Advanced International Taxation 2026 (presented by NYU School of Professional Studies)

Joseph M. Calianno, JD, LLM, MBA, CPA, Managing Director; National Tax Practice | Andersen Tax

Joseph Calianno is a Managing Director in Andersen’s US National Tax practice in the Washington, D.C. office, where he serves as the practice’s leader for international tax. He counsels clients across the full range of international tax matters, including the provisions enacted under the Tax Cuts and Jobs Act and cross-border restructurings.

• Education & Credentials

Mr. Calianno earned his B.S. in Accounting from the University of Scranton, his J.D. from Villanova University School of Law, where he served on the Villanova Law Review, his LL.M. in Taxation from New York University School of Law, and his MBA from New York University’s Leonard N. Stern School of Business. He is also a certified public accountant.

• Recognition & Leadership

Mr. Calianno has held leadership positions in the profession’s principal tax bodies, including as Past Chair of the American Bar Association Tax Section’s Foreign Activities of U.S. Taxpayers committee, Past Chair and Vice Chair of the AICPA’s International Tax Technical Resource Panel, and Co-Chair of the International Tax Section of the Federal Bar Association’s Annual Tax Law Conference, where he serves as an Advisory Board member.

• Professional Involvement

Mr. Calianno is a member of the ABA Tax Section, the International Fiscal Association (as a member of the IFA USA Branch Council), and the AICPA, where he previously served on the Tax Executive Committee. He has been a guest lecturer in New York University Law School’s Graduate Tax Program (International Business Transactions) and an adjunct faculty member in Georgetown Law School’s Graduate Tax Program. He is a frequent speaker on international tax issues and is regularly quoted in the tax press on international tax developments.

• Experience

Before joining Andersen, Mr. Calianno was a partner at both BDO and Grant Thornton, serving as the International Technical Tax Practice Leader in each firm’s national tax office. He previously served as Special Counsel to the Deputy Associate Chief Counsel (International) in the IRS Office of Chief Counsel, where he acted as a technical advisor, reviewed international tax regulations, revenue rulings, notices, TAMs, and PLRs, and provided technical advice to IRS field offices. Earlier in his career, he practiced with PwC’s national tax office and with the law firm Miles & Stockbridge. He has published numerous articles in national journals.

Sean Dokko, JD, LLM, Managing Director; National Tax Practice | Andersen Tax

Sean Dokko is a Managing Director in the Private Client Services practice at Andersen. He advises high-net-worth individuals, families, closely held businesses, family offices, and fiduciaries on sophisticated estate, gift, income, and generation-skipping transfer tax planning. Sean’s practice focuses on developing customized wealth transfer strategies, business succession planning, trust and estate planning, and charitable planning designed to preserve and efficiently transfer wealth across generations. He works closely with clients and their advisors to create integrated tax and estate planning solutions that address both personal and business objectives.

• Education & Credentials

Sean earned his Juris Doctor from Loyola Law School and his Bachelor of Arts from University of California, Los Angeles. He is admitted to practice law in California and is also licensed as a Certified Public Accountant (CPA). His combined legal and accounting background enables him to provide comprehensive advice on complex tax, estate, and wealth planning matters.

• Recognition & Leadership

As a Managing Director in the Private Client Services practice at Andersen, Sean serves in a leadership role advising clients on sophisticated wealth transfer and tax planning strategies. His dual qualifications as both an attorney and CPA, combined with his experience counseling high-net-worth families and business owners, position him as a trusted advisor on complex estate and tax planning matters.

• Professional Involvement

Sean is actively involved in advising clients and professional advisors on trusts and estates, taxation, and wealth preservation strategies. He regularly works with attorneys, accountants, financial advisors, and family offices to coordinate comprehensive estate, gift, and income tax planning solutions. Through his practice, he assists clients with implementing tax-efficient wealth transfer strategies and business succession plans tailored to multigenerational planning objectives.

• Experience

Sean has extensive experience advising high-net-worth individuals, families, fiduciaries, family offices, and closely held business owners on sophisticated estate and tax planning matters. His practice includes estate and gift tax planning, generation-skipping transfer tax planning, business succession planning, charitable planning, trust and estate planning, fiduciary income tax matters, and wealth preservation strategies. Drawing on his background as both an attorney and CPA, he develops integrated legal and tax solutions that help clients minimize transfer taxes, preserve family wealth, and achieve long-term succession and philanthropic goals.

Enrica Ma, Esq., Principal, National Tax Department, International Tax and Transaction Services | EY

Enrica Ma is a Principal in the National Tax practice at Ernst & Young LLP in Washington, D.C. She advises multinational corporations on complex U.S. and international tax matters, with a practice focused on cross-border acquisitions and divestitures, internal restructurings, intellectual property planning, supply chain planning, and tax-efficient repatriation strategies. Enrica regularly counsels clients on the international tax provisions enacted under the Tax Cuts and Jobs Act of 2017, including foreign tax credits, expense apportionment, BEAT, FDII, and GILTI planning. She also has significant experience advising pharmaceutical, medical device, and life sciences companies on corporate and international tax issues, including licensing and collaboration transactions.

• Education & Credentials

Enrica is a tax professional whose practice focuses on U.S. and international corporate taxation, particularly for multinational enterprises. Prior to joining Ernst & Young LLP in January 2022, she served as an international tax partner at a law firm and previously worked as in-house tax counsel for a Fortune 100 company. (The information provided does not include details regarding her educational background or professional licenses.)

• Recognition & Leadership

As a Principal in the National Tax practice at Ernst & Young LLP, Enrica serves in a leadership role advising multinational corporations on sophisticated international tax planning and transactional matters. Before joining EY, she served as the engagement partner for multiple clients, including several Fortune 500 companies, reflecting her extensive experience leading complex tax engagements for global organizations.

• Professional Involvement

Enrica works closely with multinational corporations on a broad range of international tax planning and transactional matters. Her practice includes advising clients on evolving international tax rules, crossborder business structures, and strategic tax planning for global operations. She has developed particular experience serving clients in the pharmaceutical, medical device, and life sciences industries, where she advises on corporate tax matters as well as licensing and collaboration transactions.

• Experience

Enrica has extensive experience advising multinational corporations on cross-border acquisitions, divestitures, internal restructurings, intellectual property planning, supply chain planning, and tax-efficient repatriation strategies. She regularly counsels clients on international tax issues arising under the Tax Cuts and Jobs Act of 2017, including foreign tax credits, expense apportionment, BEAT, FDII, GILTI planning, and transaction structures involving intellectual property onshoring. Prior to joining EY, she served as an international tax partner at a law firm, leading engagements for numerous Fortune 500 companies, and previously worked as in-house tax counsel for a Fortune 100 company, providing her with both private practice and in-house perspectives on complex international tax matters.

