think and code's U.S. International Advisory Board is comprised of esteemed professionals from renowned corporations, universities, and government entities. Below is a listing of our current board members.
John Harrington (Chair)
Dentons US LLP
John Harrington is a member of Dentons' Tax practice, which was recognized by The Legal 500 in 2016 for outstanding work in international and non-contentious tax. He advises clients on inbound and outbound transactional and compliance issues; international tax legislative, regulatory and treaty matters; and a variety of domestic tax issues. John has extensive experience in dealing with the foreign tax credit, with subpart F and cross-border activities of companies and individuals and with other international tax issues.
Prior to joining Dentons, John served as international tax counsel for the Department of Treasury. There he worked closely with the Internal Revenue Service (IRS) in developing regulations and other administrative guidance. He represented the Treasury Department and worked with congressional committees and staff on tax treaties and international tax aspects of legislation. He has also played an active role in tax treaty negotiations, and in drafting technical explanations and revisions to existing treaties. John worked closely with tax officials in other countries and he served as the United States' representative at meetings of the Organization for Economic Cooperation and Development (OECD) Committee on Fiscal Affairs and at World Trade Organization (WTO) meetings on tax-related trade disputes.
Before joining the Treasury Department, John was a tax counsel on the US House Committee on Ways and Means. On the committee staff, he was responsible for international, pass-through entities, financial institutions and products, real estate, environment, energy and other tax issues. John is a frequent speaker and panelist at tax conferences.
Daniel Z. Altman
Sidley Austin LLP
Daniel Z. Altman is a partner in Sidley’s Tax group. Dan represents clients with respect to all tax aspects of domestic and cross-border M&A and corporate restructuring transactions, including tax free and taxable transactions, stock and asset sales, mergers, bankruptcy restructuring, spin-offs, recapitalizations, joint ventures, inbound and outbound investments and IP structuring and utilization. He provides tax advice in a variety of fields, including life insurance, property and casualty insurance, IP, healthcare, real estate, manufacturing, services, asset management and others. Dan also advises clients on all international aspects of U.S. federal income taxation and assists clients in their international tax planning.
Kimberly S. Blanchard
Weil, Gotshal & Manges LLP
Kim Blanchard is a Tax partner in Weil’s Tax, Executive Compensation & Benefits Department whose practice encompasses a variety of largely international transactions involving corporate acquisitions and mergers, internal restructurings, business formations and joint ventures. Ms. Blanchard also advises domestic, foreign and multinational clients in connection with venture capital investment and fund formation, partnerships, real estate, executive compensation and exempt organization issues.
Ms. Blanchard has lectured and published extensively on topics ranging from international tax planning for U.S. businesses to the special tax issues facing foreign persons, pension plans and other exempt investors who invest in U.S. private equity partnerships and in U.S. real estate.
Ms. Blanchard is consistently recognized as a leading Tax lawyer by Chambers USA, Chambers Global, Legal 500 US, Best Lawyers in America and The Best of the Best USA. In Chambers USA, clients note that Ms. Blanchard is “very smart, very knowledgeable…an expert.” Ms. Blanchard was named to the Legal 500’s “Hall of Fame” in 2017. She was named among 2015 “Top Women” for Tax in New York by Super Lawyers. In addition, Ms. Blanchard was recognized by Expert Guides’ 2014 “Women in Business Law” publication for Tax, named a “Most Highly Regarded” lawyer by Who’s Who Legal: The International Who’s Who of Corporate Tax 2012, and she received the 2013 “Best in Tax” Award from Euromoney Legal Media Group’s “Women in Business Law” Awards.
Ms. Blanchard is a former Chair of the New York State Bar Association Tax Section. She is active with the American Bar Association's international tax committees and is a member of both the Tax Forum and the Tax Review paper and discussion groups. Ms. Blanchard is the President of the International Tax Institute. She is the author of the Tax Management Portfolio on PFICs, a “Leading Practitioner Contributor” to the Tax Management International Journal and a member of Practical Law Company’s U.S. advisory board. In addition, Ms. Blanchard is a member of the Board of Trustees of the American Indian College Fund and of the Board of Directors of the Girl Scouts of Greater New York.
