Corette & Abrutyn; former International Tax Counsel of the U.S. Treasury Department; editor and principal author of Practical Guide to U.S. Transfer Pricing.
Income Tax Treaties — Administrative and Competent Authority Aspects (Portfolio 940) Peter J. Connors, Esq.Peter J. Connors, B.A., Catholic University; J.D., University of Richmond; LL.M (in Taxation), New York University School of Law; Senior Tax Accountant, Arthur Andersen & Co.; Attorney, Tax Department, Bondy & Schloss; Tax Manager, J.C. Penney & Co.; Senior Manager, KPMG; Principal and Director of International Capital Markets Tax Services, Ernst & Young LLP; Tax Partner, Baker & McKenzie (1995 to 2001); CPA (New York).
The Mark-To-Market Rules of Section 475 (Portfolio 543)The Branch-Related Taxes of Section 884 (Portfolio 909) Joseph J. Czajkowski, Esq.Joseph J. Czajkowski, Georgetown University (B.A., 1971); studied in the Faculty of Law, University of Fribourg (Switzerland); Boston College Law School (J.D., 1975); Georgetown University Law Center (LL.M. Taxation, 1979); admitted to bar, District of Columbia (1976), Texas (1992); member, American Bar Association Section on Taxation, International Fiscal Association, and Tax Chapter Board of the Swiss-American Chamber of Commerce (Zürich).
Business Operations Switzerland (Portfolio 986)
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Roland S. Dahlman, Esq.Roland S. Dahlman, LL.B. 1970 and LL.D. 2006 (Stockholm), LL.M. 1974 (Harvard University); Advokat. Member of the Swedish Bar and of Dahlman Advokatbyrå, Stockholm, Sweden.
Business Operations Sweden (Portfolio 985) Bruce N. Davis, Esq.Bruce N. Davis, B.A., University of Virginia (high honors 1980, Phi Beta Kappa); J.D., Harvard Law School (1983); LL.M. (in taxation), Southern Methodist University (1987); Former Chairman, Subcommittee on §§338, 367 and 1491, Committee on Foreign Activities of U.S. Taxpayers, American Bar Association; Principal Special Assistant to the Associate Chief Counsel (International), Internal Revenue Service (1988-1991); member of board of advisors of various international tax publications, and frequent speaker and writer on international tax issues.
Outbound Transfers Under Section 367a (Portfolio 919)Other Transfers Under Section 367 (Portfolio 920) Mario A. de CastroMario A. de Castro, University of Miami School of Law (LL.M. in Taxation); Temple University of Law (J.D. 1994); Tulane University (B.A. 1990); member, American Bar Association; member, Florida Bar; Licensed to practice law in the State of Florida, U.S. Court of Appeals for the Eleventh Circuit, United States Tax Court; United States District Court for Southern District of Florida, and in the Republic of Colombia (pursuant to ICFES Resolution issued 1999).
Business Operations Colombia (Portfolio 956) Jocelyn Delsouiller, Esq.Jocelyne Delsouiller, graduated 1972 Geneva, Swtitzerland, admitted to the Geneva Bar 1974, legal counsel in Paris, 1979. admitted to the Paris Bar 1992. Corporate partner Campbell, Philippart, Laigo & Associes, Paris, France.
Business Operations France (Portfolio 961) Brett R. Dick, Esq.Brett R. Dick, B.A., University of Michigan (1967); J.D., University of Michigan Law School (1970); member, American Bar Association, Section of Taxation, Committee on U.S. Activities of Foreigners and Tax Treaties, Subcommittee on Source of Income; member, State Bar of California, Foreign Taxation Subcommittee; member, San Francisco Foreign Tax Club; member, San Francisco Tax Club; speaker at various conferences on international taxation.
U.S. Income Taxation of Foreign Governments, International Organizations and Their Employees (Portfolio 913) William G. DodgeWilliam G. Dodge, University of Georgia, Master of Accountancy (Tax) (1979); Walsh College, B.A. (1976); Director, Global Transfer Pricing Team; Co–Director, U.S. Transfer Pricing Team, Deloitte & Touche LLP, Washington, D.C. Formerly Partner–in–Charge, U.S. Corporate Tax Group, Deloitte & Touche, London, England. Member, Tax Management Advisory Board (Transfer Pricing). Mr. Dodge is regular speaker at seminars and has worked in New York, London, and Tokyo where he served many of Deloitte & Touche's largest U.S. and non–U.S. clients.
Transfer Pricing: Records and Information (Portfolio 891) D. Kevin Dolan, Esq.D. Kevin Dolan, B.A., University of Virginia; J.D., University of Michigan; Senior Vice President for Tax Policy, Merrill Lynch & Co.; former partner, Weil, Gotshal & Manges LLP; former Associate Chief Counsel (Technical and International), Internal Revenue Service; former partner, Arthur Young and Co., Washington, D.C.; former Attorney-Advisor, Office of International Tax Counsel, U.S. Treasury Department.
The Creditability of Foreign Taxes — General Issues (Portfolio 901) Carolyn M. DuPuy, Esq.Carolyn M. DuPuy, B.A., Mount Holyoke College; J.D. and M.L.T., Georgetown University Law Center; partner, Weil, Gotshal & Manges LLP; former Senior Technical Reviewer, Office of the Associate Chief Counsel (International), Internal Revenue Service.
The Creditability of Foreign Taxes — General Issues (Portfolio 901)
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Howard E. Engle, CPAHoward S. Engle, B.S., University of Illinois; M.S., taxation, DePaul University; partner, Deloitte Tax LLP, Chicago, Illinois; Visiting Lecturer, Graduate Tax Program, University of Illinois; frequent speaker on international tax issues; editor, International Tax Developments column, Journal of Corporate Taxation; author, numerous articles on international tax.
The Allocation and Apportionment of Deductions (Portfolio 906) Joseph M. Erwin, Esq.Joseph M. Erwin, University of Arkansas, B.A. (with honors), 1976; Southern Methodist University School of Law, J.D., 1979, LL.M. (Taxation), 1980. Member of the bars of Arkansas, Texas, U.S. Virgin Islands, U.S. Tax Court, U.S. Court of International Trade, U.S. Court of Appeals for the Third Circuit, U.S. Court of Appeals for the Eighth Circuit. Private law practice, Little Rock, Arkansas, 1980-1991. Assistant Attorney General (Tax), U.S. Virgin Islands Department of Justice, 1991-1994. Private law practice, St. Thomas, 1994-1996. Tax Manager, CSC Continuum Inc., 1996-1997. Senior Manager, International Corporate Services, KPMG LLP, Austin, Texas, 1997-1998, Dallas, Texas, 1998-2000 and 2002-2003; Senior Manager, KPMG Deutsche Treuhand-Gesellschaft AG, U.S. Corporate Tax Group, Frankfurt am Main, Germany, 2000-2002.
Business Operations in the Territories and Possessions of the United States (except Puerto Rico) (Portfolio 995)
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Pascal Faes, Esq.Pascal Faes, JD, University of Ghent (1984); Special Degree in Economics, University of Brussels (V.U.B.) (1987); Master in Tax Law, University of Brussels (U.L.B.) (1991).
Business Operations Belgium (Portfolio 953) Jayson L. FernandezJayson L. Fernandez, A.B. (1991) and J.D. (1995), second honors, Ateneo de Manila University; Senior Associate, specializing in taxation, Romulo, Mabanta, Buenaventura, Sayoc & de los Angeles and member, Tax Management Association of the Philippines.
Business Operations the Philippines (Portfolio 978) Jose Luis de Salles Freire, Esq.José Luis de Salles Freire, partner, TozziniFreire, Teixeira e Silva Advogados, São Paulo, Brazil; University of São Paulo School of Law (LL.B., 1971); Southwestern Legal Foundation (Academy of American and International Law, 1975) and New York University School of Law (M.C.J., 1976). Member of the Advisory Board of the International and Comparative Law Center of the Southwestern Legal Foundation.
Business Operations Brazil (Portfolio 954)
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James M. Gannon, CPAJames Gannon, B.S., University of Illinois; B.A., accountancy, M.A., public accounting-tax, University of Texas at Austin; tax partner, Washington International Tax Group, Deloitte Tax LLP, 2002–present; partner, Arthur Andersen, 1998-2002, staff, Arthur Andersen, 1987-1998; member, AICPA and Illinois Society of CPAs.
The Allocation and Apportionment of Deductions (Portfolio 906) Marc D. Ganz, J. D. LL. M.Marc D. Ganz, B.A., University of Wisconsin - Madison (1991); J.D., A.C. in International Affairs, Washington University (1994); LL.M. in Taxation, New York University (1995); formerly Attorney-Advisor to the Honorable William M. Fay, U.S. Tax Court, Washington, D.C.; Member of the New York Bar; Member of the Telecommunications Tax Forum.