Brandon C. Svetcov, Esq., Principal, International Tax Services | EY

Brandon C. Svetcov is an attorney with Ernst & Young LLP in New York, where he advises clients on complex tax and legal matters. His practice focuses on helping businesses navigate sophisticated legal and regulatory issues through strategic planning and practical solutions. As part of EY’s tax practice, Brandon works with clients on matters involving corporate and transactional tax issues, drawing on his legal background to provide integrated business and tax advice.

• Education & Credentials

Brandon earned his Juris Doctor from Benjamin N. Cardozo School of Law and was admitted to practice law in New York in 2010 by the Appellate Division, Second Judicial Department. He is currently registered as an attorney in New York and practices with Ernst & Young LLP.

• Recognition & Leadership

Brandon serves as an attorney within the tax practice at Ernst & Young LLP, advising clients on complex legal and tax matters. He has also participated in professional educational programs and industry webcasts, contributing his knowledge on evolving tax and legal developments. (The information provided does not identify any verified awards, honors, or formal leadership positions.)

• Professional Involvement

Brandon is actively engaged in professional education through his participation in industry webcasts and events focused on legal and tax developments. His work reflects an ongoing commitment to helping clients understand changing regulatory and tax issues while supporting practical business solutions. (The information provided does not identify memberships in professional organizations or publications.)

• Experience

Brandon has practiced law in New York since 2010 and is currently an attorney with Ernst & Young LLP. His experience includes advising clients on legal and tax matters within EY’s professional services practice, where he assists businesses in addressing complex corporate, transactional, and regulatory issues through strategic legal and tax planning.

Thomas M. Giordano-Lascari, Esq., Partner | Greenberg Glusker

Thomas Giordano-Lascari is a Partner in Greenberg Glusker’s Private Client Services Group with nearly two decades of experience counseling high-net-worth individuals and closely held businesses on international income tax and estate planning matters. Well known for his work with global families whose holdings span multiple jurisdictions, he helps clients structure worldwide assets to advance family objectives while minimizing income and transfer taxes, and regularly handles pre-immigration planning, foreign investment in the United States, U.S. residency planning and management, and expatriation planning. He is a sought-after advisor on foreign trusts, guiding foreign fiduciaries, U.S. beneficiaries, and grantors through compliance obligations and tax consequences.

• Education & Credentials

Mr. Giordano-Lascari received his LL.M. in Taxation from Loyola Law School in 2008 and his J.D. from the University of New Mexico School of Law in 2005, where he was a staff member and manuscript editor of the New Mexico Law Review and served as an extern to Justice Bosson of the New Mexico Supreme Court. He earned his BBA in Finance from the University of New Mexico in 2003. He is admitted to the California Bar and to practice before the U.S. District Court for the Central District of California and the U.S. Tax Court.

• Recognition & Leadership

Mr. Giordano-Lascari is Chair of the Los Angeles Chapter of the Society of Trust & Estate Practitioners (STEP). He is recognized in the Chambers High Net Worth Guide as a leading lawyer in Private Wealth Law (2024–2025), listed in The Legal 500 US Elite Los Angeles for Tax (2026) and the ALM/Law.com Private Client Global Elite/Excellence Directory (2026), and named in The Best Lawyers in America for Trusts and Estates (2023–2026) and Southern California Super Lawyers (2025–2026), after earlier recognition as a Super Lawyers Rising Star (2019–2021). In 2022, the Los Angeles Business Journal included him among its “Leaders of Influence: Thriving in Their 40s.”

• Professional Involvement

Mr. Giordano-Lascari is a member of the International Academy of Estate and Trust Law and of STEP, where he serves as Program Chair on the STEP Los Angeles Executive Committee. He sits on the Executive Committee of the Los Angeles County Bar Association’s Taxation Section and belongs to the International Young Lawyers Association (AIJA), serving on its Taxation and Private Client Committees. His past leadership includes chairing the LACBA Taxation Section’s Young Tax Lawyers Subcommittee, the State Bar of California Taxation Section’s International Tax Subcommittee, and the Beverly Hills Bar Association Taxation Section’s Executive Committee, as well as membership on the State Bar of California Taxation Section’s Executive Committee. He speaks frequently on international tax legislation and strategies involving foreign trusts, outbound planning, and GILTI inclusions.

• Experience

Mr. Giordano-Lascari’s published work includes articles in Bloomberg Tax, among them a 2024 piece analyzing the United Nations’ wealth tax framework and its implications for high-net-worth U.S. assets and a 2023 article on the Supreme Court’s review of the mandatory repatriation tax in Moore v. United States.

Michael J.A. Karlin, Esq., Partner | Holland & Knight

Michael J.A. Karlin is a private wealth services and tax attorney in Holland & Knight’s Century City office. He advises corporate and individual clients on tax, estate planning, and business matters that involve a cross-border element. For more than 45 years, his practice has centered on private client work: he counsels individuals and families from abroad who invest in or move to the United States, as well as U.S. individuals and families investing or moving abroad, including on the ever-increasing regulatory and reporting obligations these activities carry. Pre-immigration and expatriation planning form an important part of his practice.

• Education & Credentials

Mr. Karlin earned his M.A. and his B.A. in History and Law, with honors, from Cambridge University. He is admitted to the California Bar and to practice before the U.S. Tax Court and the U.S. District Court for the Central District of California. He speaks French.

• Recognition & Leadership

Mr. Karlin was elected a Fellow of the American College of Tax Counsel in 2020. He has been recognized in The Best Lawyers in America as a Leading Lawyer in Tax Law (2016–2026) and in Trusts and Estates (2026), in the Chambers High Net Worth guide for Private Wealth Law – California: Southern (2022–2025), in The Legal 500 USA as a Leading Lawyer in U.S. International Tax (2024), in Southern California Super Lawyers for Taxation (2015–present), and in Who’s Who Legal: Private Client (2020). He also led a national group that obtained IRS relief on the application of U.S. tax residence rules for noncitizens stranded in the United States during the COVID-19 pandemic.

• Professional Involvement

Mr. Karlin is a member of the American Bar Association, the Society of Trust and Estate Practitioners (STEP), the USC Gould School of Law Institute on Federal Taxation, and the Los Angeles County Bar Association. He is a regular speaker on tax, estate planning, and business issues, has contributed articles to publications including Tax Notes, Tax Lawyer, Journal of International Taxation, Tax Management International Journal, and Major Tax Planning, and has been involved in submitting numerous comments on tax legislation, regulations, and tax reform. His community service includes serving as Board Chair and Treasurer of Invertigo Dance Theatre (2007–2020), Docent Council Webmaster at the Los Angeles County Museum of Art (2004–2023), and in numerous board positions with the American Youth Soccer Organization, Region 76 (1990–present).