Peter H. Blessing
Peter Blessing is Head of Cross-Border Corporate Transactions in KPMG’s Washington National Tax Practice (WNT). Prior to joining KPMG, Blessing served 25 years as a partner at Shearman & Sterling LLP, a leading international law firm.
Prominent in the area of cross-border taxation, Blessing has received numerous accolades and recognitions from both peers and clients during the course of his career. He is ranked highly in various surveys, including "Best Lawyers of America 2012," Euromoney's "Best of the Best USA 2012" and Chambers and Tax Directors' Handbook. Blessing is the editor of Kluwer's recently published two-volume set Tax Planning for International Mergers, Acquisitions, Joint Ventures, and Restructurings.
Blessing is a member of the Permanent Scientific Committee of the International Fiscal Association and the Executive Committee of IFA USA Branch. He is active in various other professional organizations as well, having held leadership roles in a number of them (including his position as former chair of the New York State Bar Association Tax Section). He has also taught as an adjunct professor at Columbia Law School.
Michael J. Caballero
Covington & Burling, LLP
Michael Caballero is a partner in the Washington office of Covington & Burling LLP and a member of the Tax Practice Group. His practice focuses on international tax matters, including structural and transactional tax planning, as well as tax controversy and other government relations work.
Mr. Caballero recently served as International Tax Counsel at the U.S. Department of the Treasury. While at the Treasury, he participated in the development of legislation, regulations and administrative guidance concerning international tax matters; oversaw the U.S. tax treaty program; and coordinated the representation of the United States in various international fora, including the Organisation for Economic Co-operation and Development (OECD). He also was previously a member of the Office of International Tax Counsel for almost six years as an Attorney Advisor and Associate International Tax Counsel.
Prior to his most recent position at the Treasury, Mr. Caballero practiced as a tax partner at two global law firms.
Martin J. Collins
Marty Collins is a Partner in PricewaterhouseCoopers LLP Washington National Tax Services Office.
Marty practice covers a wide-range of cross-border tax issues, including analyzing developments and identifying planning opportunities arising from new tax legislation, regulations and treaties.
Marty specializes in advising clients on structuring tax-efficient acquisition and disposition structures, cross-border reorganizations including section 7874 (inversion) considerations, inbound financing structures, cross-border joint ventures, and principal/entrepreneur structures. Marty's practice includes developing and analyzing strategies for tax-efficient IP, financing and holding-company structures, including strategies for the redeployment of foreign earnings. Marty regularly advises clients on the U.S. anti-deferral (e.g., Subpart F income), overall foreign loss, and foreign tax credit rules and regulations.
Marty frequently speaks and writes on a broad range of international tax issues.
Marty joined PricewaterhouseCoopers in 1995 in Baltimore; transferred to Washington National Tax Services from 1998 to 2003; transferred to Chicago from 2003 to 2005; and then rejoined in March 2008 from McDermott Will & Emery where he was a partner in that firm’s tax practice from 2005-2008.
Alan is an International Tax Services Principal with PwC’s Washington National Tax Services office. He consults with the firm's practice offices and clients on international tax issues arising in complex transactions, tax planning and controversies with the IRS. Alan has also served as leader of the Washington National Tax Services Energy and Mining Industry practice.
Alan has broad experience in international and federal tax matters, including foreign tax credit and related expense allocation issues, issues arising in international mergers, acquisitions and reorganizations and tax treaty issues. He represents clients before the IRS, Treasury and the Congressional tax-writing committees.
Prior to joining PwC, Alan was a partner with a Washington, D.C. tax law firm and the Chair of its Tax Department. He was responsible for a variety of tax matters for major multinational clients. Alan was also a legislation attorney with the Congressional Joint Committee on Taxation, where he was a principal participant in the drafting of the international provisions of the Tax Reform Act of 1986 and assisted the Senate Foreign Relations Committee in its analysis of proposed income tax treaties. He is a past Chair of the Foreign Activities of US Taxpayers Committee of the American Bar Association Tax Section, and he speaks and writes frequently on international tax issues. He also is a member of the Board of Advisors of the Journal of International Taxation, the Advisory Board of Tax Management International Journal, the AICPA International Tax Technical Resources Panel, and the American Law Institute.
Alan earned a JD cum laude from Harvard Law School in 1980 and an AB magna cum laude and Phi Beta Kappa from Brandeis University in 1977. He is a member of the District of Columbia Bar and the New York Bar.