U.S. International Taxation of Telecoms (Portfolio 946) Brian S. Gleicher, Esq.Brian S. Gleicher, B.S., University of Florida, Fisher School of Accounting (with high honors, 1992); J.D., Georgetown University Law Center (cum laude, 1995). Lead Articles Editor, Tax Lawyer (1995); Chairman of the Federal Bar Association Section of Taxation (2002-2003); Chairman of the Federal Bar Association Section of Taxation's 26th Annual Tax Law Conference (2001); Editor-in-Chief of the Federal Bar Association Section of Taxation Tax Report (1997-2000); Member of the American Bar Association and the District of Columbia and Florida Bars.
IRS Procedures: Examinations and Appeals (Portfolio 623)Transfer Pricing: Records and Information (Portfolio 891) Peter A. Glicklich, Esq.Peter A. Glicklich is a partner resident in the New York office of Davies, Ward, Phillips & Vineberg LLP. His practice is concentrated on the taxation of corporate and international transactions. He advises public and closely held corporations in connection with mergers and acquisitions, cross-border financings, restructurings, reorganizations, spin-offs and intercompany pricing. Mr. Glicklich has dealt with companies in diverse fields, including chemicals, consumer products, real estate, biotechnology, software, telecommunications, pharmaceuticals and finance. As well he has worked with venture funds, investment banks, hedge funds, commodities and securities dealers and insurance companies. He is a contributing editor of the Tax Management International Journal, the Canadian Tax Journal, the Journal of Taxation of Global Transactions, and the International Tax Review, and is a former contributing editor of the Journal of Real Estate Taxation.
Mr. Glicklich has written numerous articles on cross-border financing, net loss carryovers, bankruptcy restructurings, the use of conduits, transfer pricing, loss importation, and taxation of internet activities. He also speaks frequently on international and corporate tax topics. Mr. Glicklich presently serves as the New York Regional Vice-President and an Executive Committee member of the USA Branch of the International Fiscal Association, and he is a past Secretary of that Committee. He is also a member of numerous bar associations. Mr. Glicklich received an honors degree from the University of Wisconsin - Madison in 1977 and received his J.D. cum laude from Harvard Law School in 1981.
U.S. Taxation of International Shipping and Air Transport Activities (Portfolio 945) Joseph R. Goeke, Esq.Joseph R. Goeke, Xavier University, B.S. (1972); University of Kentucky, J.D. (1975); former Special International Trial Attorney, Internal Revenue Service; frequent lecturer, including Tax Executives' Institute, World Trade Institute, Georgetown University Law Center, National Foreign Trade Council, and International Fiscal Association; member, American Bar Association, Section of Taxation; admitted to practice, Kentucky, Illinois, U.S. District Court for the Northern District of Illinois, U.S. Court of Federal Claims, and U.S. Tax Court.
Transfer Pricing: Records and Information (Portfolio 891) Sandra M. GoldbergSandra Goldberg, LL.B., University of Ottawa, 1982; Associate Partner, Deloitte & Touche LLP, Ottawa, Ontario; member Law Society of Upper Canada since 1984, Canadian Tax Foundation, International Fiscal Association; speaker on transfer pricing issues; author, articles on transfer pricing, competent authority and permanent establishments; named in Euromoney’s 2008 list of World’s Leading Transfer Pricing Advisors.
U.S. Income Tax Treaties — Competent Authority Functions and Procedures of Selected Countries (Portfolio 941) Murray L. Gordon, Esq.Murray L. Gordon, B.A. (cum laude), Brandeis University (1970); J.D., Loyola University (1975); LL.M. (Taxation), New York University (1976); member, Illinois Bar; Certified Public Accountant (Illinois); frequent lecturer on domestic and international corporate taxation, and member, World Trade Institute Tax Advisory Panel.
The Possessions Tax Credit Under Section 936 (Portfolio 933) Richard A. Gordon, Esq.Richard A. Gordon, B.A., New York University, 1964; LL.B., Duke University, 1967; tax principal, Washington International Tax Group, Deloitte Tax LLP, 2002-2005 (retired); tax partner, Director of International Specialty, Arthur Andersen, Washington, D.C., 1985-2002; Deputy Chief of Staff and International Tax Counsel, Joint Committee on Taxation, United States Congress, 1981-1985; Special Counsel for International Taxation, Internal Revenue Service, and Assistant to the Commissioner of Internal Revenue Service, Washington, D.C., 1979-1981; Associate, White & Case, Washington, D.C., 1976-1979; Attorney-Advisor, Office of International Tax Counsel, Office of Assistant Secretary of the Treasury (Tax Policy), 1972-1976; Attorney-Advisor, Legislation and Regulations Division, Office of the Chief Counsel, Internal Revenue Service, 1970-1972; Associate, Reynolds, Richards, LaVenture, Hadley & Davis, New York, 1967-1970; member, ABA; author and speaker on international tax issues.
The Allocation and Apportionment of Deductions (Portfolio 906)Foreign Corporation Earnings and Profits (Portfolio 932) Bruno GouthiereBruno Gouthiere, Ecole Nationale d´Administration, the University of Paris, Master in Law and BS in Economics, and the Institut d'Etudes Politiques of Paris; partner with CMS Bureau Francis Lefebvre, international tax department, since 1989; previously, he was acting as Chief of Staff, International Tax Relations, Tax Policy Department, Ministry of Finance; author of reference books in international tax law, such as “Les Impôts dans les affaires internationales”, "Les Holdings", "Transfer Pricing Rules and Practice in France" (Tax Management, BNA), "Advance Rulings in France" (IBFD), "The International Guide to Holding Companies" (IBFD), co-author of various books on “Wealth” (Memento du Patrimoine), “Civil Companies” (Memento Sociétés Civiles), and of numerous articles in French and foreign legal, tax and financial reviews; member of various associations of tax practitioners such as the International Fiscal Association (“IFA”) and the Fiscal Committee of the European Fiscal Confederation (“CFE”).
Transfer Pricing: European Rules and Practice (Portfolio 895) Corrado GuerraCorrado Guerra, Law Degree, University “La Sapienza” (1996); LL.M. (International, European and Comparative Law), Vrije Universiteit Brussel (2000); previously associated with Morgan, Lewis & Bockius, Lovells Boesebeck Droste and Jones Day, Brussels, Belgium.
Business Operations the European Union (Portfolio 999)
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Steven P. Hannes, Esq.Steven P. Hannes, Amherst College, B.A. (1967); New York University School of Law, J.D. (1970); formerly Associate International Tax Counsel, Department of the Treasury; Group Chief, Corporation Tax Branch, Internal Revenue Service; Member of National Council and Vice President (Washington Region), International Fiscal Association; member, District of Columbia Bar Association, American Bar Association, Tax Committee of National Foreign Trade Council.
Bertrand M. Harding, Jr. Esq.Bertrand M. Harding, Jr., Duke University (1968); J.D., The George Washington University National Law Center (1975); former Tax Law Specialist, Internal Revenue Service Exempt Organizations Division (1972-1975); former attorney-advisor to Judge Bruce M. Forrester, United States Tax Court (1975-1977); former tax partner, Baker & McKenzie, Washington, D.C. office (1984-1996); lecturer on college and university tax matters; author, The Tax Law of Colleges and Universities, 2d ed., published by John Wiley & Sons, Inc.
U.S. Income Taxation of Foreign Students, Teachers, and Researchers (Portfolio 914) Kenneth L. Harris, Esq.Kenneth L. Harris, A.B. Hamilton College (summa cum laude 1982, Phi Beta Kappa); J.D. University of Chicago Law School (1985); LL.M. New York University School of Law (1988, Graduate Editor, Tax Law Review); Member of Committee on U.S. Activities of Foreign Taxpayers and Standards of Tax Practice; co-author of Standards of Tax Practice (4th Ed. 1997); frequent speaker and writer on federal tax issues.
Partners and Partnerships — International Tax Aspects (Portfolio 910) Sandra HazanSandra Hazan graduated from the University of Paris II (Maîtrise de Droit des Affaires et Fiscalité, 1990), the University of Paris I (DEA Droit Anglais et Nord-Américain des Affaires, 1991) and attended the LLM course at Queen Mary & Westfield College, London (1993); partner, Salans.
Business Operations France (Portfolio 961) Thijs J. M. HeijenrathThijs Heijenrath, University of Tilburg, Master’s in tax law; certified tax advisor and member of the Dutch Tax Advisors Association (NOB); member of the Global Transfer Pricing Strategy board of Deloitte; international tax partner with Deloitte Belastingadviseurs BV, Netherlands affiliate of Deloitte Touche Tohmatsu, based in Rotterdam. Mr. Heijenrath leads Deloitte's Transfer Pricing / Tax-Aligned Supply Chain group in the Netherlands and is an active member of the Global Transfer Pricing Strategy board of Deloitte.