• Experience

Mr. Karlin has advised individuals and closely held businesses on the tax and business aspects of operating outside their home jurisdictions, helped establish corporations, companies, partnerships, and joint ventures in many parts of the world, and worked extensively with foreign and domestic trusts. In recent years he has helped many taxpayers address the tax and reporting consequences of foreign financial accounts and holdings, including through offshore voluntary disclosures, streamlined disclosures, and other means of resolving noncompliance. Before joining Holland & Knight, he was a founder of and attorney at a boutique private wealth services law firm in Los Angeles.

William S. Dixon, Esq., Managing Director, Mergers and Acquisitions | Citigroup Global Markets

Will Dixon is a Managing Director at Citigroup Global Markets Inc., where he advises clients on complex tax-advantaged domestic and cross-border mergers and acquisitions, capital structure solutions, and financings. His practice encompasses public and private company transactions, including mergers, acquisitions, spin-offs, divestitures, buyouts, and SPAC transactions. In addition to his transactional practice, Will serves on the firm’s Fairness Opinion Committee and is widely recognized for his extensive knowledge of U.S. federal income taxation, combining experience in investment banking, legal practice, and academia.

• Education & Credentials

Will earned his Juris Doctor, magna cum laude, from Boston University School of Law. Before transitioning to investment banking, he practiced as a Senior Attorney at Cravath, Swaine & Moore LLP in New York City, where he developed significant experience in sophisticated tax matters that continues to inform his work advising clients on complex transactions.

• Recognition & Leadership

Will serves as a member of the Fairness Opinion Committee at Citigroup Global Markets Inc. and has held numerous leadership positions within the tax profession. He has served on the Board of Directors of the International Tax Institute and on the New York Steering Committee of the International Fiscal Association. He is a former Chair of the U.S. Activities of Foreigners and Tax Treaties Committee of the American Bar Association Section of Taxation, previously served on the ABA’s Task Force on International Tax Reform, and is a former John S. Nolan Fellow.

• Professional Involvement

Will has made significant contributions to tax education and the legal profession through his teaching and speaking activities. He has served as an adjunct assistant professor at Brooklyn Law School, teaching courses on the taxation of securities, derivatives, and partnerships, and has also taught as an adjunct at the Peter J. Tobin College of Business at St. John’s University. In addition, he has delivered guest lectures at numerous institutions, including Harvard Law School and New York University Leonard N. Stern School of Business. He is also a frequent speaker at conferences and professional forums on U.S. federal income tax matters.

• Experience

Will advises public and private companies on a broad range of sophisticated domestic and cross-border transactions, including mergers and acquisitions, spin-offs, divestitures, buyouts, SPAC transactions, capital structure solutions, and financings. His practice emphasizes tax-efficient transaction structuring and strategic planning for complex corporate transactions. Before joining Citigroup Global Markets Inc., he practiced as a Senior Attorney at Cravath, Swaine & Moore LLP, where he focused on complex tax matters. His combined experience in private legal practice, investment banking, and academia provides him with a multidisciplinary perspective on transactional tax planning and corporate finance.

Sam K. Kaywood, Esq., Partner | Alston & Bird

Sam Kaywood is Senior Counsel in Alston & Bird’s Federal & International Tax Group and a co-chair of the firm’s International Team. Over a career spanning more than 30 years, he concentrated his practice on federal income tax and international tax, including cross-border M&A and joint ventures and inbound investment into the United States, offering an innovative approach to complicated federal and international tax issues wherever his clients’ global business objectives took them. He worked on virtually all forms of cross-border investment, with substantial experience in Canada, Europe, China, and Latin America, and was particularly active structuring investments and acquisitions in Latin America, including Brazil, Mexico, Argentina, and Chile.

• Education & Credentials

Mr. Kaywood received his J.D. from Emory University in 1986 and his B.S. from Babson College in 1979. He is admitted to the Georgia Bar.

• Recognition & Leadership

Mr. Kaywood has been listed in Chambers USA: America’s Leading Lawyers for Business since 2006 and in Chambers Global since 2011, and is recognized in The Best Lawyers in America for Tax, which named him “Lawyer of the Year” in Tax Law for 2021. He served as chair of the ABA Tax Section Committee on U.S. Activities of Foreigners & Tax Treaties.

• Professional Involvement

Mr. Kaywood is a member of the International Bar Association, the ABA Tax Section, and the International Fiscal Association, where he has been active, and serves on the advisory board of the CCH International Tax Journal. He is an adjunct professor at Emory University School of Law, where he teaches International Tax, and is a frequent author and speaker on international tax topics, having addressed organizations such as the International Bar Association, the International Fiscal Association, the ABA Tax Section, the Tax Executives Institute, and the Atlanta Tax Forum Georgia Federal Tax Conference in cities across the country and abroad.

• Experience

Mr. Kaywood’s representative work includes structuring the $500 million sale of a multinational food and beverage company’s operations in Ireland, Spain, and the Netherlands and defending the related IRS audit; representing a U.S. manufacturer in acquisitions and restructurings over 13 years, including a $2.5 billion acquisition of European operations; representing a worldwide financier in investments across 25 countries; handling international restructurings responding to the Tax Cuts and Jobs Act of 2017, including hybrid entities and instruments, OECD BEPS, and ATAD II; handling numerous IRS audits at the Exam and Appeals levels over more than 32 years; working on international technology-related arrangements, including offshore licensing and R&D structures; and defending a $58 million foreign tax credit position before the IRS.

William B. Sherman, Esq., Partner | Holland & Knight

William B. Sherman is a partner in Holland & Knight’s Miami and Fort Lauderdale offices, where he concentrates his practice on domestic and international taxation. He provides sophisticated tax planning for mergers and acquisitions, restructurings, joint ventures, and investments for clients in industries as diverse as private equity, healthcare, hospitality, petrochemicals, aluminum, real estate, transportation, telecommunications, retailing, investment management, and pharmaceuticals. His work spans U.S. investment overseas and foreign investment in the United States, along with international, federal, state, and local tax issues involving investment management fund structuring, corporate reorganizations, partnerships, equipment leasing, Subchapter S, executive compensation, stock options, and trusts and estates.