Peter A. Glicklich
Davies Ward Phillips & Vineberg LLP
Peter Glicklich is the Managing Partner of the Davies Ward Phillips & Vineberg LLP's New York office and a partner in its Taxation practice. For over 25 years, he has counseled North American and foreign-based multinationals and other institutions on their international and corporate tax concerns.
Peter concentrates his practice in the taxation of corporate and international transactions. He advises public and closely held corporations and REITs in connection with their mergers and acquisitions, cross-border financings, restructurings, reorganizations, spinoffs and intercompany pricing. Peter has advised entities in diverse fields, including real estate, infrastructure, finance, retail, manufacturing, mining, biotechnology, service software, transportation, telecommunications, beverages and pharmaceuticals.
He has worked with institutional investors, private equity, hedge and venture capital funds, foreign governments, pension plans, Fortune 50 companies, investment banks, commodities and securities dealers, insurance companies, and others. Peter also arbitrates tax-related contract disputes arising in connection with M&A and other transactions and handles tax controversies.
Heléna M. Klumpp
Ivins, Phillips & Barker, Chartered
Heléna M. Klumpp is a partner in the Washington office of Ivins, Phillips & Barker, specializing in international and corporate tax, as well as tax policy and controversies. Her practice includes advising clients on implications and strategies related to federal tax policy matters, counseling clients involved in (or striving to avoid) controversy matters with the IRS, and guiding businesses on the tax consequences of complex transactions.
Prior to joining Ivins, Heléna spent nine years in the tax department of Baxter International, Inc., where she eventually served as vice president and head of global tax. Heléna co-led the team charged with the tax planning and functional division of resources related to the 2015 spin-off of the company’s highly integrated bioscience division, Baxalta Inc., and worked extensively on the post-acquisition integration of Gambro AB, a $4B dialysis company based in Sweden.
Throughout her tenure with Baxter, Heléna was responsible for monitoring and analyzing tax-related legislative and regulatory developments, and for working with the corporate government affairs team and industry groups to devise and implement responsive strategies. For eight years, Heléna was responsible for the overall management of the company’s relationship with the IRS. She advised on the tax implications of numerous supply chain, business development and IP-related initiatives, and she represented the company in matters involving the U.S. Competent Authority.
Heléna began her career in the Washington office of a global law firm, where she spent eight years advising clients in the independent energy sector. An avid writer, Heléna has also served in senior editorial roles with leading tax publishers think and code and Tax Analysts, where she was editor of the company’s flagship publication, Tax Notes.
Stephen R. LaSala
Formerly of Exxon Mobil
Stephen R. LaSala is the Co-Practice Group Leader of the firm's Corporate Practice Group. He is also the former Managing Partner of the San Diego (Del Mar) office and former Team Leader of the firm’s Mergers & Acquisitions team.
O’Connor Davies LLP
Leonard D. Levin is a Partner of the Firm and has more than 30 years of international and domestic tax experience, including international mergers, acquisitions and securitizations.
Prior to joining PKF O’Connor Davies, Leonard worked in the Office of the Chief Counsel of the IRS and served as Chief Tax Officer of North American Operations for large multinational corporations. He has considerable experience handling cross-border tax issues, including structuring global operations, transfer pricing, and tax audits.
Leonard speaks German, French and Dutch, and has written and spoken about issues in international tax on numerous occasions in North America, Europe and Australia.
Kimberly Tan Majure
Kim Majure focuses on inbound and outbound tax planning and controversy. Kim advises clients on international tax planning and controversy issues, including cash management and deferral planning, withholding, cross-border financing, and multinational structuring.
Kim is an adjunct professor with the Georgetown University Law Center, where she has taught a mix of international tax classes for Georgetown’s LLM degree program, including an advanced international tax seminar and a cross-border tax controversy workshop.
Kim has spoken at the Tax Executives Institute's Audit & Appeals Seminar, the International Fiscal Association, and the American Bar Association (ABA) Tax Section. She is a regular panelist for the “Inbound-Outbound Update” session at the George Washington University/Internal Revenue Service Institute on Current Issues in International Taxation.