U.S. Income Tax Treaties — Competent Authority Functions and Procedures of Selected Countries (Portfolio 941) Francisco R. Hernández-Ruiz, Esq.Francisco Hernández-Ruiz, B.S.B.A., Boston College (1962); L.L.B. University of Puerto Rico School of Law (1965); L.L.M. (in Taxation), New York University Law School (1972); Assistant Professor of Tax Law, Interamerican University School of Law (1984–1988); Assistant Professor of Taxation, University of Phoenix (1994–1995); Member of the Board of Bar Examiners (1985–1986); Member of the Evaluating Committee of the Council of Higher Education for the Accreditation of the Graduate Law Program of Catholic University; Member of the Puerto Rico Bar Association; Member of Tax Committee of the Puerto Rico Chamber of Commerce; Member of the Tax Committee of the Puerto Rico Manufacturing Association; frequent lecturer on tax issues; author of various articles on tax laws.
Business Operations Puerto Rico (Portfolio 2650)Business Operations Puerto Rico (Portfolio 980) James Hickey, Esq.James P. Hickey, B.B.A., Western Illinois University; MST, DePaul University; member, American Institute of Certified Public Accountants; Illinois and Ohio CPA Societies; Adjunct Professor of Taxation, DePaul University Graduate School of Business, College of Commerce.
Foreign Sales Corporations (Portfolio 934) Robert F. Hudson, Jr. Esq.Robert F. Hudson, LL.M. (Taxation), New York University (1972); J.D., University of Florida (1971); B.S.B.A., Economics, University of Florida (1968); member, Florida and New York Bars; Chairman, S.E. Region, U.S.A. Branch of International Fiscal Assoc. (1984); Chairman, Foreign Tax Advisory Committee of Florida Bar, Tax Section (1983–1985); project chairman and a principal author of the Florida Bar's “Proposed Revisions of Pending FIRPTA Withholding Tax Bill (Feb. 10, 1984)” which was essential basis of Code Section 1445 enacted as part of the Deficit Reduction Act of 1984; Contributor to: Tax Management International Journal, Tax Management Real Estate Journal, Tax Planning International Review, Lawyer of Americas, American Bar Journal, Florida Bar Journal, Florida Bar International Law Quarterly; Speaker, World Trade Institute, International Fiscal Association — U.S.A. Branch, International Tax Planning Association, Florida Bar, Florida Institute of CPAs, Quebec Bar Assoc., University of Florida, University of Miami, Universite Laval, University of Netherlands Antilles, and University of Barbados.
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Geraldine Josephina, Esq.Geraldine C. Josephina, graduated in Dutch tax law from the University of Leiden, The Netherlands (1990); senior tax law practitioner, Loyens & Loeff, Curaçao, rendering advice on Netherlands Antilles and Aruba tax matters.
Business Operations The Netherlands Antilles (Portfolio 974)
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Akemi Kawano, Esq.Akemi Kawano, B.M., The Julliard School (1989), M.M., The Julliard School (1991), D.M.A., Manhattan School of Music (1999), J.D., with Honors, George Washington University Law School (2002); associate in the Washington, D.C. office of Alston & Bird LLP; serves as general counsel of the Japan America Society of Washington, D.C.
Income Tax Treaties — Administrative and Competent Authority Aspects (Portfolio 940) Larry R. Kemm, Esq.Larry R. Kemm, B.S. (1984), University of Missouri – Kansas City; J.D. (1992, summa cum laude), Indiana University School of Law; Associate Editor, Indiana Law Review; Certified Public Accountant (Texas); Board Certified, Tax Law, Texas Board of Legal Specialization (1997–2002); past Chair, Controlled Group Subcommittee, ABA Tax Section, Affiliated and Related Corporations Committee; frequent speaker on international tax subjects at various institutes and seminars; Treasurer and member of Steering Committee, Midwest Region, International Fiscal Association; admitted to practice, Texas, Illinois, U.S. Tax Court, and U.S. District Court for the Northern District of Texas.
CFCs — Sections 959-965 and 1248 (Portfolio 930) Lee Khvat, Esq.Lee Khvat is an associate in the law firm of McDermott Will & Emery UK LLP, based in its London office. He is a member of the Tax Department, where his practice focuses on a range of corporate tax matters.
Business Operations the United Kingdom (Portfolio 989) Woo Taik Kim, Esq.Woo Taik Kim, Seoul National University (B.A., 1970); Columbia University (M.B.A., 1972); tax partner, Kim & Chang, Seoul; Member, Korean Institute of Tax Attorneys, Korean Institute of Certified Public Accountants, New York State Society of Certified Public Accountants, International Fiscal Association.
Transfer Pricing: Foreign Rules and Practice Outside of Europe, Part 2 (Portfolio 898)Business Operations the Republic of Korea (Portfolio 970) Martha A. Klasing, CPAMartha A. Klasing, B.S., Southern Illinois University — Carbondale; Master of Accounting (Taxation), University of Missouri – St. Louis; Partner, KPMG LLP; Certified Public Accountant; member, American Institute of Certified Public Accountants; contributor: Tax Management International Journal; International HR Journal; Tax Management Compensation Planning Journal; frequent speaker on international tax issues and developments.
Section 911 and Other International Tax Rules Relating to U.S. Citizens and Residents (Portfolio 918) Adil K. KotwalAdil K. Kotwal, B.Com, F.C.A., Bachelor of Commerce, University of Bombay (1978), Fellow of the Institute of Chartered Accountants of India. He joined the firm in 1978 and is currently the Managing Partner and partner responsible for the firm's international and corporate finance practice. He has served as visiting faculty with the University of Bombay teaching Accountancy and Taxation.
Business Operations India (Portfolio 966) Kenneth J. Krupsky, Esq.Kenneth J. Krupsky, Tax Partner, Jones Day (Washington, DC); Columbia Law
School (J.D. 1972; Harlan Fiske Stone Scholar; International Fellow;
Columbia Law Review; Comments and Case Notes Editor, Columbia Journal of
Transnational Law); Columbia College (B.A. in Philosophy 1969; National
Merit Scholar). Served as Deputy Assistant Secretary of the Treasury for
Tax Policy, U.S. Treasury Department in President Clinton's second term,
Chair of the International Tax Committee of the District of Columbia Bar
Association, and Adjunct Professor at Georgetown University Law Center.
Member of Tax Management International Journal's "Panel of Leading
Practitioners" and regularly contributes to that journal. Other
publications include: Joint Ventures with International Partners (coauthor, Butterworth 1994); and International Joint Ventures coauthor, Federal Publications 1986; 2d ed. 1988). Regularly
listed as a leading tax lawyer in Chambers USA, Euromoney's International
Tax Review (one of the "world's leading tax advisers" and "world's leading
transfer pricing advisers"), and Super Lawyers.
Transfer Pricing: Alternative Practical Strategies (Portfolio 890) Kalle KylakallioKalle Kyläkallio, LL.B., 1993 (University of Lapland), Varatuomari, 1995 (“lawyer trained in the court”),Address: Susiluoto Attorneys-at-Law Ltd, Uudenmaankatu 16 B, 00120 Helsinki, Finland, Tel:+358 9 6869 110, Fax: +358 9 6869 1169
Business Operations Finland (Portfolio 960)
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Daniel S. LangeDaniel S. Lange, B.B.A., 1981, M.S., taxation, 1983, University of Wisconsin; managing partner, U.S. International Tax practice, Deloitte Tax LLP, 2002–present; tax partner, International Tax Specialty Team, Arthur Andersen, Milwaukee, Wisconsin, 1992-2002, manager, 1986-1991, staff, 1983-1985; member AICPA, WICPA; speaker, international tax issues; author, numerous articles on international tax issues.
The Allocation and Apportionment of Deductions (Portfolio 906)Foreign Corporation Earnings and Profits (Portfolio 932) Werner LedererWerner Lederer, University of Zürich (lic. iur., 1988); Swiss Certified Tax Consultant; member, Swiss Institute of Certified Accountants and Tax Consultants, International Fiscal Association, International Bar Association.
