Introduction to International Taxation 2026 (Presented by NYU School of Professional Studies)

Michael J. Miller, Esq., Partner | Roberts & Holland

Michael J. Miller is a Partner at Roberts & Holland LLP, where he has provided U.S. tax advice to domestic and international clients for more than 20 years. His practice centers on international taxation. For foreign clients, he structures inbound U.S. investments and operations to avoid creating a U.S. permanent establishment and designs structures that make use of U.S. income tax treaties, the portfolio interest withholding exemption, and other rules for minimizing U.S. tax, while accounting for anti-abuse rules such as earnings-stripping limitations and restrictions on treaty shopping and hybrid entities. He also works with U.S. multinationals to structure foreign investments and operations to reduce the impact of restrictions on outbound transfers and the anti-deferral rules applicable to shareholders of controlled foreign corporations and passive foreign investment companies, and to maximize the use of foreign tax credits.

• Education & Credentials

Michael earned his J.D. from New York University School of Law and his B.A., cum laude, from Columbia University. He is admitted to practice in New York.

• Recognition & Leadership

Michael serves in editorial leadership roles across the international tax field: he 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 BNA Tax Management International Journal.

• Professional Involvement

Michael is a former Chair of the U.S. Activities of Foreign Taxpayers Committee of the American Bar Association Tax Section and of the Business Entities Committee of the New York City Bar Association. He co-authored two Bloomberg Tax Portfolios, one on the limitation-on-benefits article of income tax treaties and one on U.S. taxation of international shipping and air transport activities. He is a frequent author and speaker, including co-chairing the Introduction to International Taxation and Advanced International Taxation conferences at NYU’s Summer Institute in Taxation and speaking at the NYU Institute on Federal Taxation.

• Experience

Before entering private practice, Michael clerked on the U.S. Tax Court for the Honorable James S. Halpern from 1991 to 1993. He has since spent more than two decades advising domestic and international clients on U.S. tax matters and publishing extensively in journals including the International Tax Journal, the Tax Management International Journal, and the Canadian Tax Journal.

James S.H. Null, Esq., Partner | Kilpatrick Townsend & Stockton

Jamie Null is a leading tax lawyer with nearly eighteen years of experience advising on U.S. federal tax matters, including transactional tax issues associated with U.S. inbound and outbound investments, as well as domestic and international tax planning for individual, corporate, and partnership transactions. He advises on private equity investments and structures and on domestic and cross-border mergers and acquisitions. His diverse practice spans industries including real estate, entertainment, media, biotechnology, alternative energy, hospitality, transportation, and technology. He has substantial experience with real estate-related transactions, including sophisticated like-kind exchanges involving domestic and foreign interest holders, and works frequently in the media and entertainment sector, advising U.S. and non-U.S. entertainment clients on the production and talent side of U.S. and international entertainment investments. He is a member of Kilpatrick’s Transactional Tax Team in the firm’s Corporate, Finance and Real Estate Department. • Education & Credentials Jamie earned his LL.M. from New York University School of Law (2006) and his J.D. from the University of Miami School of Law (2002).

• Recognition & Leadership

Jamie was recommended by Legal 500 US in 2019 for both U.S. Taxes: Non-Contentious and International Tax Law, and was recognized as a New York Super Lawyer for Tax Law by Super Lawyers magazine in 2019.

• Professional Involvement

Jamie’s publications include a November 2019 piece on how Opportunity Zones can defer and exclude gain for non-U.S. investors in U.S. real property.

• Experience

Jamie joined Kilpatrick’s New York office in August 2024 from Loeb & Loeb LLP, where he was a partner. Prior to that, he was a partner in the New York office of an international multi-service law firm counseling clients on complex tax structures across industries, and before that a partner at an international corporate law firm working on federal and international tax matters, with earlier practice focused on M&A, private equity investments, corporate transactions, and U.S. federal tax matters. Representative matters include representing the largest U.S. media agency in the sale of a minority interest to a Singaporean sovereign wealth fund; representing a California-based lender in transactions including a $50 million senior secured term loan to an independent cable network and a $61.5 million delayed draw term loan; structuring and advising on a $50 million joint venture with a Hong Kong-based biotechnology company to develop a melanoma vaccine; advising Hong Kong and Chinese nationals on inbound U.S. investments and U.S. tax residency issues; restructuring a public company with significant operations in China, Hong Kong, Europe, and the U.S.; and structuring a U.S. outbound coal investment in China and the Netherlands.

David G. Shapiro, Esq., Partner | Saul Ewing

David Shapiro leads Saul Ewing’s Tax Practice and advises clients on international and domestic business tax planning, including domestic and cross-border expansion, joint ventures, mergers, acquisitions, and financing transactions. His practice includes entity formation and structure planning, securities offerings and hybrid financings, joint ventures, and strategic acquisitions and dispositions, and he represents both equity sponsors and investors in real estate transactions and structures, including Qualified Opportunity Funds and cross-border real estate deals. He also advises clients on evaluating tax risks, including whether those risks may be insurable, has obtained tax rulings for multiple clients, and handles audits, appeals, and litigation when tax authorities disagree with taxpayer positions. A client described him as the best tax attorney they had ever worked with, praising his responsiveness and authoritative guidance.

• Education & Credentials

David earned his J.D., cum laude, from Duke University School of Law in 1998, where he was Executive Editor of the Alaska Law Review, and his A.B. from Yale University in 1995. He is admitted to the Pennsylvania bar. He has taught as an Adjunct Professor at Temple University’s James E. Beasley School of Law since 2022 and previously taught in Villanova University School of Law’s Graduate Tax Program from 2013 to 2016.

• Recognition & Leadership

David was named the Philadelphia Lawyer of the Year for Tax Law by Best Lawyers for 2026 and has been listed in The Best Lawyers in America for Tax Law since 2024. He has been recognized among America’s Leading Lawyers in Tax Law by Chambers USA since 2018 and was included in Who’s Who Legal: Corporate Tax from 2012 to 2018 and in 2023. Opportunity Zone Magazine named him a Top 25 Tax Specialist in 2021 and a Top 25 OZ Influencer in 2020. Earlier honors include Lawyer on the Fast Track (Legal Intelligencer and Pennsylvania Law Weekly, 2009), Pennsylvania Super Lawyers Rising Star (2005-2008, 2011-2012), and selection as a John S. Nolan Fellow of the ABA Section of Taxation (2001-2002).