Kim is a current vice-chair of the ABA Tax Section Committee, Foreign Activities of U.S. Taxpayers and chairs an annual international tax seminar series for think and code/CITE. She is the lead author on an annual periodical: “Select U.S. Federal Income Tax Considerations in European Joint Venture,” Tax Planning for Domestic & Foreign Partnerships, LLCs, Joint Ventures, & Other Strategic Alliances (2006-present).
Before joining KPMG, Kim was a partner in the D.C. law firm Miller & Chevalier. Kim has also served as senior manager in the national office of another Big Four firm.
Samuel M. Maruca
Covington & Burling, LLP
Sam Maruca has practiced broadly and exclusively in the area of federal income tax since 1983, focusing in recent years on large-case controversies, including complex transfer pricing disputes. He has represented both US and foreign-based multinational companies in the pharmaceutical, bio-tech, communications, heavy manufacturing, entertainment, and retail sectors, in matters at the audit level, in IRS Appeals, in mediation, in competent authority, and in the courts. His expertise includes the preparation of opinion letters and compliance advice relating to cross-border financing transactions and transfer pricing matters, repatriation of foreign earnings, anti-deferral regimes and limitation on benefits, mutual assistance and other treaty issues.
From 2011-2014, Mr. Maruca served as the first Director of Transfer Pricing Operations in the Large Business & International Division of the Internal Revenue Service, where he had national responsibility for transfer pricing compliance and double tax cases under US tax treaties.
Michael J. Miller
Roberts & Holland LLP
A Partner with Roberts & Holland LLP, Michael J. Miller has provided U.S. tax advice to domestic and international clients for more than 20 years. Working with foreign clients, he has structured inbound U.S. investments and operations to avoid the creation of a U.S. permanent establishment and developed structures designed to take advantage of U.S. income tax treaties, the withholding tax exemption for portfolio interest, and other special rules for minimizing U.S. tax. This includes consideration of various anti-abuse rules, such as earnings-stripping limitations and restrictions on the ability to engage in treaty shopping or earn income through hybrid entities. He has worked with U.S. multinationals to structure their foreign investments and operations so as to minimize the impact of certain restrictions on outbound transfers and anti-deferral rules applicable to shareholders of controlled foreign corporations and passive foreign investment companies, as well as maximize the utilization of foreign tax credits. Michael is an editor of the International column for the Journal of Taxation, and a member of the Advisory Boards of the International Tax Journal and the think and code Tax Management International Journal. He has co-authored two think and code Portfolios: Income Tax Treaties - The Limitation on Benefits Article and U.S. Taxation of International Shipping and Air Transport Activities.
Michael is currently Chair of the U.S. Activities of Foreign Taxpayers Committee of the American Bar Association Tax Section and a former Chair of the Business Entities Committee of the New York City Bar. Michael is designated as a leading tax professional in Chambers USA, Super Lawyers, and Legal Media Group's Expert Guides: Tax Advisors.
Ernst & Young LLP
Jose is a National Tax partner and leads Ernst & Young’s International Tax Services group in Washington DC. Jose also serves as the firm’s Director of NTD Washington International Tax Services National Tax Department. His practice focuses primarily on cross—border acquisitions, dispositions and restructurings. Prior to his current role, Jose was in the Treasury Department’s Office of Tax Policy, where he assisted with the development of international tax policy, Treasury regulations and other guidance, and negotiating income tax treaties. Prior to his time at the Treasury Department, he was part of EY’s International Tax Services practices in the Houston and Washington, DC offices. Jose is a frequent contributor to tax publications and a presenter at internal and external international tax seminars.
University of Florida School of Law
Fred F. Murray, is the Director of the Graduate Tax Program and Professor of Taxation Practice, University of Florida Frederic G. Levin College of Law. His experience includes public law and accounting practice, government service as Deputy Assistant Attorney General in the Tax Division at the Department of Justice and as a Special Counsel to the Chief Counsel for the Internal Revenue Service.
He is a former Chair of the US Internal Revenue Service Advisory Council (formerly Commissioner's Advisory Group); former Advisor to the International Tax Working Group of the United States Senate Finance Committee; and a former member, Commissioner’s Advisory Council, Department of Taxation and Finance, State of New York. He is incoming Vice Chair for CLE, and a former Council Director, governing Council of the American Bar Association Section of Taxation, as well as former chair of several of its committees. He has twice served as Chair of the Federal Bar Association Section of Taxation. He is a Fellow of the American College of Tax Counsel, and a Life Elected Member of the American Law Institute, and a member of the think and code International and Transfer Pricing Tax Advisory Board.