• Education & Credentials

Mr. Sherman received his LL.M. in Taxation from New York University School of Law, his J.D., with honors, from Brooklyn Law School, and his B.A., cum laude, from Brooklyn College of the City University of New York. He is admitted to practice in Florida and New York.

• Recognition & Leadership

Mr. Sherman chairs New York University’s Summer Institute in Taxation Introductory and Advanced International Tax Seminars and its Institute on Federal Taxation International Tax Program, and served as Co-Chair of the NYU School of Professional Studies 84th Institute on Federal Taxation in 2025. He is a Fellow of the American College of Tax Counsel and a past chair of the ABA Tax Section’s Committee on U.S. Activities of Foreigners and Tax Treaties. His recognitions include Chambers USA for Tax (2009–2026), The Legal 500 USA for International Tax and U.S. Non-Contentious Tax (2023–2026), The Best Lawyers in America for Litigation and Controversy – Tax (2005–2026), Tax Law (2013–2026), and Closely Held Companies and Family Business Law (2014–2026), including Fort Lauderdale “Lawyer of the Year” honors in Litigation and Controversy – Tax (2020, 2022), Lawdragon 500 Leading Global Tax Lawyers (2025–2026), Who’s Who Legal for Corporate Tax (2018) and Corporate Tax – Advisory (2019, 2022), Who’s Who Legal Florida for Corporate Tax (2020), Fort Lauderdale Illustrated Top Lawyer for Tax Law (2020), Florida Super Lawyers (2015–2019), and a Martindale-Hubbell AV Preeminent peer review rating.

• Professional Involvement

Mr. Sherman serves on the Advisory Board of New York University’s Institute on Federal Taxation and is a member of the New York State Bar Association Tax Law Section, the International Fiscal Association, and The Florida Bar Tax Law Section. A well-known lecturer, he has served on numerous panels with The Florida Bar and the American Bar Association.

• Experience

For 12 years, Mr. Sherman was an adjunct professor of Tax Law in the University of Miami’s Graduate Tax Program. His representative engagements include advising a leading physician-led nephrology organization on a strategic private equity investment, including structuring ongoing acquisitions and negotiating transaction documents; advising an investor in North American renewable energy projects on investment structuring; advising a private equity manager with more than $2 billion in capital on the sale of a majority equity stake; structuring the domestication of a foreign company engaged in U.S. government contracting while preserving its home-country status; structuring a $200 million-plus investment in four Caribbean resort real estate developments to minimize local and U.S. tax; and advising a foreign-based company on multistate U.S. tax issues in connection with its restructuring and U.S. expansion.

Adam Bair, Esq., Principal, National Tax Services | PwC

Adam Bair is a Principal in the National Tax Services practice at PwC, based in New York. He advises multinational businesses on complex U.S. and international tax matters, with a practice focused on international tax consulting, cross-border transactions, global business restructurings, and technical tax advisory services. Adam works closely with multinational enterprises to navigate evolving international tax rules and develop taxefficient strategies for global operations and business transactions.

• Education & Credentials 

Adam earned his Juris Doctor from University of Miami School of Law. He is admitted to practice law in Florida and has built his career advising multinational corporations on sophisticated international tax planning, compliance, and cross-border business matters.

• Recognition & Leadership

As a Principal in the National Tax Services practice at PwC, Adam serves in a leadership role providing technical tax guidance to multinational businesses on complex international tax issues. His practice emphasizes strategic tax planning for global enterprises, including cross-border transactions, international restructurings, and evolving U.S. international tax rules.

• Professional Involvement

Adam contributes to the international tax field through his legal scholarship and thought leadership. He has authored publications addressing international tax and corporate governance, including Objective Corporate Governance (2010), which examined corporate governance reforms in Japan aimed at encouraging foreign investment, and The Inevitable Hike (2010), which analyzed proposed increases to Japan’s consumption tax and their potential economic impact. His work reflects an ongoing interest in international taxation, global business policy, and comparative corporate governance.

• Experience

Adam advises multinational corporations on a broad range of international tax matters, including international tax planning, cross-border tax consulting, U.S. international tax compliance, global business restructurings, and the tax implications of international business structures and transactions. As a Principal at PwC, he helps clients navigate the complexities of cross-border operations and changing international tax regimes, providing strategic guidance on tax-efficient structures for multinational enterprises.

Steven Burns, CPA, Director, National Tax Services | PwC

Steven Burns, CPA, is a tax professional with an extensive career at PwC, where he served as a Tax Partner for more than 19 years. His professional background includes significant experience in tax services and a long-standing tenure with the firm, culminating in his retirement from PwC on December 31, 2020.

• Education & Credentials

Steven Burns is a Certified Public Accountant (CPA), reflecting his professional credential in the accounting and tax field.

• Recognition & Leadership

Steven Burns served as a Tax Partner at PwC for more than 19 years, demonstrating his senior-level role and leadership within the firm’s tax practice.

• Professional Involvement

Steven Burns has maintained a professional presence through his LinkedIn profile, where he showcases his extensive professional network and experience in tax services.

• Experience

Steven Burns built his career at PwC, serving as a Tax Partner for over 19 years. His tenure at the firm focused on tax services and concluded with his retirement on December 31, 2020.

Alan I. Appel, Esq., Professor of Law | New York Law School

Alan I. Appel is Professor of Law and Director of the International Tax Program at New York Law School. He specializes in international and domestic tax planning involving the taxation of mergers and acquisitions, partnerships, joint ventures, and limited liability companies, as well as tax controversy matters.

• Education & Credentials

Professor Appel received his LL.M. from New York University in 1980, his J.D. from New York Law School in 1976, and his B.B.A. from Baruch College in 1973.

• Recognition & Leadership

Professor Appel is a Fellow of the American College of Tax Counsel. On behalf of the ABA Tax Section, he had primary responsibility for drafting and submitting comments to the U.S. Treasury Department and the IRS on the scope of guidance under the proposed Section 1446 regulations, and the IRS Office of Chief Counsel asked him to train its attorneys on the issue. He formerly served as Council Director of the ABA Tax Section’s U.S. Activities of Foreigners and Tax Treaties Committee, Foreign Activities of U.S. Taxpayers Committee, Transfer Pricing Committee, and Foreign Lawyers Forum, and as Chair of the U.S. Activities of Foreigners and Tax Treaties Committee.

• Professional Involvement

Professor Appel serves on the Board of Advisors of the Journal of International Taxation. He has appeared on radio and television to discuss income tax issues, including a feature in AccountingToday.com on the Foreign Account Tax Compliance Act’s requirements. At NYLS he teaches Commercial Law, Federal Income Tax (Corporate and Individual), International Taxation, and the International Tax Planning Seminar.