Business Operations Switzerland (Portfolio 986) Howard J. Levine, Esq.Howard J. Levine, B.A., Hunter College (1969); J.D., State University of New York at Buffalo (cum laude, 1972); LL.M. (Taxation), Georgetown University Law Center (1976); attorney and assistant branch chief, Office of Chief Counsel, Internal Revenue Service (1972-1976); adjunct lecturer in Real Estate Taxation, American University Law School (1980-1982); adjunct professor, The George Washington University Law School and Georgetown University Law Center LL.M. Tax Programs (1982-1993); contributing editor, The Journal of Real Estate Taxation; Tax Management Distinguished Author (2000); member, Advisory Board, Tax Management International Journal; member, Advisory Board, CCH Journal of Taxation of Global Transactions; author, 936 T.M., U.S. Income Tax Treaties — The Limitation on Benefits Article; partner, Roberts & Holland LLP, Washington, D.C. and New York, N.Y.; member, American Bar Association (Chairman, Committee on Sales, Exchanges and Basis, and Subcommittee Chairman, Like Kind Exchanges, Tax Section 1990-1994), New York Bar, District of Columbia Bar, International Fiscal Association.
U.S. Income Tax Treaties — The Limitation on Benefits Article (Portfolio 936) Edward H. Lieberman, Esq.Edward H. Lieberman, B.A., C.C.N.Y.; J.D., Brooklyn Law School; LL.M., London School of Economics; member, The District of Columbia and New York Bars and the American and International Bar Associations; formerly, Tax Law Specialist, IRS Corporation Tax Branch; author: “The Foreign Sales Corporation Issues and Answers Under the Temporary Regulations,” Tax Mgmt. Intl. J., March, 1985; “Analysis of the Foreign Sales Corporation — Temporary Regulations,” Tax Mgmt. Memo., February, 1986; “Foreign Sales Corporations — The Shape of Regs. to Come,” Tax Mgmt. Intl. J., January, 1987; and “Foreign Sales Transactions: A Prognosis for 1987,” Tax Mgmt. Memo., February, 1987. Member, IRS Commissioner's Advisory Group 1995–1996.
Foreign Sales Corporations (Portfolio 934) Howard M. Liebman, Esq.Howard M. Liebman, A.B. (summa cum laude), Colgate University (1974); A.M. (with distinction), Colgate University (1975); J.D. (cum laude) Harvard Law School (1977); Member, District of Columbia Bar and “B” List of the French-speaking Brussels Bar; Belgian Member, Tax Management International Forum; Contributing Editor, European Taxation; Editorial Advisory Board, Practical European Tax Strategies; Chairman, Legal & Taxation Committee, American Chamber of Commerce in Belgium.
Business Operations the European Union (Portfolio 999) Gregory P. Lubkin, Esq.Gregory P. Lubkin, University of Edinburgh (U.K.) (M.A. 1975); University of California, Berkeley (Ph.D. 1982); Harvard University (J.D. 1996); member, District of Columbia Bar and Section of Taxation of American and District of Columbia Bar Associations; contributor: Tax Management International Journal.
Source of Income Rules (Portfolio 905)
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Ewing W. Madole, Esq.Ewing W. Madole, B.A., M.B.A. Mississippi State University (1973, 1975); J.D., Columbia University School of Law (1985); LL.M. in Taxation, New York University (1990); Member of the New York Bar; Certified Public Accountant, Tennessee (1977).
Controlled Foreign Corporations — Section 956 (Portfolio 929) Jacques Malherbe, Esq.Jacques Malherbe, JD, University of Louvain (1962); LL.M., Harvard University (1964); Professor, University of Louvain; Visiting Professor, Universities of Paris II, Paris XII, Dijon, Vienna, Hamburg.
Business Operations Belgium (Portfolio 953) Petri ManninenPetri Manninen, LL.B., 1993 (University of Helsinki), Varatuomari, 1995 (“lawyer trained in the court”), LL.M. in European Community Law (University of Leiden), 1996.
Business Operations Finland (Portfolio 960) Patrick MarleyPatrick Marley, B.Comm., Queen's University; LL.B., University of Western Ontario; LL.M., New York University; Barrister and Solicitor of the Bars of Ontario and New York; Tax Partner, Osler, Hoskin & Harcourt LLP.
Business Operations Canada (Portfolio 955) Joel M. McDonaldJoel M. McDonald, B.S., summa cum laude, University of Alabama (1984); J.D., University of Virginia (1987); Advisor to the Russian Government on Tax Reform (1994-1997).
Business Operations Russia (Portfolio 981) Michael J. Miller, Esq.Michael J. Miller is a partner in the New York office of Roberts & Holland LLP. He counsels foreign-and-U.S. based multinationals regarding a wide range of tax issues pertaining to their cross-border activities. Michael co-authored 945 T.M., U.S. Taxation of International Shipping and Air Transport Activities, and has written numerous articles on international tax issues for the Tax Management International Journal, CCH Journal of Taxation of Global Transactions, and the Canadian Tax Journal. Michael is an active member of the U.S. Activities of Foreign Taxpayers and Tax Treaties Committee of the American Bar Association Tax Section. He received his B.A. cum laude from Columbia College in 1988 and his J.D. from New York University in 1991. He clerked on the U.S. Tax Court for the Honorable James S. Halpern from 1991-1993.
U.S. Income Tax Treaties — The Limitation on Benefits Article (Portfolio 936)U.S. Taxation of International Shipping and Air Transport Activities (Portfolio 945) Luis Fernando MirandaLuis Fernando Miranda, Universidad Central de Venezuela (Public Accounting, 1986); Columbia University (Professional Extension Program); Professor, Universidad Central de Venezuela; member, Tax Committee of Venamcham; former member, Committee of Coindustria.
Business Operations Venezuela (Portfolio 993) Jerrie V. Mirga Jerrie Varrone Mirga, College of William & Mary, B.A. (1979); George Washington University, MBA (1985) and post-MBA Certificate (2001); Vice President, Economic Consulting Services, LLC. Ms. Mirga advises clients on transfer pricing issues involving tangible and intangible property for planning, documentation and audit purposes.
Transfer Pricing: Economic, Managerial, and Accounting Principles (Portfolio 889) Michael C. Moetell, Esq.Michael C. Moetell, B.S. (cum laude), Villanova University (1982); J.D. (cum laude), Harvard Law School (1985); member, International Fiscal Association, American Bar Association's Section of Taxation, D.C. Bar Association's Tax Section.
Indirect Foreign Tax Credits (Portfolio 902) Gianmarco MonsellatoGianmarco Monsellato; graduate of the HEC Group, International Management School France; recognized as “Lead Tax Adviser” and “Lead Transfer Pricing Advisor” in all Euromoney Legal Media Group Surveys. Co-founder of the Transfer Pricing worldwide Deloitte team, his service line has been quoted n°1 Transfer Pricing Team in France, by the International Tax Review; co-author of the first French book on transfer pricing: Les prix de Transfert; wrote the French chapter in Transfer Pricing – an International Guide; author of numerous articles on international tax and transfer pricing in French and international reviews; is a member of the global transfer pricing task force of the International Chamber of Commerce; member of the IFA; member of the French-US Chamber of Commerce; has substantial experience in strategic tax planning, tax controversies, Advance Transfer Pricing Agreements and Competent Authority Procedures; is currently the Managing Partner (CEO) of Taj, an international tax and law firm in France, member of Deloitte Touche Tohmatsu and advises leading European, Japanese, Korean and US multinational companies in transfer pricing and international tax strategies.
U.S. Income Tax Treaties — Competent Authority Functions and Procedures of Selected Countries (Portfolio 941) Clifford E. Muller, Esq.Clifford E. Muller, B.S., B.A., Bucknell University (magna cum laude 1978), Delta Mu Delta; J.D., George Washington University (with high honors 1981), Order of the Coif; Professional Lecturer in Law, George Washington University Law School, 1987–1990. Member, District of Columbia Bar Association; member, American Bar Association, Section of Taxation; Chairman, Subcommittee on International Financial Transactions; member, Committee on Foreign Activities of U.S. Taxpayers, Foreign Currency Subcommittee. Lecturer: World Trade Institute, New York, “Taxation of Foreign Currency” and “Foreign Currency Exposure Management.”