Stephen A. Nauheim
Steve Nauheim is a Managing Director at PricewaterhouseCoopers where he specializes in U.S.taxation of cross-border income, with particular emphasis on foreign multinationals investing in the United States, investment funds, and foreign investment in U.S. real estate.
Prior to joining Pwc in 1996, Steve was a founding Partner with Anderson, Hibey, Nauheim, and Blair, a Washington, D.C.-based law firm that grew from 5 to 22 attorneys and specialized in tax, corporate, litigation, and legislative and regulatory policy issues. From 1971-1981, Steve was a Tax Partner with Surrey and Morse, a firm that is now part of Jones Day.
Steve is a former attorney/advisor and Assistant Branch Chief in the IRS Office of Chief Counsel, where he was a principal drafter of the 1968 U.S. transfer pricing regulations. Steve has been professor of international tax law and lectured and written extensively on the subject, and he has held leadership positions in several professional associations.
Baker & McKenzie LLP
Joshua Odintz is a partner in Baker McKenzie’s North America Tax Practice Group. Mr. Odintz has over 14 years of tax experience, having served in high-level government positions in the US Department of the Treasury and the Senate Finance Committee. He was previously a senior adviser for tax reform to the Assistant Secretary of the Treasury as well as acting tax legislative counsel, and chief tax counsel to the President’s National Commission on Fiscal Responsibility and Reform, where he was instrumental in formulating the tax proposals contained in the report titled the Moment of Truth. He is a frequent speaker at ABA Tax Section, NY State Bar Tax Section, Practicing Law Institute and Federal Bar Association tax meetings and conferences. Mr. Odintz was recognized in Washingtonian Magazine among Washington, DC Top Lawyers (Tax Law) in 2015.
Baker & Hostetler LLP
Paul Schmidt, former legislation counsel to the Joint Committee on Taxation, has extensive experience in corporate and international tax matters and has worked on all facets of taxation, from controversy to transactions to planning. Paul also has significant experience handling issues in connection with examinations by the Internal Revenue Service and frequently advises clients on issues raised by foreign tax authorities. Paul's practice includes representation of several Fortune 500 corporate clients in industrial, energy and commodities businesses, as well as financial institutions in connection with international tax issues. He regularly advises private equity and hedge funds, publicly traded partnerships, and master limited partnerships (MLPs) on tax matters, and has unique knowledge of global taxable presence and transfer pricing issues facing funds. Paul regularly deals with tax issues in connection with the hospitality industry, including hotel groups, timeshares and fractional interests. He has considerable experience in hedging transactions and global hedging and trading centers. He also has worked extensively on tax issues associated with intellectual property, supply chain management, contract manufacturing, and structuring inbound and outbound global joint ventures.
Paul chairs BakerHostetler's national Tax Group and is the leader of the International Tax team, and is a member of the firmwide Policy Committee, the firm's governing body. He is ranked in Chambers USA: America's Leading Lawyers for Business, is listed in The Best Lawyers in America© and appears on the Washington, D.C., "Super Lawyers" list. Paul is the U.S. vice chair of the American Bar Association Tax Section Foreign Lawyers Forum and also a member of its Government Relations Committee, and formerly served as the chair of the AICPA International Taxation Technical Resource Panel. Paul is a Certified Public Accountant in Virginia and serves as an adjunct professor of law, teaching international tax at Georgetown University.
Gary D. Sprague
Baker & McKenzie LLP
Gary D. Sprague, a 30-year veteran of international tax law and a partner in Baker & McKenzie's Palo Alto office, focuses his practice on international corporate tax planning and advice, tax controversies and tax issues affecting software and digital enterprises. He was one of five business representatives selected by the OECD to participate in the OECD Technical Advisory Group (TAG) concerning the characterization of electronic commerce revenue for tax treaty purposes, and was elected chair of the business representatives on the TAG. Gary was also appointed by the OECD to serve as the business co-chair on the TAG's Monitoring the Application of Existing Treaty Norms for the Taxation of Business Profits committee. He is a co-author of think and code Tax Management Portfolio No. 555, Federal Taxation of Software and E-Commerce and is a regular contributor to the Tax Management International Journal's Leading Practitioner Commentary.