• Professional Involvement

David is a Regent of the American College of Tax Counsel and a Board Member of the Theodore Tannenwald Jr. Foundation for Excellence in Tax Scholarship. In the ABA Section of Taxation, he chaired the Committee on U.S. Activities of Foreigners and Tax Treaties (2013-2014) and was principal author of comments to Treasury and the IRS on proposed anti-inversion rules and co-author of comments on the 2017 tax reform. In the International Bar Association Taxes Committee he has served as Treasurer (20192020), Membership Officer (2017-2018), Young Lawyers Programme Officer (2015-2016), and U.S. National Tax Reporter (2008-2009), and co-authored comments to the OECD on the BEPS action plan. He chaired the Philadelphia Bar Association’s Tax Section and served on its Board of Governors (2017-2018), and served as a Trustee of Congregation Rodeph Shalom from 2000 to 2011.

• Experience

David’s experience spans structuring and negotiating cross-border and domestic transactions, securing tax rulings, and representing taxpayers in audits, appeals, and litigation. Outside the office, he has played violin with the Lansdowne Symphony Orchestra since 1999.

Robert Christoffel, Esq., Counsel | Saul Ewing

Robert Christoffel advises clients on U.S. domestic and cross-border transactional matters as well as international tax issues. Public and private companies and private equity funds turn to him to structure and negotiate taxable and tax-free corporate mergers and acquisitions (share and asset deals), reorganizations including spinoffs, dispositions of ongoing businesses, and investments into domestic and foreign portfolio companies, and he negotiates and drafts tax provisions for membership interest purchases, joint ventures, and partnership and LLC formations. He also counsels on public offerings of debt and equity securities, credit and financing transactions, investment fund closings, tax-efficient structuring of multinational operations and intercompany transactions, IRS and foreign tax authority audits (including transfer pricing audits) and tax litigation, and developments in U.S. and global tax reform, including OECD Pillar I and II and digital taxes. He is a fully qualified German lawyer, having passed both German bar exams, and has particular experience with clients in the technology, media, energy, and consumer goods industries.

• Education & Credentials

Robert earned his J.D., summa cum laude, from the University of Maryland Francis King Carey School of Law in 2015; completed the German Second State Exam at the Higher Regional Court of Düsseldorf in 2012; received an LL.M. in Comparative Law from the University of Miami School of Law in 2007 as a Fulbright Scholar; and passed the German First State Bar Exam (J.D.-equivalent) at Heinrich Heine University, Düsseldorf, in 2005. He is admitted in the District of Columbia and New York. He is a native German speaker and is proficient in French and Dutch.

• Recognition & Leadership

Robert was a lecturer at the University of Cologne’s Institute of Tax Law from 2007 to 2009, teaching courses on German and E.U. tax law and German constitutional law.

• Professional Involvement

Robert serves as U.S. National Reporter for the Taxes Committee of the International Bar Association and is a member of the USA Branch of the International Fiscal Association, where he assists the Co-Chair of the GW/IRS Annual Institute on Current Issues in International Taxation. He is also a member of the Fulbright Association, the U.S. Department of State International Exchange Alumni, and Fulbright Germany.

• Experience

Robert’s advice to multinational companies on international and foreign tax issues, including business and supply chain tax planning, is shaped by his experience working at international law firms in both the United States and Germany. He clerked for Judge Dr. H. Theissen of the Regional Court Düsseldorf, Civil Chamber. He also comes from a family of winemakers in Germany’s Mosel region and has worked on wine estates and in vineyards in Germany and France.

Oliver Minguillon, MBA, Managing Director, Economic and Valuation Services (Transfer Pricing) | KPMG

Oliver Minguillon is a Managing Director in KPMG’s Economic and Valuation Services Department with over fifteen years of transfer pricing experience. He specializes in operational transfer pricing as a member of the KPMG National Operational Transfer Pricing team, and in addition to operational transfer pricing engagements, he specializes in the financial services and banking industries. He directs large-scale operational transfer pricing projects for Fortune 1000 companies, assessing current states and implementing end-to-end transfer pricing processes that align transfer pricing policies with financial systems and tools, and coordinates global transfer pricing planning and documentation initiatives, including functional interviews and managing interactions with local country member firms.

• Education & Credentials

Oliver earned his MBA in Finance from Rutgers University (2008–2011) and his B.S. in Economics from Rutgers University (2000–2005), where he was a member of Phi Kappa Sigma International Fraternity. He also holds LinkedIn certifications in Business Ethics and Building Trust (issued November 2020).

• Recognition & Leadership

Oliver serves as a member of KPMG’s National Operational Transfer Pricing team.

• Professional Involvement

Oliver co-authored “Transfer Pricing and ESG, Part 2: Improving Governance Through Operational Transfer Pricing,” published in Tax Notes International (March 2024), examining how multinational corporations can use operational transfer pricing to ensure compliance with their transfer pricing policies as part of ESG tax governance.

• Experience

Oliver has spent more than sixteen years at KPMG US, serving as Managing Director since October 2022 (based in Short Hills, New Jersey), and previously as Senior Manager (October 2015 – October 2022), Manager (June 2012 – October 2015), and Senior Associate/Senior Transfer Pricing Consultant (June 2010 – September 2012). Before KPMG, he was a Transfer Pricing Consultant and Senior Transfer Pricing Consultant at True Partners Consulting from October 2006 to June 2010. His engagement experience includes preparing transfer pricing reports under Section 482 regulations and OECD guidelines covering intellectual property licensing, cost allocations, financing, and service transactions, and assisting clients with bilateral Advance Pricing Agreement (APA) submissions.