Tax Aspects of Foreign Currency (Portfolio 921) Michael Mulroney, Esq.Michael Mulroney, B.S.C., University of Iowa (1954); J.D., Harvard Law School (1959); Order of Coif; Professor of Law, Director, Graduate Tax Program, Villanova School of Law (1988-present); Adjunct Professor, Georgetown University Graduate Tax Program (1986-present); Partner, Lee, Toomey & Kent, Washington, D.C. (1969-1988) (Associate 1965-1969); Appellate Attorney, Tax Division, U.S. Department of Justice, Washington, D.C. (1961-1965); Attorney Advisor, U.S. Tax Court (1959-1961). Teacher: Federal taxation; professional responsibility; faculty advisor, Villanova Law School Tax Clinic. Admitted to practice: District of Columbia; Iowa; U.S. Supreme Court; Iowa Supreme Court; U.S. Circuit Courts of Appeal for the Second, Third, Fourth, Fifth, Sixth, Seventh, Eighth, Ninth and Tenth Circuits; U.S. Tax Court; U.S. District Court for the District of Columbia; District of Columbia Court of Appeals. Professional organizations: District of Columbia Bar; Iowa State Bar Association; Federal Bar Association; American Bar Association, Section of Taxation (Tax Lawyer Committee, former Managing Editor, The Tax Lawyer, Chair Annual Reports Subcommittee; Court Procedure Committee; Standards of Practice Committee; Teaching Taxation Committee; Committee on Government Submissions), Section of Legal Education and Admissions to the Bar; District of Columbia Bar (Tax Section); Federal Bar Association (Tax Section); Iowa Bar Association (Tax Section); Fellow, American College Tax Counsel; J. Edgar Murdock American Inn of Court (Founding Master); American Association of Law Schools (Tax Section); International Fiscal Association (U.S.A. Director); Washington Tax Lawyers' Study Group; Philadelphia Tax Conference (Director, Executive Committee); Reporter, Invitational Conference on Professionalism in Tax Practice (1993); Commentator, Statute of the Bar of the Republic of Belarus (CEELI); author of various books and tax articles. Competition license holder, Sports Car Club of America.
Tax Aspects of Foreign Currency (Portfolio 921)
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Andrew C. Newman, CPAAndrew C. Newman, B.B.A., University of Wisconsin, 1980; tax partner, International Tax Service Line, Deloitte Tax LLP, Chicago, Illinois, 2002-present; Arthur Andersen, 1980-2002; member, AICPA, Illinois CPA Society, International Fiscal Association, Chicago Counsel on Foreign Relations; author, numerous articles on international tax matters; frequent speaker at seminars on international tax issues.
The Allocation and Apportionment of Deductions (Portfolio 906) Thanh Vinh NguyenThanh Vinh Nguyen holds his Bachelor of Arts Degree in English from the University of Ho Chi Minh City and his LL.B. from the College of Law of Ho Chi Minh City. Mr. Nguyen worked for two international accounting firms for eight years before joining the Ho Chi Minh City office of Baker & McKenzie in 2004. His principal practice areas are tax advice and planning, finance and banking, and general corporate matters. He is fluent in English as well as his native Vietnamese.
Business Operations Vietnam (Portfolio 994) Peter M. W. Nias, Esq.Peter Nias is a partner in the law firm of McDermott Will & Emery UK LLP, based in its London office. He is Head of the London office Tax Department, where his practice focuses on direct and indirect tax advice on a broad range of corporate and commercial business activities, including acquisitions and disposals, and corporate structures for UK and international business investments. Peter also advises on general corporate commercial tax matters for companies and advises individuals on wealth preservation techniques.
Business Operations the United Kingdom (Portfolio 989) Lionel B. NobreLionel Bonner Nobre, Director of BDO Seidman LLP's Brazilian Consulting Services in Miami; Pontifical University of São Paulo, Brazil (LLB, 1992 and LLM, 2000); Member, Brazilian Bar, Brazilian Institute of Certified Financial Planners (“Instituto Brasiliro de Certificação de Planejadores Financeiros – IBCPF”), Brazilian Association of Tax Consultants (“Associação Brasileira de Consultores Tributários – ABCT”), Academy of Brazilian Tax Law (Academia Brasileira de Direito Tributário – ABDT”), and the Brazilian Tax Planning Institute (“Instituto Brasileiro de Planejamento Fiscal – IBPT”).
Transfer Pricing: Foreign Rules and Practice Outside of Europe, Part 2 (Portfolio 898)
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Christopher Ocasal, Esq.Christopher (Chris) Ocasal is an international tax partner with Sutherland, Asbill & Brennan. Mr. Ocasal has extensive experience in advising clients with regard to their international tax issues and has substantial expertise in international insurance tax issues. Mr. Ocasal has worked with major U.S. multinationals with significant international operations and major foreign multinationals with significant U.S. operations. He advises on structuring joint ventures, domestic and international reorganizations, mergers and acquisitions, financial products, foreign currency transactions, anti-deferral regimes, withholding tax issues, foreign tax credit planning, and U.S. tax treaties. Prior to joining Sutherland, Mr. Ocasal was a principal in the PricewaterhouseCoopers LLP Washington National Tax Services office for nearly a decade. Additionally, prior to joining PricewaterhouseCoopers, Mr. Ocasal was a member of the Washington, D.C. office of Baker & McKenzie. Chris Ocasal received a J.D. from George Washington University Law School and an LL.M. from Georgetown University. He is a member of the New York and Virginia bar. Mr. Ocasal is also the co-author of a new BNA tax management portfolio, to be published, on Financial Instruments in which he reviews the taxation of notional principal contracts.
State Tax Appeal Systems (Portfolio 1700)U.S. Income Taxation of International Insurance Activities(Portfolio 931) Margaret Peg O'Connor, Esq.Margaret O’Connor, A.B. Bryn Mawr College; J.D. University of Maryland; M.L.T. from Georgetown University; International Tax Services Principal, Ernst & Young LLP, Washington, DC; member District of Columbia Bar, Maryland Bar, ABA; speaker on international tax issues; author of numerous articles relating to international tax.
Reporting Requirements Under the Code for International Transactions (Portfolio 947) Thomas A. O'Donnell, Esq.Thomas A. O'Donnell, Esq., B.A., Swarthmore College (1969); Ph.D., Rutgers University (1979); J.D., University of Cincinnati College of Law (1983); member, American Bar Association, District of Columbia Bar Association.
PFICs (Portfolio 923) Michael A. Olesnicky, Esq.Michael Olesnicky holds a BA and LLB from Adelaide University in Australia. He also holds an LLM from Columbia University in New York. He practiced from 1979–82 with Baker & McKenzie's office in Sydney. In 1988, he rejoined Baker & McKenzie's office in Hong Kong, and became a partner in 1989 in the International Tax Group. His chief specialty is Hong Kong and regional tax advisory work as well as estate duty planning. He is the Chairman of the Joint Liaison Committee on Taxation, which is a quasi-governmental committee that interfaces between tax practitioners and the Inland Revenue Department. He is a past chairman of the tax committee of the Australian Chamber of Commerce. He was a member of the Inland Revenue Board of Review (the lowest-level tax court in Hong Kong) between 1985 and 1994. He was Chief Editor of the Hong Kong Law Journal for five years. He writes and speaks frequently on Hong Kong tax matters.
Business Operations Hong Kong (Portfolio 964) Ricardo Gonzales OrtaRicardo Gonzalez Orta; graduate of the Universidad Iberoamericano; has significant experience in transfer pricing matters and coordinates the Deloitte Mexico and Latin America region Transfer Pricing practices; spent eight years in a number of top executive posts with the Ministry of Finance (Secretaría de Hacienda y Crédito Público -SHCP-) and the Tax Administration Service (Servicio de Administración Tributaria -SAT-), most recently as Director General of Tax Policy and, as Director General of International Fiscal Affairs, in these positions he was in charge of Mexico's tax and customs policy and the negotiation of double taxation treaties; is a frequent speaker in different domestic and international forums; writes periodically on Mexican tax and transfer pricing issues in the Tax Management International Journal; is currently a partner at Galaz, Yamazaki, Ruiz Urquiza SC, Deloitte Touche Tohmatsu´s Mexico affiliate, where he advises multinational companies on tax-related matters, including structuring new businesses, acquisitions, reorganizations, joint ventures, double taxation issues, and transfer pricing.
U.S. Income Tax Treaties — Competent Authority Functions and Procedures of Selected Countries (Portfolio 941)
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Michael F. Patton, Esq.Michael F. Patton; University of Maryland (B.A. and J.D. with honors, Order of the Coif), Georgetown University Law Center (LL.M., Taxation); was editor and a major contributor to the Treasury/IRS Transfer Pricing White Paper; was a member of the Treasury/IRS study group to revise the competent authority function; worked extensively on the OECD Multilateral Treaty on Mutual Administrative Assistance in Tax Matters and the U.S.-Bermuda Tax Convention; was the lead U.S. Treasury negotiator in many negotiations with foreign governemnts for tax information exchange agreements under the Caribbean Basin Initiative; named one of the Best of the Best U S transfer pricing advisors as well as one of the leading Asia Pacific tax advisors by Euro Money and the International Tax Review; has been named as a “Highly Recommended” tax advisor by the International Tax Review; member, Editorial Advisory Board of Tax Management, Inc; contributor to the Tax Management International Tax Journal, the Transfer Pricing Reporter, and other publications; is a Principal with Ernst & Young, a member of the International Tax Services Group in the National Tax Department.