• Experience

Professor Appel began his career as a trial attorney in the IRS Office of Chief Counsel in Washington, D.C. and New York City, and spent 13 years as Counsel at Bryan Cave Leighton Paisner LLP (formerly Bryan Cave LLP) before joining New York Law School, first as an adjunct professor in 2009 and then full-time in 2013. His extensive publications include chapters in the New York University Institute on Federal Taxation and articles in Tax Notes, Tax Notes International, The Journal of Taxation, Tax Management Memorandum, Tax Management International Journal, The Journal of International Taxation, and the New York Law Journal, among others, including a 2021 article co-authored with Michael Karlin on gain or loss of foreign persons from the sale or exchange of partnership interests.

Heather Ripley, Esq., Partner | Alston & Bird

Heather Ripley is a partner in Alston & Bird’s Federal & International Tax Group and a member of the firm’s REITs and Real Estate Funds tax team. She helps U.S. and foreign business entities and high-net-worth individuals navigate U.S. federal and international tax law, counseling on tax-efficient structuring of U.S. and cross-border investments and activities, U.S. tax and compliance obligations and risks, and the correction of noncompliance. Her advisory work covers income tax treaty application, FATCA, FIRPTA, and other inbound investment issues, the CFC and PFIC anti-deferral regimes for outbound investments, tax aspects of M&A transactions, and tax information reporting regimes.

• Education & Credentials

Ms. Ripley received her J.D. from Harvard University in 2009 and her Master of Accountancy and B.B.A. from the University of Georgia in 2006. She is admitted to the New York Bar.

• Recognition & Leadership

Ms. Ripley has been recognized by The Best Lawyers in America in Tax Law and as a New York Law Journal Rising Star. She chairs the ABA Tax Section’s Committee on Foreign and U.S. Taxation – Individuals and Passthroughs and serves as International Organizations liaison officer for the International Bar Association’s Taxes Committee.

• Professional Involvement

Ms. Ripley is a member of the New York State Bar Association’s Tax Section and Under 10 Club, the Harvard Club of New York, and the University of Georgia Terry College of Business Alumni, and serves on the board of Volunteers of Legal Service (VOLS). She is a frequent speaker at tax conferences and writes regularly on international tax developments, and has provided volunteer income tax assistance for low-income individuals.

• Experience

Ms. Ripley has significant federal tax controversy experience, having guided numerous clients through IRS voluntary disclosure procedures, letter rulings, and competent authority requests, and has counseled charitable and nonprofit organizations on incorporation, tax exemption applications and restrictions, and related tax issues. Her representative matters include serving as U.S. tax counsel to one of the largest foreign multinational financial services groups, representing significant European multinationals on their U.S. structures, restructurings, and operations, and advising European funds and their advisors on optimal tax structures, subscription agreements, and tax certifications.

Sean J. Tevel, Esq., Partner | Holland & Knight

Sean Tevel is a private wealth services and international tax attorney in Holland & Knight’s Miami office. He advises foreign and domestic clients on U.S. federal income, gift, and estate tax matters associated with their cross-border investments and businesses. His international tax practice includes advising on multinational trust and business structures, including the controlled foreign corporation rules, the Passive Foreign Investment Company (PFIC) rules, and international tax treaties.

• Education & Credentials

Mr. Tevel received his LL.M. in Taxation and his J.D., cum laude, from the University of Miami School of Law, and his B.A. in Economics and Political Science from McGill University. He is admitted to The Florida Bar and speaks French.

• Recognition & Leadership

Mr. Tevel is recognized in the Chambers USA guide for Tax (2022–2026) and the Chambers High Net Worth guide for Private Wealth Law: Florida (2024–2025), where industry sources have praised his ability to solve complex cross-border tax matters. He was named among The Best Lawyers in America Miami Tax Law “Ones to Watch” (2021–2024) and a Florida Super Lawyers Rising Star (2020).

• Professional Involvement

Mr. Tevel is a member of the Society of Trust and Estate Practitioners (STEP) and of The Florida Bar’s Tax Section and International Law Section.

• Experience

Mr. Tevel has significant experience structuring U.S. real estate investments, including the application of the Foreign Investment in Real Property Tax Act of 1980 (FIRPTA). He frequently represents domestic and foreign funds on fund formation and structuring considerations for non-U.S. investors, regularly advises on domestic and cross-border joint venture transactions, and has assisted many clients in establishing Qualified Opportunity Funds and maximizing the tax benefits of Opportunity Zone investments. Before joining Holland & Knight, he was a tax attorney in the Miami office of an international law firm.

Jason Schwartz, Esq., Partner | Cahill Gordon & Reindel

Jason Schwartz is a tax partner in CahillNXT, Cahill’s premier practice for Digital Assets and Emerging Technology, based in Washington, D.C. He specializes in tax issues relating to digital assets, financial products, securitizations, funds, treaties, and lending.

• Education & Credentials

Mr. Schwartz received his LL.M. from New York University School of Law, his J.D., magna cum laude and Order of the Coif, from American University Washington College of Law, and his B.A., cum laude, from New York University. He is admitted to practice in New York and the District of Columbia.

• Recognition & Leadership

Mr. Schwartz is ranked by Chambers USA, Legal 500 US, and Best Lawyers, and Chambers USA sources have singled him out as a resource for sophisticated tax planning relating to cryptocurrency. He oversees Cahill’s 501Foundry, a pro bono program that incorporates, advises, and obtains tax exemption for charitable and other nonprofit organizations; under his ten-plus years of oversight, the program has helped hundreds of charitable organizations obtain tax-exempt status.

• Professional Involvement

Mr. Schwartz is frequently asked to speak on panels and podcasts across a wide range of tax topics and is committed to pro bono work and community service.

• Experience

Mr. Schwartz has authored numerous tax articles, a Bloomberg BNA Tax Management Portfolio on the taxation of CLOs, and a Practising Law Institute chapter on the taxation of digital assets. Before joining Cahill, he was a partner at a large international law firm.

Matthew Stevens, Esq., Principal | EY

Matthew Stevens is a Principal in EY’s International Tax and Transaction Services practice in Washington, D.C. He advises multinational corporations, financial institutions, and investment clients on complex U.S. and cross-border tax matters, with a particular focus on international taxation, financial products, capital markets transactions, and tax controversy. Throughout his career, he has built a distinguished reputation for his work in international tax, financial products, and tax policy, combining experience in private practice, government service, academia, and the financial services industry.

• Education & Credentials

Matthew Stevens earned his J.D. from Harvard Law School and his B.A. from the University of Kansas.