Logan E. Gans, Esq., Partner | Holland & Knight

Logan E. Gans is a private wealth services and tax attorney in Holland & Knight’s Miami office and co-chair of the firm’s State and Local Tax Team. He advises high-net-worth individuals, family offices, closely held businesses, and institutional clients on complex federal, state, and international tax matters, with particular strengths in Florida state and local tax (including documentary stamp tax and nonrecurring intangible personal property tax), business aviation tax, cross-border structuring, and tax controversy. His aviation work includes structuring aircraft acquisitions and dispositions, bonus depreciation and Section 280F analysis, leasing and management arrangements, charter and Part 135 operations, and fractional and co-ownership structures. He counsels real estate developers, lenders, and borrowers on Florida and multistate tax matters and on Qualified Opportunity Fund investments; represents clients in federal and state tax controversies, including audits, penalty appeals, voluntary disclosures, IRS streamlined filing procedures, and delinquent FBAR submissions; and advises on outbound planning (Subpart F, GILTI, PFIC, and FDII) and inbound investment structuring, including real property, portfolio debt planning, and cross-border M&A.

• Education & Credentials

Logan earned his J.D., cum laude, from the University of Florida Levin College of Law; an M.S. in Accounting from Boston College’s Carroll School of Management; and a B.A. in Economics and History, with highest honors, from Emory University. He is admitted to The Florida Bar and the U.S. Tax Court and is a Florida-licensed Certified Public Accountant.

• Recognition & Leadership

Logan is recognized in the 2026 Chambers USA guide for Tax and for Tax: State & Local, and in The Legal 500 USA for Latin America International Firms – City Focus: Miami (2021-2023) and Tax – U.S. Taxes: Non-Contentious (2025, 2026). He has been listed in The Best Lawyers in America for Trusts and Estates (2025, 2026) and previously among Miami Tax Law Ones to Watch (2021-2023), named a Leading Global Tax Lawyer by Lawdragon 500 (2025), an On the Rise (Large Firm) honoree at the Daily Business Review’s Florida Legal Awards (2024), a Rising Star by Florida Super Lawyers (2022, 2024), a Top Lawyer by South Florida Legal Guide (2021-2022), and a 40 Under Forty honoree by the Emory Alumni Association (2021). He is a member of Phi Beta Kappa.

• Professional Involvement

Logan serves on the Law360 Editorial Advisory Boards for Tax Authority State and Local (2026) and Tax Authority International (2024), and on the National Business Aviation Association’s Tax Committee Planning Group (2025, 2026). He has served on The Florida Bar Tax Section’s C-Corporations Subcommittee (2020-2022) and the Florida Institute of CPAs’ State Tax Committee and International Taxation Committee, and is a member of The International Tax Group. He also served on the Emory Miami Legal Network General Board (2021-2023).

• Experience

Prior to joining Holland & Knight, Logan was a tax attorney at a Florida-based Am Law 200 firm in Miami and previously served as an international tax senior consultant with a multinational accounting firm. During law school, he was a judicial extern for the Honorable Frederick D. Smith of Florida’s Eighth Judicial Circuit, editor-in-chief of the Journal of Technology Law and Policy, a member of the Florida Journal of International Law, and a teaching assistant for legal research and writing and appellate advocacy.

Lucas Giardelli, Esq., Partner | Mayer Brown

Multinational companies rely on Lucas Giardelli for the structuring and execution of business transactions and for corporate and international tax planning. He advises clients across industries on the tax aspects of acquisitions, divestitures, joint ventures, financings, and other corporate transactions, particularly in the cross-border context, and regularly assists U.S. and international clients with internal restructurings and financings, holding company structures, double tax treaties, tax attribute optimization, supply chain and IP planning, and post-acquisition integration. He also counsels high-net-worth individuals and family offices on international tax matters.

• Education & Credentials

Lucas holds an LL.M. from Harvard Law School, an LL.M. in Tax Law from Universidad Austral, and a law degree from Universidad Austral, where he received the Gold Medal Award. He is admitted in New York and Argentina and speaks Spanish.

• Recognition & Leadership

Legal 500 has praised Lucas’s ability to explain highly complex restructuring matters at the C-suite level. He serves as co-leader of Mayer Brown’s International Tax & Transfer Pricing practice.

• Professional Involvement

Lucas frequently writes and speaks on international and corporate tax topics. He is a member of the NYU International Tax Program Practice Council and the International Tax Journal Advisory Board, and belongs to the International Fiscal Association and the American Bar Association Tax Section.

• Experience

Lucas’s recent work includes publications on AI training data and transfer pricing (2026) and key tax considerations for preferred equity (2026), and recent matters listed by the firm include advising on the financing of a transmission project in Chile and advising arrangers on a credit facility supporting a corporate acquisition. His speaking engagements include the Pacific Rim Tax Conference and the TEI Midyear Conference (2026).

Amitai Barth, Esq., Senior Manager | Deloitte

Amitai Barth is a Senior Manager in Deloitte’s Washington National Tax – International Tax Services group, where he handles complex inbound and outbound issues, transactions, and restructurings, with specializations in financing, corporate tax, PFICs, and insurance. Drawing on Big Four, Biglaw, and IRS Office of Chief Counsel experience in identifying, analyzing, distilling, and resolving complex transactional and controversy issues, he adds value for clients by pairing broad technical knowledge with sharp research, analytical, and writing skills to develop tax-efficient solutions. His strengths include spotting potential tax traps in restructurings and reorganizations, probing the Code, regulations, case law, and IRS guidance to flesh out applicable authorities, translating technical language and legalese into plain English, and developing overall strategy and specific tax advice tailored to a taxpayer’s unique facts and risk profile.

• Education & Credentials

Amitai earned his LL.M. in Taxation from New York University School of Law (2008–2010), where his coursework spanned corporate tax, international tax, property transactions, partnership tax, timing, private equity, policy, estate and gift, M&A, foreign tax credit and Subpart F, tax penalties and prosecutions, and a civil tax litigation seminar. He earned his J.D. from New York University School of Law (2005–2008), cum laude, where he was a Staff Editor of the Journal of Law & Liberty, and his B.A. in History, magna cum laude, from Yeshiva University (2001–2004), where he was a tutor in the Writing Center. His profile also lists Georgetown Law (no degree or program details shown). He is admitted to practice law, and his certifications include Deloitte Impact Day credentials (2025, 2026).