Transfer Pricing: Alternative Practical Strategies (Portfolio 890) Josephine Y. K. Peng Josephine Y. K. Peng, Member of Taiwan CPA Association and Taipei Certified Public Accountant Association (since 1985); CPA, New Jersey, USA (since 1982); Senior CPA and Senior Counselor, Lee and Li, Attorneys-at-Law, Taipei (2000–present); Managing Partner, Intellects & Co., CPAs, Taipei (1989–2000); Columbia University, USA (Accounting Doctoral Program, 1981); Central State University of Oklahoma, USA (MBA, 1980); National Chung Hsing University, Taipei (B.B.A., 1977). Named by International Tax Review in 2006 as the most sought after tax adviser in Taiwan; and by The Tax Directors Handbook 2009 as one of the three best tax advisers in Taiwan; leads the Tax Practice Group of Lee and Li, Attorneys-at-Law, which was voted by International Tax Review in 2006 and 2007 as Taiwan Tax Firm of the Year; an active member on the tax committees of the American Chamber of Commerce in Taipei and the European Chamber of Commerce in Taipei; and a regular contributor of articles on various tax issues.
Business Operations in the Republic of China (Taiwan) (Portfolio 958) Charles T. Plambeck, Esq.Charles T. Plambeck, A.B. University of North Carolina (1983); J.D. University of North Carolina School of Law (1986); Office of the Associate Chief Counsel (International), Internal Revenue Service (1988-1990); Special Counsel of the Chief Counsel, Internal Revenue Service (1990-1992); Of Counsel and Partner, Caplin & Drysdale (1992-1997); Managing Director and Tax Counsel, Bankers Trust Company and Deutsche Bank (1997-2001).
U.S. Income Taxation of Foreign Corporations (Portfolio 908) Irving H. PlotkinIrving H. Plotkin, Wharton School, University of Pennsylvania, B.S.; Massachusetts Institute of Technology, Ph.D. in mathematical economics. Dr. Plotkin is Managing Director of the Boston Tax practice of PricewaterhouseCoopers; for many years previous, he was Vice-President for Forensic Economics at Arthur D. Little, Inc. Dr. Plotkin has designed and conducted research studies on various topics including the effects of government regulation, self-regulation, industry efficiency and risk taking. Dr. Plotkin lectures frequently on economic and regulatory issues, and based on his research work, has presented expert testimony in the Tax Claims, U.S. District, and State Courts on behalf of taxpayers and the IRS in a number of high-profile tax disputes (including Du Pont, UPS, DHL, ACM, Bausch and Lomb, The Limited, Dow, and the captive cases) and has testified before U.S. congressional committees and federal and state commissions.
Transfer Pricing: Economic, Managerial, and Accounting Principles (Portfolio 889) Dirk PohlDr. Dirk Pohl, University of Tax Administration, Northrhine-Westfalia (1987), University of Bonn (First State Law Examination 1993, Second State Law Examination 1997); Doctor of Jurisprudence (1997); member, German Bar for lawyers (Rechtsanwälte) and for tax consultants (Steuerberater); member, International Fiscal Association.
Business Operations Germany (Portfolio 962) G. Garner Prillaman, Jr. Esq.G. Garner Prillaman, Jr., B.S., Virginia Polytechnic Institute and State University (1975); M.B.A., Virginia Polytechnic Institute and State University (1976); J.D., Wake Forest University (1981); LL.M. in Taxation, New York University (1985). Member, District of Columbia Bar Association; member, American Bar Association, Section of Taxation; member, Committee on Foreign Activities of U.S. Taxpayers, Controlled Foreign Corporations Subcommittee; Certified Public Accountant, North Carolina; Lecturer: World Trade Institute, New York, “Foreign Currency Exposure Management.”
Tax Aspects of Foreign Currency (Portfolio 921) Timothy J. Pronley, Esq.Timothy J. Pronley, B.B.A., University of Wisconsin – Madison, 1990; J.D., University of Minnesota, 1993; Tax Senior Manager, Deloitte Tax LLP, Minneapolis, Minnesota; member Wisconsin Bar, ABA, WICPA; speaker on international tax issues; author, articles on international taxation, including contributions to Practicing Law Institute and American Bar Association publications.
Foreign Corporation Earnings and Profits (Portfolio 932)
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Amnon RafaelDr. Amnon Rafael, member of the Israeli and New York Bars (Advocate); LL.M. graduate of New York University (Taxation); J.S.D. graduate of New York University (Doctoral thesis on Tax Aspects of American Investments in Israel); member of the International Fiscal Association.
Business Operations Israel (Portfolio 967) Diane L. Renfroe, Esq.Diane L. Renfroe, B.A., Wellesley College, 1968; J.D., Boston College Law School, 1977; admitted to Bar, Massachusetts, District of Columbia; Adjunct Professor, LLM International Tax Program, Georgetown University Law Center, 2004–present; tax principal, Washington International Tax Group, Deloitte Tax LLP, 2002–present; tax partner, International Tax Specialty Team, Arthur Andersen, Washington, D.C., 1988-2002; manager, Arthur Andersen, 1983-1988; formerly Assistant Branch Chief/Attorney-Advisor, Legislation and Regulations Division, Office of Chief Counsel, Internal Revenue Service, 1977-1982; member, Commissioner's Advisory Group, 1990-1992; author, numerous articles on international tax issues and developments; frequent speaker at seminars on international tax issues.
The Allocation and Apportionment of Deductions (Portfolio 906) Diane M. RingDiane M. Ring, A.B. Harvard College (1986); J.D. Harvard Law School (1990); Caplin & Drysdale (1991-1994); Assistant Professor of Law, Harvard Law School (1994-2004); Associate Professor of Law, University of Florida (2004-2005); U.S. National Reporter to IFA (2003-2004).
U.S. Income Taxation of Foreign Corporations (Portfolio 908) Jennifer Roeleveld, CA(SA)Professor Jennifer Roeleveld, B.Compt (Hon)(SA), B.Com (Honours) (Taxation), LLM University of Cape Town; CA(SA), member of the South African Institute of Chartered Accountants (SAICA); member of the International Fiscal Association. Executive board member of the South African Fiscal Association; member of the National Tax Committee of SAICA and Integritax; head of taxation, Faculty of Commerce, University of Cape Town and registered tax practitioner.
Business Operations South Africa (Portfolio 982) Ricardo J. Romulo, Esq.Ricardo J. Romulo, B.S., cum laude, Georgetown University (1955); J.D., Harvard Law School (1958); Senior Partner, specializing in foreign investments and taxation, Romulo, Mabanta, Buenaventura, Sayoc & de los Angeles; Chairman, Makati Business Club and member, Philippine-United States Business Council; member, 1986 Constitutional Commission, which drafted the present Constitution of the Philippines; former President, Philippine Bar Association.
Business Operations the Philippines (Portfolio 978) Howard D. Rosen, Esq.Howard D. Rosen, B.B.A., University of Miami (1969, magna cum laude); J.D., University of Miami (1973, summa cum laude); member, Editorial Board, University of Miami Law Review; Certified Public Accountant, Florida; member, Florida Bar; member, Tax and International Law Sections of the Florida Bar; Adjunct Professor of Law, University of Miami School of Law (1990- ); member, Board of Governors of the Florida Institute of Certified Public Accountants (1997-1999), member, Florida Institute of Certified Public Accountants, past president and director of the South Dade Chapter of the Florida Institute of Public Accountants.
Asset Protection Planning (Portfolio 810)U.S. Taxation of Foreign Estates, Trusts and Beneficiaries (Portfolio 854)U.S. Taxation of Foreign Estates, Trusts and Beneficiaries (Portfolio 911) Charles D. Rubin, Esq.Charles D. Rubin, Esq., University of Florida (1983); B.A. (Political Science), Northwestern University (1980); member, Florida Bar; Vice–chairman, Foreign Tax Advisory Committee of Florida Bar, Tax Section (1988); Author, “The FIRPTA Manual — Compliance and Planning Guide to the Foreign Investment in Real Property Tax Act” (Maxwell McMillan); Author, “Florida Sales and Use Taxes on Boats — Compliance and Planning Manual” (Florida Tax Publications); Contributor to: University of Florida Law Review, Journal of Bank Taxation, Marine Business Journal, Tax Ideas, Tax Management Estates, Gifts and Trusts Journal, Tax Notes, Journal of Taxation, Callaghan & Co. publications, Bureau of National Affairs publications; Adjunct Professor, University of Miami School of Law, Graduate Program in Taxation and Graduate Program in Estate Planning (1991–present).