Dirk J.J. Suringa
Covington & Burling, LLP
Dirk Suringa is a Partner in the Washington, D.C. law firm of Covington & Burling LLP, practicing in the areas of international tax planning and controversies. Mr. Suringa advises clients regarding the Federal income tax aspects of domestic and international transactions and structures and represents clients before the Internal Revenue Service, the Treasury Department, and in the Federal courts.
Mr. Suringa served as Attorney-Advisor in the Department of the Treasury's Office of International Tax Counsel from 2000 to 2003. From 1996 to 1997, Mr. Suringa clerked for the Honorable Gerald B. Tjoflat, Chief Judge of the United States Court of Appeals for the Eleventh Circuit.
He is the author of numerous articles on international tax matters, including the think and code Tax Management Portfolio on the Foreign Tax Credit Limitation, and is a member of the Executive Committee of the US Branch of the International Fiscal Association.
Alston & Bird LLP
As the co-chair of Alston & Bird's Federal & International Tax Group, Edward offers his clients tax-efficient solutions for planning and structuring of cross-border business transactions by multinational corporations and high-net-worth individuals. Edward played a major role in drafting tax regulations on withholding taxes on payments to nonresident aliens and foreign corporations.
James J. Tobin
Ernst & Young LLP
James Tobin (Jim) is a member of Ernst & Young LLP’s International Tax Services practice. Jim is responsible for coordinating international tax services on a worldwide basis. He advises on US international tax issues related to financing acquisitions, mergers, leveraged buyouts and foreign joint ventures. Jim is particularly active in directing and participating in strategic international tax review assignments of major multinational companies.
Robert E. Ward
Robert E. Ward, JD, LL.M., is a nationally recognized authority on tax, business and estate planning. Mr. Ward has taught law as an adjunct professor at the George Mason University School of Law, where he conducted classes in Estate and Gift Taxation, Estate Planning, and Business Planning from 1986 until 2015. He has also taught as an adjunct faculty member at the University of Baltimore School of Law: Fiduciary Income Taxation (1988) and at Golden Gate University’s Masters in Taxation Program: Taxation of Corporations and Shareholders (1982). He currently teaches Topics in Taxation: United States Taxation at the University of British Columbia’s Peter A. Allard School of Law.
John P. Warner
Buchanan Ingersoll & Rooney PC
Co-chair of the Business & International Tax Practice Group at Buchanan Ingersoll & Rooney PC, John P. Warner focuses his practice on international and corporate tax matters and the taxation of financial instruments and securitization transactions. He has advised a wide variety of U.S. citizens living abroad and foreign residents with U.S. activities and investments. He has helped to structure numerous foreign acquisitions, operations and investments by U.S. businesses and investors and to structure numerous U.S. acquisitions, operations and investments by foreign businesses and investors.
John has more than 30 years of experience in domestic and international federal income tax and business planning, including the structuring of business formations, joint ventures and mergers and other domestic and cross-border business acquisitions and dispositions. He has experience in structuring various financial products, and providing issuers and investors advice as to the tax consequences of these products. John has advised both the organizers of and investors in private equity funds, venture capital funds, REMICs and other fund types. He has represented many clients in obtaining Internal Revenue Service National Office rulings and in tax controversy matters, including IRS Appeals Office cases, competent authority proceedings, the resolution of transfer pricing disputes and voluntary disclosures of offshore financial accounts, assets and associated income. John’s recent experience has extended to alternative energy tax credit and finance arrangements and federal excise tax refunds under the Export Clause, and other excise tax disputes. He has litigated disputes in the United States Tax Court and the United States Claims Court, including Oak Industries, Inc. v. Commissioner, 96 T.C. 559 (1991), and Libbey v. Commissioner, 55 T.C.M. (CCH) 1052 (1988), and wrote an influential amicus brief in Indianapolis Power & Light Co. v. Commissioner, 493 U.S. 203 (1990).