• Recognition & Leadership

At Deloitte, Amitai leads cross-functional teams and advises clients on high-stakes matters across sectors, and is known for a collaborative leadership style.

• Professional Involvement

Amitai speaks at the NYU School of Professional Studies Introduction to International Taxation conference, where he co-presented the session on the U.S. taxation of shareholders of passive foreign investment companies (PFICs) — covering the definitional provisions of the PFIC rules, the alternative methods of taxation of U.S. shareholders, and proposed regulations addressing PFICs held through domestic partnerships — alongside Deloitte Principal Jason Robertson.

• Experience

Amitai has been a Senior Manager at Deloitte US since August 2015 (11 years). Before Deloitte, he was Manager of Tax Advisory Services at Arthur Bell CPAs (September 2014 – May 2015), leading a small team of attorneys performing extensive tax research and facilitating efficient planning for the mid-size accounting firm’s client base of high-net-worth individuals and investment funds. He spent over five years at the IRS Office of Chief Counsel (Corporate Division): as an Attorney in the IRS National Office in Washington, D.C. (July 2012 – September 2014), addressing corporate and consolidated return tax issues confronting C corporations, drafting private letter rulings, and briefing the Corporate front office on difficult and sensitive issues; and as a Trial Attorney in New York (July 2009 – June 2012), representing the IRS before the U.S. Tax Court in all aspects of litigation, conducting conferences and negotiations with taxpayers to evaluate documentation and determine tax liabilities, and trying four cases, including Kuretski, T.C. Memo. 2012-262. Earlier in his career, he was an Associate at Dewey & LeBoeuf LLP (September 2008 – May 2009) and a Judicial Intern for Magistrate Judge E. Thomas Boyle of the U.S. District Court for the Eastern District of New York (June–August 2005).

Jason Robertson, Esq., Principal | Deloitte

Jason Robertson is a Principal in Deloitte Tax LLP’s Washington National Tax practice, where he is a member of the International Tax Group. He specializes in advising U.S. and foreign-based multinationals on a broad range of international tax matters and is a member of the Deloitte Tax Cryptocurrency Working Group.

• Education & Credentials

Jason earned his J.D. from the USC Gould School of Law (1997–2000), his Master of Business Taxation from the USC Marshall School of Business (1998–1999), and his B.A. in English from the University of Michigan (1993–1997).

• Recognition & Leadership

Jason serves as a Principal in Deloitte’s Washington National Tax International Tax Group, the firm’s national office for technical international tax matters.

• Professional Involvement

Jason is a frequent speaker at tax events, including programs sponsored by Deloitte, Bloomberg BNA, and the Manufacturers Alliance for Productivity and Innovation, and he co-presents the PFIC session at the NYU School of Professional Studies Introduction to International Taxation conference. He is a past member of the AICPA Technical Resource Panel on International Tax and a regular contributor to Deloitte Tax publications.

• Experience

Jason has spent nearly fifteen years at Deloitte Tax LLP, serving as Principal in Washington National Tax (International Tax) since August 2019, and previously as Managing Director in Washington National Tax (August 2016 – August 2019), Senior Manager in Washington National Tax (June 2014 – July 2016), both in Washington, D.C., and Senior Manager, International Tax, in Houston, Texas (October 2011 – May 2014). Before Deloitte, he was Director of International Tax at Mattel (May 2008 – October 2011), a Fortune 500 manufacturer, where he focused on planning, implementing, reporting, and defending cross-border transactions; Senior Manager, Tax Planning, at Amgen (February 2004 – April 2008), a Fortune 500 biotechnology company, where he supported the company’s Puerto Rican manufacturing and worldwide treasury operations; and a Senior Associate in International Tax Services at PwC (September 2000 – February 2004), all in the Los Angeles area.

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

Adam Bair is a Principal in PwC’s National Tax Services practice, where he advises high-net-worth individuals, family offices, and closely held businesses on sophisticated tax planning strategies. With deep expertise in partnership taxation, estate and gift tax, and income-shifting techniques, Adam works closely with clients and advisors to structure tax-efficient solutions aligned with wealth preservation and succession goals. He is a licensed attorney with extensive experience navigating the intersection of legal strategy and federal tax law.

• Education & Credentials

Adam earned his LL.M. in Taxation (2010–2011) and his J.D. in Business Law (2008–2011) from the University of Miami School of Law, where he served as President of the Effective Firm Management Society, participated in the Student Bar Association, the Asian Pacific American Law Student Association, the Entertainment and Sports Law Society, the Tax Law Society, Books and Buddies, and the Rathskeller Advisory Board, and received the Dean’s Certificate of Academic Achievement in Constitutional Law (2008). He earned his B.A. in Journalism/Advertising from The University of North Carolina at Chapel Hill (2004–2008), where he made the Dean’s List in five semesters and was a member of the Sigma Alpha Lambda National Leadership & Honors Organization, the Advertising Club, and the College Republicans. He is a Florida licensed attorney.

• Recognition & Leadership

Adam served as President of the Effective Firm Management Society during law school and received the Dean’s Certificate of Academic Achievement in Constitutional Law.

• Professional Involvement

Adam frequently presents on topics related to advanced estate planning, entity structuring, and IRS compliance. Earlier in his career, he served as an Associate Editor of the Wealth Strategies Journal (August–November 2011).

• Experience

Adam has spent nearly fifteen years at PwC, serving as Principal since July 2021 in New York. He previously served as Director, International Tax Services (July 2017 – June 2021, New York); Manager, International Tax Services (July 2015 – June 2017, Houston); Senior Associate, International Tax Services (July 2013 – June 2015, Houston); and Associate, International Tax Services (November 2011 – June 2013, Houston). His international tax consulting work focused on U.S. and non-U.S. headquartered multinational corporations in the energy industry, including structuring outbound U.S. investments, tax-efficient financing structures and repatriation strategies, foreign tax credit and other attribute utilization techniques, cross-border leasing structures, and post-acquisition U.S. integration, advising clients in manufacturing, oil and gas exploration and production, and oilfield services. Before PwC, he was a Manager of Business Development at Foreya Partners and at Accounting Asia (both May–December 2010), a Legal Intern at the Guilford County District Attorney’s Office (2007), and an Intern at ComputerNet Resource Group (2006).