• Recognition & Leadership

Matthew is widely recognized for his leadership in the tax profession. He serves as Chair of the annual Practising Law Institute program Taxation of Financial Products and Transactions and previously chaired the Financial Transactions Committee of both the American Bar Association Section of Taxation and the District of Columbia Bar Tax Section. He has also been recognized by Chambers USA: America’s Leading Lawyers for Business for his work in tax law.

• Professional Involvement

Matthew has co-taught United States Taxation of International Income II at Georgetown University Law Center and has authored numerous publications on international tax and the taxation of financial products. His professional involvement reflects his commitment to legal education and advancing thought leadership in the field of taxation.

• Experience

Before joining EY, Matthew served as Special Counsel to the Chief Counsel of the Internal Revenue Service, where he advised on published guidance involving financial products and cross-border transactions. He has also held senior positions in private practice and the financial services industry, bringing extensive experience to his work advising clients on complex domestic and international tax matters.

Leila D. Carney, Esq., Partner | Caplin & Drysdale

Leila Carney is a seasoned tax lawyer focused on resolving disputes with the IRS. Her core practice involves providing a surgical defense to IRS audits, assessments, and penalties, including litigation against the IRS and the Department of Justice in the U.S. Tax Court, federal district court, and the D.C. Circuit. She is adept at handling multifaceted issues involving global business and investing structures for individuals, corporate clients, and complex trusts, and has handled sensitive IRS exams, administrative appeals, criminal matters, voluntary disclosures, ruling requests, and comment letters on proposed regulations.

• Education & Credentials

Ms. Carney received her J.D. from the University of Virginia School of Law in 2004 and her B.A. from The College of William & Mary in 2001. She is admitted to the bars of the District of Columbia and Virginia and to practice before the U.S. Tax Court and the U.S. District Court for the Eastern District of Virginia.

• Recognition & Leadership

The source material does not list awards or honors. Her recent leadership in the profession includes leading an ABA Tax Section Administrative Practice Committee program on the IRS LB&I Puerto Rico campaign (2024).

• Professional Involvement

Ms. Carney is a member of the American Bar Association Section of Taxation and the District of Columbia Bar.

• Experience

Ms. Carney has practiced in Caplin & Drysdale’s Tax Disputes & Tax Litigation Group since joining the firm’s Washington, D.C. office in 2004, and also contributes her tax, litigation, and federal law expertise to the firm’s Complex Litigation, Criminal Tax & White Collar Defense, Private Client, and Political Law practices. She has litigated cases involving foreign-source income, captive insurance, conservation easements, and IRS third-party summonses; defended Puerto Rico residency and sourcing positions in IRS campaign audits; navigated the Congressional Joint Committee on Taxation’s large tax refund review process; defended a gift tax return examination involving a high-net-worth trust structure; and pursued penalty abatements relating to foreign trust reporting, return preparers, and appraisers. She has represented clients in sensitive audits carrying fraud risk, in responses to civil and criminal subpoenas, and in collection matters such as offers-in-compromise, lien releases, installment agreements, and innocent spouse petitions, along with state tax matters before the California Franchise Tax Board. She is also experienced in obtaining and defending tax-exempt status for public and private charities and trade associations, and has advised clients on compliance with regimes governing taxpayer consent to disclosure of return information, FBAR reporting, and nonqualified deferred compensation plans.

Jorge M. Oben-Cuadros, Esq., Partner | Procopio

Jorge Oben-Cuadros is a Partner in Procopio’s Washington, D.C. office, where he advises clients on planning, controversy and litigation, and policy matters involving tax and trade. He represents multinational corporations, defense contractors, investment funds, high-net-worth individuals, and family offices — particularly from Latin America, Puerto Rico, and Europe — on complex U.S. and international matters. His practice centers on inbound structuring into the United States, cross-border planning, tariff exposure and mitigation, tax and trade litigation, and strategic guidance on tax and trade policy developments affecting global operations.

• Education & Credentials

Mr. Oben-Cuadros received his LL.M. in Taxation from Georgetown University Law Center and his J.D. and B.S. in Business Administration (Accounting) from the Universidad de Puerto Rico. He is admitted in the District of Columbia and Puerto Rico and before the U.S. Court of Federal Claims, the U.S. Court of International Trade, and the U.S. Tax Court, and he speaks Spanish.

• Recognition & Leadership

Mr. Oben-Cuadros was elected a Fellow of the American College of Tax Counsel in 2026 and served as an ABA Section of Taxation Loretta Collins Argrett Fellow (2023–2026). His government service was recognized with the IRS Excellence Award (Schedules K-2 and K-3 Team, 2020), the Deputy Commissioner’s Award (International Training Strategy, 2020, and TCJA Face-to-Face Training Team, 2019), the Treasury Department Legal Division’s Legal Team of the Year Award (GILTI Team, 2019), and the Commissioner’s Award (Tax Cuts and Jobs Act Implementation Team, 2019).

• Professional Involvement

Mr. Oben-Cuadros serves on the Steering Committee of the D.C. Bar Association’s Taxation Community, on the ABA Section of Taxation’s Nominating Committee and its U.S. Activities of Foreigners and Tax Treaties and Foreign Activities of U.S. Taxpayers Committees, and as Regional Counsel for the District of Columbia Region of the USA Branch of the International Fiscal Association. He previously chaired the Federal Bar Association Section on Taxation’s Beyond-the-Beltway Committee and co-chaired its Health and Wellness and Diversity, Equity, and Inclusion Committees. He is a prolific speaker and author on international tax, Puerto Rico tax incentives, Pillar Two, and tariff and trade issues before organizations including the Practising Law Institute, the ABA Tax Section, the D.C. Bar, the International Bar Association, and the International Fiscal Association.

• Experience

Before joining Procopio, Mr. Oben-Cuadros served in the IRS Office of Associate Chief Counsel (International), where he drafted significant published guidance — including the GILTI regulations under Section 951A — and advised the IRS, the U.S. Treasury Department, and taxpayers on complex international tax issues. He also served as an IRS detailee to the U.S. House Committee on Ways and Means, working on international and corporate tax legislation, Puerto Rico and U.S. territories matters, traderelated tax issues, and the energy provisions of the Inflation Reduction Act of 2022. His representative matters include representing individuals relocating to Puerto Rico in residency and sourcing examinations, representing internationally renowned recording artists in IRS controversies, advising foreign-parented multinationals and foreign funds on inbound and outbound U.S. tax matters, securing abatement of roughly $1 million in penalties for a payroll provider, and obtaining corrections, abatements, levy releases, and refunds exceeding $850,000 for a federal contractor through the IRS Taxpayer Advocate Service.