Risto Rytohonka, Esq.Risto Rytöhonka, LL.B., 1978 (University of Helsinki), Diploma in European Integration, 1981 (University of Amsterdam), Varatuomari, 1984 (“lawyer trained in the court”), LL.M. in Taxation, 1992 (University of Miami); member of the international lawyers’ organization, The Nordlund Group.
Business Operations Finland (Portfolio 960)
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Ozzie A. Schindler, Esq.Ozzie A. Schindler, Esq., B.S. in Accounting, University of Florida (1990); J.D., University of Florida (1993); LL.M., New York University (1995); member, Florida Bar Association.
PFICs (Portfolio 923) Kristine K. SchlamanKristine K. Schlaman, B.A., University of Northern Colorado (1977); J.D., Washburn University (1983); M.L.T. with Distinction, Georgetown University (1989); KPMG, LLP, International Corporate Services Tax Practice; Attorney-Adviser, Office of Associate Chief Counsel (International) (1989–1996); Attorney, Schroeder, Heeney, Groff and Coffman, P.A., Topeka, Kansas (1984–1988).
Income Tax Treaties — Administrative and Competent Authority Aspects (Portfolio 940) Jeffrey A. SchoenblumJeffrey A. Schoenblum, A.B., Johns Hopkins University (1970); J.D., Harvard Law School (1973); professor, Vanderbilt University Law School (1977-present); author, “Reaching for the Sky or Pie in the Sky: Is U.S. Onshore Trust Reform an Illusion?” in Extending the Boundaries of Trusts and Other Ring-Fenced Funds in the Twenty-First Century (Kluwer); author, Multistate and Multinational Estate Planning, 2 vols. (Aspen 1999 & 2002 Supp.); author, Page on Wills: Annual Supplement (Anderson); author, Multistate Guide to Estate Planning (Aspen 2003); author, “Fiduciary Duty and the Direct-Derivative Distinction in the Takeover/Merger Context” in L'Alambicco Del Comparatista: Amministratori: Fiduciari—Ma Di Chi? (2001); editor, A Guide to International Estate Planning (ABA 2000); author, “Conflict of Laws; Trusts and Civil Law; Situs Wills—The American Perspective” in International Estate Planning (1996); author, Preface, Global Estate Planning (Kluwer 1995); author, “The Use of Offshore Trusts by Residents or Nationals of Civil Law Jurisdictions” and “Property Ownership and Succession Planning for the Foreign National: Conflicts of Law; Recognition of Trusts and Testamentary Dispositions; Marital Property Rights and Forced Heirship” in International Wealth Transfer Techniques—1990s and Beyond (1995); co-editor, International Estate Planning (ABA 1991) (with D. Kozusko); author, “The Adaptation of the Asset Protection Trust for Use by the Multinational Corporation—The American Perspective” in Commercial Aspects of Trusts and Fiduciary Obligations (Clarendon 1992).
Bilateral Transfer Tax Treaties (Portfolio 851)Bilateral Transfer Tax Treaties (Portfolio 939) Ching-Ling SeahChing Ling Seah, L.L.B. (Hons), National University of Singapore, 2002; Advocate & Solicitor, Supreme Court of Singapore; Associate Director, Tax & Private Clients Services, Drew & Napier LLC, Singapore.
Business Operations Singapore (Portfolio 983) Michael SedlaczekMichael Sedlaczek, Universities of Vienna and Innsbruck (Master of Laws 1988); Doctor of Jurisprudence (1992); member, Austrian Bar; member, International Academy of Estate and Trust Law; International Fiscal Association; and International Bar Association.
Business Operations Austria (Portfolio 952) Rajiv G. ShahRajiv G. Shah, B.Com, F.C.A., University of Bombay (1980), Fellow of the Institute of Chartered Accountants of India, Member of International Taxation and Taxation Committee of Bombay Chartered Accountants’ Society, Member of Taxation and International Trade Committee of Bombay Chamber of Commerce and Industry, contributor and speaker at seminars on taxation. Partner responsible for firm's taxation practice.
Business Operations India (Portfolio 966) Stanley G. Sherwood, Esq.Stanley G. Sherwood, Bryant College, B.S.B.A. (1968); Suffolk University Law School, J.D. (1971); New York University Graduate School of Law, LL.M. (1979); Member of the Bar of the State of New York; Certified Public Accountant (New York); Member of the Board, Institute of International Taxation; Member, International Fiscal Association, American Bar Association Tax Committee, New York State Bar Association Committee on Foreign Investment in the U.S.
Steven R. Sieker, Esq.Steven Sieker holds a BA (Honors) from the University of Alberta and an LLB from Dalhousie University (both in Canada). He is a former law clerk to the Supreme Court of Canada and joined Baker & McKenzie's office in Hong Kong in 1998. His specialties are Hong Kong and regional tax advisory work and litigation as well as Canadian tax planning. He has been a member of the Inland Revenue Board of Review and a part-time lecturer in Revenue Law at City University and Hong Kong University. He writes and speaks frequently on tax matters.
Business Operations Hong Kong (Portfolio 964) Stuart Sinclair, Esq.Stuart Sinclair is a partner in the law firm of McDermott Will & Emery UK LLP, based in its London office. He is a member of the Tax Department, where his practice focuses on a range of corporate tax matters, specializing in tax-based structured finance transactions, capital markets, financial instruments, mergers and acquisitions, reorganizations and tax insurance.
Business Operations the United Kingdom (Portfolio 989) Paul A. Smith, Esq.Paul A. Smith, CPA; B.S. (Accounting), Rollins College; M.S. (Taxation), University of Denver; Certified Public Accountant, State of Florida and Washington, D.C.; formerly associated with Ernst & Young, LLP as Director of Tax Accrual Services in the National Tax Department in Washington, D.C.; frequent lecturer on the international tax aspects of accounting for income taxes. Mr. Smith is Vice President of Global Tax at Levi, Strauss & Co. in San Francisco, California.
U.S. Tax-Related Accounting Issues of Multinational Corporations (Portfolio 948) George H. Soba, Esq.George H. Soba, Esq., New York University School of Law, LL.M. (Taxation) (1982); University of Toledo College of Law, J.D. (cum laude) (1981); Franklin and Marshall College, B.A. (1978); formerly IRS Tax Counsel, Brooklyn District Counsel Office and Senior Attorney–Advisor in the Office of Associate Chief Counsel (International).
Transfer Pricing: Records and Information (Portfolio 891) Phillip A. Stoffregen, Esq.Philip A. Stoffregen, B.A. Earlham College (honors 1973); Ph.D. University of Chicago (Mrs. Giles Whiting Fellow 1979); J.D. University of Chicago Law School (honors 1982); Law Clerk, The Honorable Bruce M. Forester, United States Tax Court; frequent speaker and writer on international tax subjects.
Partners and Partnerships — International Tax Aspects (Portfolio 910) Dirk J. J. Suringa, Esq.Dirk Suringa is a Partner in the Washington, D.C. law firm of Covington & Burling LLP, practicing in the areas of international and corporate taxation. Mr. Suringa graduated from Princeton University (B.A. 1992, departmental honors, Phi Beta Kappa) and Harvard Law School (J.D. 1996, magna cum laude), where he served as editor of the Harvard Law Review. Mr. Suringa clerked for the Honorable Gerald B. Tjoflat, Chief Judge of the U.S. Court of Appeals for the Eleventh Circuit, from 1996 to 1997. Mr. Suringa served as Attorney-Advisor in the Office of International Tax Counsel of the Department of the Treasury, from 2000 to 2003. Mr. Suringa is a member of the Florida Bar and the District of Columbia Bar, the American Bar Association, and the International Fiscal Association.
The Foreign Tax Credit Limitation Under Section 904 (Portfolio 904)Foreign Personal Holding Companies (Portfolio 922)
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Shimon Takagi, Esq.Shimon Takagi, Osaka City University (LL.B. 1988); New York University School of Law (LL.M. in Taxation 1995); admitted to Japanese Bar (1990); member, Tokyo Bar Association, New York State Bar and International Fiscal Association.
Business Operations Japan (Portfolio 969) Carol P. Tello, Esq.Carol P. Tello, B.A., College of William and Mary, J.D., University of Maryland School of Law, and M.L.T., Georgetown University Law Center; lecturer on international tax topics; author of numerous articles on international taxation; member of the Tax Management Foreign Income Advisory Board; member, U.S. Branch Council, International Fiscal Association and Foreign Activities of U.S. Taxpayers and U.S. Activities of Foreigners and Tax Treaties Subcommittees of the ABA Section of Taxation; former attorney-advisor, Office of Associate Chief Counsel (International) and Technical Advisor to the Assistant Commissioner (International).