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.

Barbara T. Kaplan, Esq., Shareholder | Greenberg Traurig

Barbara T. Kaplan chairs Greenberg Traurig’s New York Tax Practice and focuses her tax litigation practice on representing domestic and foreign corporations, partnerships, and individuals in federal, state, and local tax examinations, controversies, and litigation, including administrative and grand jury criminal tax investigations. Her concentrations include tax compliance counseling, offshore account reporting, sensitive audits, promoter audits, preparer penalties, civil tax controversies, complex tax litigation, criminal tax investigations, voluntary disclosures, tax penalties and procedure, Bank Secrecy Act compliance, Circular 230 violations, ERISA litigation, regulatory investigations, state and local tax, and audits and litigation involving tax-exempt organizations.

• Education & Credentials

Barbara earned her LL.M. in Taxation from New York University School of Law (1979), her J.D., cum laude, from Brooklyn Law School (1975), her M.A. from Northwestern University (1972), and her B.A. from the University of Wisconsin-Madison (1970). She is admitted in New York and before the U.S. Supreme Court, the U.S. Court of Appeals for the Ninth Circuit, the U.S. District Courts for the Eastern and Southern Districts of New York, the U.S. Court of Federal Claims, and the U.S. Tax Court.

• Recognition & Leadership

Barbara has been named one of the top 50 women lawyers in New York City by Super Lawyers magazine and has been listed in The Best Lawyers in America for Litigation and Controversy – Tax from 2006 to 2026, including as Lawyer of the Year in 2020. She is recognized by International Tax Review as a Highly Regarded World Tax Leader for the Americas (2023, 2025, 2026) and a Women in Tax Leader (2025-2026), has been listed in the Chambers USA Guide from 2010 to 2026 and the Chambers High Net Worth Guide from 2022 to 2025, and won Euromoney Legal Media Group’s Americas Women in Business Law Award for Best in Tax Dispute Resolution in 2016. Other recognitions include Crain’s New York Notable Women in Law (2019), The Legal 500 United States, New York Metro Super Lawyers (2006-2025, including Top 50 Women and Top 100 lists), Fellowship in the American College of Tax Counsel, and an AV Preeminent rating.

• Professional Involvement

Barbara is a member of the Tax Sections of the American and New York State Bar Associations, the American Association for Justice, the National Association of Criminal Defense Lawyers, and the Bar Association of the City of New York. She served on the Advisory Board of the New York University Institute on Federal Taxation from 1989 to 1996 and on the Executive Committee of the New York State Bar Association Tax Section from 2001 to 2005. She is a frequent speaker at tax conferences, including the Practising Law Institute, the NYU Institute on Federal Taxation, the Tax Executives Institute, and the ABA Tax Section, and contributes to the GT Israel Law Blog.

• Experience

Barbara’s litigation experience includes representing foreign corporations in transfer pricing and valuation litigation, ERISA benefit-plan litigation, estate and family limited partnership challenges in U.S. Tax Court, partnership tax shelter cases across many industries, refund litigation in the Court of Federal Claims, and fraud-related Tax Court proceedings. Her administrative practice covers sensitive audits, offshore account reporting, TEFRA partnership proceedings, refund claims, transfer tax, tax shelters, REIT compliance, residency issues, and penalty and interest abatement, along with tax collection matters such as installment agreements, offers in compromise, and lien removal. She has completed voluntary disclosures involving undisclosed offshore accounts, defended taxpayers in summons enforcement and criminal investigations, and represented tax professionals before the IRS Office of Professional Responsibility. Earlier in her career, she served as a Trial Attorney and Senior Trial Attorney with IRS Regional and District Counsel and as an instructor in the IRS Criminal Tax Attorneys Training Program.

Scott D. Michel, Esq., Member | Caplin and Drysdale, Chartered

Scott D. Michel has worked on cutting-edge tax enforcement cases his entire career, advising individuals, families, corporations, tax professionals, financial institutions, and others on five continents in criminal and civil tax enforcement and compliance matters. Since the early 1980s his client representations have paralleled the domestic and international enforcement priorities of the IRS and the Department of Justice, including unreported income and false deduction cases, unreported foreign assets and structures, criminal tax shelter, Employee Retention Credit, conservation easement, and Malta Pension Plan cases, and employment tax, cash-reporting, and cryptocurrency reporting failures. He has helped many thousands of taxpayers return to compliance through the voluntary disclosure process and is routinely consulted by other practitioners on sensitive ethical questions in tax practice.

• Education & Credentials

Scott earned his J.D. from the University of Virginia School of Law in 1980, where he was elected to the Order of the Coif, and his B.S., with highest distinction, from Northwestern University in 1977. He is admitted in New York and the District of Columbia and before the D.C. Court of Appeals, the U.S. District Courts for the District of Maryland and the District of Columbia, the U.S. Supreme Court, the U.S. Bankruptcy Court for the District of Columbia, and the U.S. Tax Court.

• Recognition & Leadership

Scott served as Chair of the American Bar Association Section of Taxation for 2023-2024 and is the Section’s Immediate Past Chair. In spring 2025 he received the Jules Ritholz Memorial Merit Award from the ABA Tax Section’s Committee on Civil and Criminal Tax Penalties for outstanding work in criminal and civil tax controversy. He has been recognized in Chambers USA since 2009, the Chambers High Net Worth Guide (2022), The Legal 500 (recommended since 2014; Leading Lawyer for multiple years), The Best Lawyers in America since 2006 (Lawyer of the Year, 2023), Super Lawyers (including Top 100 in D.C., 2015), and The Washingtonian’s Top Lawyers (Lifetime Achievement, 2022). His firm received The American Lawyer’s Global Legal Award for Global Dispute of the Year in 2015 for the Swiss tax settlements and the ABA Rule of Law Initiative’s International Pro Bono Award in 2018.