Lawrence A. Sannicandro, Esq. Partner | Pillsbury Winthrop Shaw Pittman

Lawrence “Larry” Sannicandro is a partner in Pillsbury’s New York office. He focuses his practice on a broad range of federal and state tax disputes affecting individual private clients as well as their estates, trusts, and businesses, both public and private. These disputes span the full range of civil and criminal tax matters, including audits and examinations, administrative appeals, collection matters, summons proceedings, grand jury subpoenas, criminal tax investigations and prosecutions, and litigation before the U.S. Tax Court, the U.S. Court of Federal Claims, federal district and appellate courts, and state tax tribunals.

• Education & Credentials

Mr. Sannicandro received his LL.M. in Taxation from Georgetown University Law Center in 2010, his J.D. from the University of Florida College of Law in 2006, and his M.B.A. in Finance (2003) and B.A. in Political Science (2001) from Binghamton University. He is admitted in New Jersey, New York, and the District of Columbia, and before the U.S. Supreme Court, the U.S. Courts of Appeals for the Second, Third, Fourth, Eleventh, and D.C. Circuits, the U.S. Court of Federal Claims, the U.S. Tax Court, and several federal district courts. He clerked for the Hon. David Laro of the U.S. Tax Court from 2010 to 2012.

• Recognition & Leadership

Mr. Sannicandro received the ABA Section of Taxation’s Janet Spragens Pro Bono Award (2020), the section’s highest honor for pro bono service, and its John S. Nolan Fellowship (2016). He has been recognized by Lawdragon among its 500 Leading Global Tax Lawyers (2025), by Chambers for tax law (2023–2025), and by Super Lawyers (2021); was selected Bloomberg Tax Portfolio Author of the Year (2023); served on Law360’s 2023 Tax Authority Federal Editorial Advisory Board; was named a 2022 ROINJ Influencer in Law and a 2018 New Jersey Law Journal Leader of the Bar; and received the New York County Lawyers’ Association Pro Bono Award (2015). He chairs the ABA Tax Section’s Court Procedure Practice Committee.

• Professional Involvement

Mr. Sannicandro is a member of the IRS Advisory Council, a Fellow of the American College of Tax Counsel, and a member of the Supreme Court of New Jersey District VA Ethics Committee. He previously taught corporate and partnership tax, tax practice and procedure, and legal ethics at several universities, and speaks extensively before organizations including the Practising Law Institute, the ABA Section of Taxation, the Federal Bar Association, the D.C. Bar, and the NYU Tax Controversy Forum, including a presentation on current penalty issues at the NYU Summer 2025 Institute in International Taxation.

• Experience

A former estate and gift tax attorney for the IRS, Mr. Sannicandro is uniquely well-versed in estate and gift tax planning techniques, the valuation of closely held businesses, and defending those techniques in disputes with tax authorities. He has favorably resolved hundreds of tax disputes involving income taxes, estate and gift taxes, employment and payroll taxes, excise taxes, sales and use taxes, federal and state tax credits, and employee plan matters, and advises clients on uncertain tax positions and the identification, quantification, and procedural management of tax-based risks. Representative matters include persuading the U.S. Tax Court that a closing agreement precluded proposed assessments relating to allegedly unreported foreign assets; obtaining full IRS concessions for taxpayers claiming Puerto Rico Act 22 benefits; securing invalidation-driven concessions on a disaster loss carryback regulation; resolving a global high wealth audit of a private equity and family office founder; and securing a non-custodial sentence in a criminal matter involving cryptocurrency-related income while persuading the government to reduce the alleged tax loss by approximately 90 percent. He is the author of Bloomberg BNA portfolios on IRS National Office procedures and innocent spouse relief and a chapter of the ABA’s Effectively Representing Your Client Before the IRS, along with numerous articles.

Michael Sardar, Esq., Partner | Kostelanetz

Michael Sardar is a partner in Kostelanetz LLP’s New York City office with extensive experience across a wide range of tax controversy and white-collar criminal defense matters. He represents clients in all stages of civil and criminal tax controversies before the IRS, state tax authorities, the Department of Justice, and local prosecutors, and advises taxpayers facing audits and investigations of noncompliance with foreign bank and asset reporting requirements.

• Education & Credentials

Mr. Sardar received his J.D. from Cornell Law School in 2007 and graduated summa cum laude from Baruch College in 2004 with a B.B.A. in Marketing Management. He is admitted in New York State, before the U.S. District Courts for the Southern and Eastern Districts of New York, and before the U.S. Tax Court.

• Recognition & Leadership

Mr. Sardar is recognized by Best Lawyers for Litigation and Controversy – Tax in New York and by Super Lawyers for Tax in New York. He is Co-Chair of the Federal Bar Association Section on Taxation, New York Chapter, and Co-Chair of the Subcommittee on Offshore Enforcement of the ABA Committee on Civil and Criminal Tax Penalties, and formerly served as Vice-Chair of the New York County Lawyers’ Association Taxation Committee.

• Professional Involvement

Mr. Sardar lectures and writes frequently on tax controversy topics, including foreign asset reporting and noncompliance, with recent appearances at the ABA Midyear Tax Meeting and Kostelanetz’s Annual Tax Controversy Seminar, publications on trust fund tax liability in New York and Puerto Rico residency audits, and co-authorship of a New York State Bar Association Tax Section report on proposed updates to the IRS Voluntary Disclosure Practice.

• Experience

Mr. Sardar joined Kostelanetz in 2009 and was named partner in January 2019; he previously practiced transactional tax law at Heller Ehrman LLP. He has represented scores of clients with unreported foreign assets, enabling the repatriation of over half a billion dollars of offshore assets through the IRS Offshore Voluntary Disclosure Program, the Streamlined Compliance Procedures, and the current Voluntary Disclosure Practice. His representative results include convincing the DOJ Tax Division to discontinue a criminal investigation involving over $50 million in purportedly unreported foreign assets; saving a telecom executive more than $10 million in penalties by demonstrating that the nondisclosure of $50 million in foreign accounts was not willful; securing non-jail sentences in fraud matters where sentencing guidelines called for imprisonment; canceling in full a responsible-officer withholding tax assessment; and securing credit for $3 million in taxes withheld on a foreign account. He also handles New York State and City residency audits, internal investigations, gift and estate tax valuation disputes, and advises nonprofit organizations on exemption and UBIT issues.