U.S. Withholding and Reporting Requirements for Payments of U.S. Source Income to Foreign Persons (Portfolio 915) Gary M. Thomas, Esq.Gary M. Thomas, B.A., University of Washington, 1973; J.D., Harvard Law School, 1977; Asia University, Masters of Japanese Law/Taxation (1989) and Masters of Japanese Accounting (1994); Partner, White & Case LLP, Tokyo, Japan; admitted in Japan as licensed tax attorney (zeirishi); member of Tokyo Zeirishi Association, California State Bar Association, and Dai-ni Tokyo Bar Association; speaker on Japanese international tax issues; author, articles on Japanese taxation in the United States, Japan and Europe.
Transfer Pricing: Foreign Rules and Practice Outside of Europe (Portfolio 897) Syllas Tozzini, Esq.Syllas Tozzini, partner, TozziniFreire, Teixeira e Silva Advogados, São Paulo, Brazil; University of São Paulo School of Law (LL.B., 1972); Parker School of Foreign and Comparative Law, Columbia University (1987).
Business Operations Brazil (Portfolio 954) Richard G. Tremblay, Esq.Richard Tremblay, B.Sc., McGill; LL.B., Osgoode Hall; LL.M., New York University; Barrister and Solicitor of the Bar of Ontario; Tax Partner, Osler, Hoskin & Harcourt LLP.
Business Operations Canada (Portfolio 955)
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Priscilla B. ValerPriscilla B. Valer, B.S., cum laude, University of Sto. Tomas (1985); J.D., second honors, Ateneo de Manila University (1992); Partner, specializing in taxation, Romulo, Mabanta, Buenaventura, Sayoc & de los Angeles and Director, Tax Management Association of the Philippines.
Business Operations the Philippines (Portfolio 978) H. Tom van der Meer, Esq.Tom van der Meer is a graduate of Leiden law school and is a partner at Loyens & Loeff. He has worked for the Curaçao, New York and Amsterdam offices of the firm and is currently responsible for the Luxembourg office. He has made numerous speeches for large organizations on Netherlands, Luxembourg and international tax issues and is an active member of the International Bar Association and the European American Tax Institute.
Business Operations Luxembourg (Portfolio 971) Kees van Raad, Esq.Kees van Raad, Master of Laws, University of Leiden, The Netherlands (1969); M.C.L., Georgetown University, Washington D.C. (1970); Doctor of Laws, University of Leiden, The Netherlands (1986); Visiting Professor of Law, University of Florida, USA (1982, 1997, 2003); Universities of Stockholm and Uppsala, Sweden (1987); University of London, UK (1990); Emory University, USA (1991), New York University, USA (1992, 2002, 2004, 2006); Bocconi University, Italy (1993, 1994, 2002); University of California (Hastings College of the Law (1996, 2008)); the Free University of Brussels (1997); University of Sydney (1998, 2005); Xiamen University, China (2004); Peking University (PKU) Law School, China (2005, 2006, 2007); and National Taiwan University (2007, 2008). Associate Judge at the Court of Appeal of ‘s-Hertogenbosch. Recipient of the 1982 Netherlands Biannual Award for Publications on Taxation; Chairman of the Board of the Association of European Tax Professors; author of books and articles on international tax law; and frequent speaker at international conferences, seminars and symposia.
Business Operations The Netherlands (Portfolio 973)
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A. Duane Webber, Esq.A. Duane Webber, Kansas State University (B.A., B.S. 1981); Georgetown University (J.D. 1984); Member, Section of Taxation (Court Procedure Committee) and Section of Litigation of the American Bar Association; Member, Taxation Section of the Federal Bar Association; Member, J. Edgar Murdock American Inn of Court.
Transfer Pricing: Judicial Strategy and Outcomes (Portfolio 888) Francis J. Wirtz, Esq.Francis J. Wirtz, B.S. (accountancy) University of Illinois (with honors 1975); J.D. University of Michigan Law School (cum laude 1979); certified public accountant; Chairman of Subcommittee on International Taxation of Partnerships, S Corporations and Trusts, Committee on Foreign Activities of U.S. Taxpayers; frequent speaker and writer on federal tax issues.
Partners and Partnerships — International Tax Aspects (Portfolio 910) Steven C. Wrappe, Esq.Steven C. Wrappe, Esq., New York University School of Law, LL.M. (Taxation) (1988); University of Texas School of Law, J.D. (1985); University of Notre Dame, Bachelor of Business Administration (1980). Member, State Bar of Texas; Certified Public Accountant. Partner, National Transfer Pricing Team, Deloitte & Touche LLP, Washington, D.C. Formerly, IRS APA Program attorney. Internationally–recognized speaker on the resolution of transfer pricing disputes, with speeches before the Tax Executives Institute, American Bar Association, and Federal Bar Association. Adjunct faculty member at George Mason University Law School, teaching International Tax, and guest lecturer in the LL.M. Program at New York University School of Law.
Transfer Pricing: Records and Information (Portfolio 891)
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Sophia H. H. YehSophia H. H. Yeh, National Taiwan University, Taipei (LL.B., 1980); University of Pennsylvania Law School (LL.M., 1987); senior counselor at Lee and Li, Attorneys-at-Law (1981–present ); co-leader of projects for Amendments to the Company Act, Amendments to Mechanisms for Merger and Acquisition and Share Swap, Knowledge-based Economy Related Legal Framework Research, Strategy Planning for Establishing Taiwan as a Global or Asian Resource Integrator, Securitization of Assets; Co-writer of the Taxation of Income Derived from the Supply of Technology (IFA), Model Acquisition Asset Purchase Agreement (ABA).
Business Operations in the Republic of China (Taiwan) (Portfolio 958) Dong Jun YeoDong Jun Yeo, Tax Attorney, Kim & Chang; Seoul National University, College of Social Science, International Economics (B.A., 1980); University of Illinois, Urbana-Champaign (M.A. in Accounting, 1987); Employment, Tax practice in Korea (1981-1985), tax practice, New York (1987-1992); Member, Korean Institute of Certified Public Accountants, American Institute of Certified Public Accountants. Languages: Korean and English.
Transfer Pricing: Foreign Rules and Practice Outside of Europe, Part 2 (Portfolio 898) Lowell D. Yoder, Esq.Lowell D. Yoder, B.A. (1979, with highest distinction) and J.D. (1982, magna cum laude), University of Illinois; Order of the Coif; Law Review Editor; Law Clerk, The Honorable James M. Sprouse, Federal Court of Appeals for the Fourth Circuit; frequent lecturer on international tax topics; author of numerous articles on international taxation; member of the Tax Management International Journal Advisory Board, member of the Editorial Board of the Journal of International Taxation, and member of the University of Chicago Law School's Federal Tax Conference Planning Committee; Adjunct Professor of Law at Chicago-Kent College of Law, teaching International Taxation.
CFCs — Foreign Personal Holding Company Income (Portfolio 927)Subpart F—General (Portfolio 926)CFCs — Foreign Base Company Income Other than FPHCI (Portfolio 928)CFCs — Sections 959-965 and 1248 (Portfolio 930)
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Howard M. Zaritsky, Esq.Howard M. Zaritsky, B.A., Emory University (1970); J.D., Stetson University College of Law (1973); LL.M. (Taxation), Georgetown University Law Center (1976); Consulting Counsel; member, Virginia State Bar; BNA Tax Management Advisory Board on Estates, Gifts and Trusts; University of Miami (Heckerling) Estate Planning Institute Advisory Committee; author or co-author, numerous articles and several treatises, including: Tax Planning for Family Wealth Transfers, Generation-Skipping Transfer Taxes: Analysis with Forms (with Carol Harrington & Lloyd Leva Plaine); Structuring Buy-Sell Agreements (with Farhad Aghdami & Mary Ann Mancini); Structuring Estate Freezes After Chapter 14 (with Ron Aucutt); Federal Income Taxation of Estates and Trusts (with Robert Danforth & Norman Lane); Tax Planning With Life Insurance (with Stephan Leimberg) — all published by Warren, Gorham & Lamont/RIA Group; tax editor, Probate Practice Reporter; Fellow, the American College of Trust and Estate Counsel and American College of Tax Counsel; former Chair, Virginia Bar Association Section on Wills, Trusts & Estates; lecturer, numerous Tax and Estate Planning Institutes, including Institutes of the University of Miami (Heckerling Institute), New York University, Georgetown University, Duke University, and the University of Southern California.
Grantor Trusts: Sections 671-679 (Portfolio 858)Revocable Inter Vivos Trusts (Portfolio 860)U.S. Taxation of Foreign Estates, Trusts and Beneficiaries (Portfolio 854)U.S. Taxation of Foreign Estates, Trusts and Beneficiaries (Portfolio 911)