• Professional Involvement

Scott has been active in the ABA Section of Taxation throughout his career, serving as Vice-Chair for Committee Operations (2016-2018), a Council Director, and Chair of the Committees on Civil and Criminal Tax Penalties and on Standards of Tax Practice, and founding and co-chairing the Section’s Annual International Tax Enforcement and Controversy Conference. He is an Adjunct Professor of Law in the University of Miami School of Law Graduate Program in Taxation, a Fellow and former Regent of the American College of Tax Counsel, a member of the Advisory Board of the American Tax Policy Institute, and a member of the International Fiscal Association. He has served as a mentor in the ABA Rule of Law Initiative, advising Croatian Ministry of Finance officials on tax enforcement, following similar work in Poland in 1992, and is Co-Founder and Director of Buildable Hours, Inc.

• Experience

Scott’s representative engagements include acting as criminal tax counsel in IRS and DOJ investigations with the objective of steering cases back into a civil context, handling sensitive offshore-related civil examinations and IRS Appeals for clients around the world, helping families and companies correct prior noncompliance through civil resolutions, resolving matters for banks and financial services firms with the DOJ Tax Division (often through non-prosecution agreements or no action), and advising.

Daniel N. Price, Esq., Managing Member | Law Offices of Daniel N. Price

Dan Price’s practice focuses on tax and Title 31 (Bank Secrecy Act) controversy matters with the IRS and tax matters before certain state tax authorities. For over nineteen years, Dan served as an attorney in the IRS Office of Chief Counsel, and his experience as a former trial attorney, supervisory trial attorney, and Special Assistant United States Attorney gives him a distinctive perspective on tax controversy and tax administration. For federal tax and federal immigration matters, he accepts clients nationally.

• Education & Credentials

Dan earned his J.D. with Honors from the University of Texas School of Law in 2002, during which he passed the Uniform CPA Exam (not licensed) and served on the editorial boards of two law journals. He holds a Master of Science in Accounting from Trinity University (1999, 4.00 GPA) and a B.B.A. in Accounting from The University of Texas at San Antonio (1998, 4.00 GPA, recognized as the College of Business’s graduating senior with the highest GPA). He is licensed to practice law in Texas and New York.

• Recognition & Leadership

In February 2025, the American College of Tax Counsel elected Dan as a fellow in recognition of his experience practicing tax law. During his IRS tenure he received numerous awards, including the LB&I Public Service Recognition Award (2016) and the Deputy Commissioner for Services and Enforcement Award (2015) for contributions to the Offshore Voluntary Disclosure Program and Streamlined Filing Compliance Procedures teams, the Chief Counsel Superior Achievement Award for Legal Support (2014), the SBSE Division Counsel Client Service Award (2012), and recognition as the 2009 SBSE Division Counsel Attorney of the Year.

• Professional Involvement

Dan volunteers with the American Bar Association on comment projects and serves on the AICPA’s Form 3520 Task Force. He maintains an active pro bono practice, including representing low-income taxpayers in Tax Court and administrative proceedings, handling asylum matters in Immigration Court and before USCIS, and teaching a tax-compliance webinar for volunteers assisting refugees. He writes for publications including Tax Notes, Procedurally Taxing, and the EA Journal, and submits comment letters to Treasury and the IRS on matters such as foreign trust and foreign gift reporting regulations and Forms 3520 and 3520-A.

• Experience

Dan’s government service included extensive international enforcement work: assisting the IRS in completely revising the Voluntary Disclosure Practice; working with the Offshore Voluntary Disclosure Programs, the Streamlined Filing Compliance Procedures, FBAR matters, Bank Secrecy Act investigations, LB&I compliance campaigns, expatriation issues, and international collection; and serving as a Chief Counsel FBAR Coordinator reviewing willful FBAR penalty cases and as part of the Chief Counsel team that met regularly with the DOJ Tax Division. In 2014, the Chief Counsel appointed him Managing Counsel of the Austin, Texas post of duty. He tried many cases, managed attorneys and paralegals, provided training across the United States and Puerto Rico, served as an IRS spokesperson presenting in the United States, Mexico, and Canada, and departed the government at the end of 2021 as a member of the teams overseeing the Voluntary Disclosure Practice, the Streamlined Filing Compliance Procedures, and the Relief Procedures for Certain Former Citizens.

Alyssa Maloof Whatley, Esq., Director | Frost Law

Alyssa Maloof Whatley is the Director of Tax Controversy (Domestic) at Frost Law, bringing extensive experience and a client-centered approach to resolving complex tax matters. An experienced tax lawyer with a proven record of reducing tax liability, she is a dedicated advocate in navigating the IRS, crafting tailored solutions for each tax problem, from audits to negotiated settlements, and emphasizing clear communication, education, and client-focused technology.

• Education & Credentials

Alyssa earned her J.D. from Georgia State University College of Law, where she received the CALI Excellence for the Future Award in National Security Law, held a J.B. Moore Tax Clinic Fellowship, and worked in the Philip C. Cook Low-Income Taxpayer Clinic and as a graduate research assistant. She earned her B.A. in International Affairs, cum laude, from the University of Georgia. She is admitted in Georgia and practices before the United States Tax Court and the U.S. District Court for the Northern District of Georgia.

• Recognition & Leadership

Alyssa has been named to the Super Lawyers Rising Stars list from 2019 through 2026, recognized in Best Lawyers: Ones to Watch for Litigation and Controversy – Tax Law from 2023 through 2026, received AVVO’s Client’s Choice Award from 2018 to 2020 based on client ratings, and received the 2019 Distinguished Service Award from the National Association of Consumer Bankruptcy Attorneys.

• Professional Involvement

Alyssa is a member of the State Bar of Georgia, Vice Chair of the ABA Tax Collection, Bankruptcy & Workouts Committee, a board member of the North Georgia Low Income Taxpayer Clinic, and served as President of the Metro Atlanta Consumer Bankruptcy Attorneys Group from 2016 to 2018. She speaks frequently on tax and bankruptcy topics, including at ABA tax meetings and the ABA Criminal Tax Fraud and Controversy Conference, NACBA conventions, and American Society of Tax Problem Solvers programs, and has been quoted in Tax Notes Federal and featured on WSB-TV Channel 2’s investigation of a high-profile Georgia tax settlement case.