DAY 1, THURSDAY, JULY 23, 2026

WELCOME REMARKS | 8:25am – 8:30am

Kathleen Costello, CMP, Assistant Director, NYU School of Professional Studies, New York, NY

SESSION 1 – CONTROLLED FOREIGN CORPORATION PLANNING: WHAT’S NEW AFTER OB3? | 8:30am – 11:30am 

The One Big Beautiful Bill Act made substantial changes to the rules that impose US taxation of US shareholders of CFCs. This session addresses how those changes affect planning opportunities and traps for the unwary. Some of the topics discussed include changes made to the rules relating to how US shareholders determine their pro rata share of Subpart F income and net CFC tested income or NCTI (previously GILTI), the reinstatement of Section 958(b)(4) which prohibits downward attribution from a foreign person to a US person under the constructive ownership rules, a new provision, Section 951B, which provides for CFC inclusions in the case of certain ownership structures, and the various changes to the GILTI (now NCTI) regime, including corresponding foreign tax credit changes. This session also discusses how the Subpart F and NCTI rules apply in certain partnership structures. Finally, the session discusses the application of certain exceptions to Subpart F income (e.g., the CFC look through rule of Section 954(c)(6), the active rent and royalty exception, and the high-tax exception) as well as certain exceptions relating to NCTI regime (e.g., the high-tax exception).

Joseph M. Calianno, JD, LLM, MBA, CPA, Managing Director; National Tax Practice, Andersen Tax, Washington, DC

Sean Dokko, JD, LLM, Managing Director; National Tax Practice, Andersen Tax, New York, NY

Enrica Ma, Esq., Principal, National Tax Department, International Tax and Transaction Services, EY, Washington, DC

Brandon C. Svetcov, Esq., Principal, International Tax Services, EY, New York, NY

BREAK | 9:45am – 10:00am

BREAK | 11:30am – 11:45am

SESSION 2 – OUTBOUND PLANNING AND CHOICE OF ENTITY CONSIDERATIONS FOR INDIVIDUALS | 11:45am – 1:00pm

A principal focus of both the TCJA and OB3 was reforming the taxation of US based multinationals. Unfortunately, the impact of that reform on individuals who own foreign corporations either directly or through pass-through entities, such as partnerships and S corporations, appears not to have been well thought out. This panel addresses the taxation of such individuals, the problems that they face under TCJA/OB3, and the steps that they can take to mitigate these apparent unintended consequences of tax reform.

Thomas M. Giordano-Lascari, Esq., Partner, Greenberg Glusker, Los Angeles, CA Michael J.A. Karlin, Esq., Partner, Holland & Knight, Los Angeles, CA

LUNCH | 1:00pm – 2:15pm

SESSION 3 – INTERNATIONAL MERGERS AND ACQUISITIONS: US TAX CONSIDERATIONS AND PLANNING TECHNIQUES | 2:15pm – 4:30pm

Among the topics covered in this session are the US tax considerations for taxable and tax-free stock acquisitions of foreign companies, CFC issues, tax-free acquisitions of US companies, planning for the use of holding companies, inversion transactions, debt-equity regulations, use of hybrid instruments, OECD BEPS issues, and recent developments. The session also includes planning in light of tax law changes from OB3, including the base erosion anti-abuse tax (BEAT) and the anti-hybrid deduction limitations.

William S. Dixon, Esq., Managing Director, Mergers and Acquisitions, Citigroup Global Markets, New York, NY

Sam K. Kaywood, Esq., Partner, Alston & Bird, Atlanta, GA

William B. Sherman, Esq., Partner, Holland & Knight, Fort Lauderdale, FL

BREAK | 3:30pm – 3:45pm

DAY 2, FRIDAY, JULY 24, 2026  

SESSION 1 – ADVANCED FOREIGN TAX CREDITS | 8:45am – 10:15am

With over six months having elapsed after their promulgation, this session dives into the final foreign tax credit regulations, exploring some of the key provisions and issues including what constitutes a creditable foreign income tax and how to allocate and apportion foreign tax to different “baskets.” The session covers, among other things, applying and navigating the newly renamed “attribution” and “cost recovery” requirements and the treaty coordination rules for foreign tax credit creditability determinations, as well as the rules for allocating and apportioning foreign tax applicable to disregarded distributions, foreign law distributions and dispositions.

Adam Bair, Esq., Principal, National Tax Services, PwC, New York, NY

Steven Burns, CPA, Director, National Tax Services, PwC, Washington, DC

BREAK | 10:15am – 10:30am

SESSION 2 – “FIRPTA” RULES AND PLANNING APPLICABLE TO FOREIGN PERSONS INVESTING IN US REAL ESTATE | 10:30am – 12:15pm

This session addresses the definition of US real property interest; tax rules applicable to foreign persons disposing of US real property interests; special rules applicable to investments through real estate investment trusts; special exceptions including for interests in publicly traded companies and domestically controlled real estate investment trusts, as well as special exemptions for qualified pension investors and foreign sovereign investors; and treaty and other withholding tax exemptions for payments of interest to foreign investors.

Alan I. Appel, Esq., Professor of Law, New York Law School, New York, NY

Heather Ripley, Esq., Partner, Alston & Bird, New York, NY

Sean J. Tevel, Esq., Partner, Holland & Knight, Miami, FL

LUNCH | 12:15pm – 1:30pm

SESSION 3 – INBOUND DEBT INVESTING | 1:30pm – 3:00pm

This session addresses issues relating to investments by foreign persons in US debt, including US trade or business status, the safe harbors for certain investing and trading activities, “season and sell” techniques, and the use of income tax treaties including “bring your own treaty” funds.

Jason Schwartz, Esq., Partner, Cahill Gordon & Reindel, Washington, DC Matthew Stevens, Esq., Principal, EY, Washington, DC

BREAK | 3:00pm – 3:15pm

SESSION 4 – CURRENT PENALTY ISSUES | 3:15pm – 4:30pm

Tax controversy professionals, and the Taxpayer Advocate, have long been sounding the alarm about the complex filing requirements for international information returns and the often life-altering penalties imposed for noncompliance. Due in part to the IRS’s overzealous approach towards enforcement in this area, taxpayers have challenged international information return penalties on various technical grounds and on the basis of reasonable cause. Recently, some of these challenges have been addressed by the courts. This session discusses recent cases in the area as well as their implications going forward.

Leila D. Carney, Esq., Partner, Caplin & Drysdale, Washington, DC 

Jorge M. Oben-Cuadros, Esq., Partner, Procopio, Washington, DC

Lawrence A. Sannicandro, Esq. Partner, Pillsbury Winthrop Shaw Pittman, New York, NY Michael Sardar, Esq., Partner, Kostelanetz, New York, NY