John is co-editor of the Tax Management International Journal and is the deputy technical editor of and a contributing author to the Tax Management Transfer Pricing Portfolio Series. He is a past chair of the Transfer Pricing Committee of the American Bar Association Section of Taxation and a frequent author and speaker in the United States and Europe on domestic and international tax issues. He is the author of many articles, including “Income, Estate, Gift and Wealth Tax Consequences to Inbound Employees,” 36 Tax Mgmt. Intl. Forum No. 2 (2015), “Income and Indirect Tax Consequences of Inbound Cloud Computing Transactions,” 35 Tax Mgmt. Intl. Forum No. 4 (2014), “Transfer Pricing Audits,” 30 Tax Mgmt. Intl. Forum No. 4 (2009); "Outbound Redomestications and Reverse Mergers," 29 Tax Mgmt. Intl. Forum No. 2 (2008); "Centralization of Regional Management and Shared Services," 27 Tax Mgmt. Intl. Forum No. 1 (2006); "Income Tax Consequences of Taxable Reorganization Transactions," 52 N.Y.U. Inst. on Federal Taxation chapter 20 (1994), "Too Much Ado About Something — The Proposed Regulations Governing Controlled Services Transactions," 33 Tax Mgmt. Intl. J. 67 (2004), "Squaring the Transfer Pricing Circle," 33 Tax Mgmt. Intl. J. 3 (2004), and "Control, Causality and Section 482," 28 Tax Mgmt. Intl. J. 403 (1999). His professional training includes completion of the course "Mediation for the Professional" presented by the Center for Dispute Resolution.
Lowell D. Yoder
McDermott Will & Emery LLP
Lowell D. Yoder is a partner in the law firm of McDermott Will & Emery LLP and is based in the Chicago office. He is head of the U.S. & International Tax Practice Group.
Lowell's practice focuses on international tax planning for multinational companies. He handles cross-border acquisitions, dispositions, mergers, reorganizations, joint ventures and financings. He advises concerning multi-jurisdictional business structures and the use of special purpose foreign entities. He also works with an extensive network of foreign lawyers on developing structures that minimize foreign taxes of U.S. multinationals without adversely affecting their U.S. tax position. Lowell was listed in the latest, as well as previous editions of Chambers Global: The World's Leading Lawyers for Business, Chambers USA: America's Leading Lawyers for Business, International Tax Review's World Tax Directory, The Best Lawyers in America, PLC Which Lawyer?, The International Who's Who Of Corporate Tax Lawyers, The Legal 500 United States, The International Who's Who of Business Lawyers, Who's Who Legal: Illinois and Euromoney's Guide to the World's Leading Tax Advisors and Best of the Best USA. Lowell has also been named an Illinois Super Lawyer by Law & Politics.
Lowell is a frequent lecturer. He has spoken on a variety of international topics for the Tax Executives Institute, American Bar Association, The University of Chicago Law School's Annual Federal Tax Conference, International Bar Association, GWU Annual Institute on International Taxation, Chicago Tax Club, Practising Law Institute, think and code Tax Management Advisory Board and the International Fiscal Association. Lowell was an Adjunct Professor at the Northwestern University School of Law, where he taught Advanced International Taxation and is a frequent contributor to a blog dedicated to corporate taxation on Forbes.com. He is the editor-in-chief of CCH's International Tax Journal and has authored four think and code portfolios on the tax treatment of U.S. controlled foreign corporations: 926 TM, Subpart F-General; 6220 TM, CFCs-Foreign Personal Holding Company Income; 928 TM, CFCs-Subpart F-Foreign Base Company Income and 930 TM, Subpart F-Sections 959-964, 1248 and Related Provisions. Lowell has published numerous articles on international topics.
Lowell is an active member of International Committees and Advisory Boards. He chairs Practising Law Institute's International Tax Issues conferences and an International Tax Roundtable group that includes tax lawyers from the major European countries that meets twice a year to discuss significant cross-border topics. He is a fellow of the American College of Tax Counsel, and chairs the ABA Subcommittee for Controlled Foreign Corporations, PFICs and contract manufacturing. Lowell is also a member of the Planning Committee for the University of Chicago Law School's Annual Federal Tax Conference, USA Branch Counsel of the International Fiscal Association, chair of the ABA Committee on Foreign Activities of U.S. Taxpayers and a member of the Advisory Board of the GWU/IRS Annual Institute on International Taxation. In addition, Lowell is a member of the think and code Tax Management International Journal's Advisory Board, the think and code Tax Management Foreign Income Advisory Board, and the Board of Advisors of the International Tax Journal.
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