• Experience

Before joining Frost Law, Alyssa founded her own successful law firm. Her background, from working in her family’s small business to assisting a U.S. Bankruptcy Judge, has given her a comprehensive understanding of financial challenges from multiple perspectives, and she has dedicated her career to tax litigation, helping individuals and businesses resolve back-tax issues.

Bonnie J. Daniels, Esq., Associate | Roberts & Holland

Bonnie J. Daniels provides comprehensive tax planning to high-net-worth individuals by crafting domestic and cross-border gift and estate tax-efficient plans, structuring closely held businesses, and facilitating philanthropic objectives. Her practice includes drafting wills and domestic and foreign trusts (including dynasty trusts, insurance trusts, and defective grantor trusts), forming closely held family companies, and structuring gift, estate, and income tax-efficient transactions. She advises inbound and outbound clients on their tax and reporting obligations, including the specific U.S. issues that arise in the context of foreign trusts, helps clients structure their qualified opportunity zone (QOZ) investments, advises on the New York State pass-through entity tax, and forms private foundations while providing operational advice on avoiding self-dealing pitfalls and related issues.

• Education & Credentials

Bonnie earned her LL.M. in Taxation from New York University School of Law (2018 – May 2022), her J.D. from Harvard Law School (2015–2018), and her B.A., summa cum laude, from LeTourneau University (2008–2012), where she earned a 4.0 GPA. She is admitted to practice in New York.

• Professional Involvement

Bonnie is a member of The Society of Trust and Estate Practitioners and of the Tax Section and Trusts & Estates Law Section of the New York State Bar Association.

• Experience

Bonnie has been a Tax Associate at Roberts & Holland LLP since October 2018, having first joined the firm as a Summer Intern in August 2017. She was previously a Summer Intern at McDermott Will & Emery LLP (May–July 2017) and, before law school, a Technical Writer at Investor-tools, Inc. (April 2014 – August 2015). Her early legal experience includes a Trusts and Estates legal internship with Bruce M. DiCicco, Attorney at Law, and an immigration legal internship with Maria Mateo, Attorney at Law (both January-March 2014), where she drafted petitions, completed immigration forms, and assisted clients in English and Spanish. She also taught as a secondary teacher at Athens Christian Preparatory Academy in Athens, Texas (2012–2013). Her published work includes co-authoring “Estate Planning Opportunities in Times of Economic Upheaval” for the firm’s Estate & Gift Tax Planning Newsletter (May 2020).

Joseph M. Calianno, JD, LLM, MBA, CPA, Managing Director; National Tax Practice | Andersen Tax Joe Calianno is a Managing Director in Andersen’s US National Tax

practice in the Washington, D.C. office, where he serves as the USNT leader for international tax. He advises clients on all areas of international tax, including provisions related to the Tax Cuts and Jobs Act, the One Big Beautiful Bill Act, and cross-border restructurings.

• Education & Credentials

Joe earned his LL.M. in Taxation from New York University School of Law, his MBA from New York University’s Leonard N. Stern School of Business, his J.D. from Villanova University School of Law, where he served on the Villanova Law Review, and his B.S. in Accounting from the University of Scranton.

• Recognition & Leadership

Joe serves on the Tax Notes Council of Eminent Persons and is regularly quoted in the tax press on international tax developments. His leadership roles span the profession’s major organizations: he is a Past Chair of the ABA Tax Section’s Foreign Activities of U.S. Taxpayers committee and of the AICPA’s International Tax Technical Resource Panel, a member of the International Fiscal Association’s Executive Committee, and previously served as Co-Chair of the Federal Bar Association’s International Tax Section.

• Professional Involvement

Joe is a member of the ABA Tax Section, the AICPA (including prior service on its Tax Executive Committee), and the IFA (past member of the US Branch Council), and previously served as an Advisory Board Member for the Federal Bar Association’s Annual Tax Law Conference. He has been a guest lecturer in NYU Law School’s Graduate Tax Program (International Business Transactions) and an adjunct faculty member in Georgetown Law’s Graduate Tax Program. A frequent speaker on international and corporate tax issues, he has presented for the ABA, AICPA, Atlas, BNA, DC Bar, Dallas Bar, Federal Bar, GW/IRS, Houston International Tax Forum, IFA, NYU Advanced International Tax Institute, PLI, TEI, St. Louis International Tax Group, USD School of Law International Tax Institute, Wall Street, and World Trade Council tax conferences, and has published in outlets including CCH, International Tax Review, the Journal of International Taxation, the Journal of Corporate Tax, PLI, Tax Notes, Tax Notes International, Tax Management International Journal, Tax Management Memorandum, and The Tax Adviser.

• Experience

Before joining Andersen, Joe spent over 15 years as a partner at BDO and Grant Thornton, serving as the International Technical Tax Practice Leader in both firms’ national tax offices. He previously served as Special Counsel to the Deputy Associate Chief Counsel (International) in the IRS Office of Chief Counsel, acting as a technical advisor to the Associate and Deputy Associate Chief Counsel (International), reviewing international tax regulations, revenue rulings, Notices, TAMs, and PLRs, and providing 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.

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

Thomas Giordano-Lascari is a Partner in Greenberg Glusker’s Private Client Services Group with nearly two decades of experience advising high-net-worth individuals and closely held businesses on international income tax and estate planning issues. Highly regarded for representing global families with footprints in multiple jurisdictions, he helps clients structure worldwide assets to maximize family objectives and minimize income and transfer taxes, and frequently assists with pre-immigration planning, foreign investments in the United States, U.S. residency planning and management, and expatriation planning. He also provides sought-after guidance on foreign trusts to foreign fiduciaries, U.S. beneficiaries, and grantors, addressing compliance obligations and tax consequences.

• Education & Credentials

Thomas earned his LL.M. in Taxation from Loyola Law School (2008), his J.D. from the University of New Mexico School of Law (2005), where he was a staff member and manuscript editor of the New Mexico Law Review and an extern to Justice Bosson of the New Mexico Supreme Court, and his B.B.A. in Finance from the University of New Mexico (2003). He is admitted in California and before the U.S. District Court for the Central District of California and the U.S. Tax Court.

• Recognition & Leadership

Thomas is recognized in the Chambers High Net Worth Guide as a leading lawyer in Private Wealth Law (2024, 2025) and is listed in Legal 500’s US Elite Los Angeles for Tax (2026), the ALM/Law.com Private Client Global Elite and Excellence directories (2026), The Best Lawyers in America for Trusts and Estates (2023-2026), and Southern California Super Lawyers (2025-2026, and as a Rising Star from 2019 to 2021). The Los Angeles Business Journal named him among its “Leaders of Influence: Thriving in Their 40s” in 2022.

• Professional Involvement

Thomas is Chair of the Los Angeles Chapter of the Society of Trust & Estate Practitioners (STEP), where he also serves as Program Chair on the Executive Committee, and a member of the International Academy of Estate and Trust Law. He serves on the Executive Committee of the Los Angeles County Bar Association’s Taxation Section and belongs to the International Young Lawyers Association’s Taxation and Private Client Committees. His past roles include chairing the LACBA 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.

• Experience

Thomas frequently speaks on international tax legislation and tax strategies relating to foreign trusts, outbound planning, and GILTI inclusions, including at the NYU Tax Institute’s Introduction to International Taxation program, and has published in Bloomberg Tax on topics including a UN wealth tax framework (2024) and the Supreme Court’s Moore v. United States foreign earnings tax case (2023).

Michael J.A. Karlin, 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.

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

Alan I. Appel 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. He is a Professor of Law at New York Law School and Director of its International Tax Program.

• Education & Credentials

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

• Recognition & Leadership

Professor Appel is a Fellow of the American College of Tax Counsel and serves on the Board of Advisors for the Journal of International Taxation. He has appeared on radio and television to discuss income tax issues and was featured in AccountingToday.com‘s coverage of FATCA’s requirements.

• Professional Involvement

On behalf of the ABA Tax Section, Professor Appel had primary responsibility for drafting comments to the Treasury Department and IRS on proposed regulations under Section 1446 of the Internal Revenue Code, and the 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 chaired the U.S. Activities of Foreigners and Tax Treaties Committee. He has published extensively, including in Tax Notes, The Journal of Taxation, Tax Management Memorandum, the Tax Management International Journal, The Journal of International Taxation, and the New York Law Journal, and has contributed multiple chapters to the New York University Institute on Federal Taxation.

• 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 later spent 13 years as Counsel at Bryan Cave Leighton Paisner LLP (formerly Bryan Cave LLP). He began teaching at New York Law School as an adjunct professor in 2009 and joined the faculty full-time in 2013, where he teaches Commercial Law, Federal Income Tax (Individual and Corporate), International Taxation, and an International Tax Planning Seminar.

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

William B. Sherman concentrates his practice on domestic and international taxation, providing 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 experience spans U.S. investment overseas, foreign investment in the U.S., and international, federal, state, and local tax issues involving investment fund structuring, corporate reorganizations, partnerships, equipment leasing, Subchapter S, executive compensation, stock options, and trusts and estates.

• Education & Credentials

Bill earned 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 in Florida and New York.

• Recognition & Leadership

Bill has been recognized in the Chambers USA guide for Tax from 2009 through 2026 and in The Legal 500 USA for International Tax and U.S. Taxes: Non-Contentious from 2023 through 2026. He has been listed in The Best Lawyers in America for Litigation and Controversy – Tax since 2005, Tax Law since 2013, and Closely Held Companies and Family Business Law since 2014, and was named Fort Lauderdale Litigation and Controversy – Tax Lawyer of the Year for 2020 and 2022. Additional honors include Leading Global Tax Lawyers by Lawdragon 500 (2025, 2026), Who’s Who Legal recognition for Corporate Tax, Top Lawyer: Tax Law by Fort Lauderdale Illustrated (2020), Florida Super Lawyers (2015-2019), and an AV Preeminent peer-review rating.

• Professional Involvement

Bill is a well-known lecturer who 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 (2025). He is a Fellow of the American College of Tax Counsel, a member of the NYU Institute on Federal Taxation Advisory Board, past chair of the ABA Tax Section’s Committee on U.S. Activities of Foreigners and Tax Treaties, and a member of the New York State Bar Association Tax Law Section, the International Fiscal Association, and The Florida Bar Tax Law Section. For 12 years he was an adjunct professor of tax law in the University of Miami’s Graduate Tax Program.

• Experience

Bill’s representative experience includes advising a leading physician-led nephrology organization on a strategic private equity investment and ongoing acquisitions; advising an investor in North American renewable energy projects on investment and tax structuring; advising a private equity company managing more than $2 billion on the sale of a majority equity stake; structuring the domestication of a foreign government-contracting company 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.

DAY 1, MONDAY, JULY 20, 2026

WELCOME REMARKS AND INTRODUCTION | 8:25am – 8:45am

Kathleen Costello, CMP, Assistant Director, NYU School of Professional Studies, New York, NY
Michael J. Miller, Esq., Partner, Roberts & Holland, New York, NY

SESSION 1 – US TAXATION OF FOREIGN PERSONS | 8:45am – 12:00pm

This session covers the rules governing source of income; US trade or business; effectively connected income; FDAP income; withholding taxes; FIRPTA; branch profits tax; branch level interest tax; earnings-stripping; anti-conduit financing; and the base erosion anti-abuse tax (BEAT).

Michael J. Miller, Esq., Partner, Roberts & Holland, New York, NY
James S.H. Null, Esq., Partner, Kilpatrick Townsend & Stockton, New York, NY

BREAK | 10:15am – 10:30am

LUNCH | 12:00pm – 1:15pm

SESSION 2 – TAX TREATY PRIMER—AN OVERVIEW OF TAX TREATIES AND TAX TREATY PLANNING TECHNIQUES | 1:15pm – 2:45pm

Tax treaties modify the statutory tax rules affecting cross-border taxation. This session explores the typical provisions of such treaties, who is eligible to benefit under a treaty, and how a treaty modifies the tax rules that would otherwise apply.

David G. Shapiro, Esq., Partner, Saul Ewing, Philadelphia, PA
Robert Christoffel, Esq., Counsel, Saul Ewing, Washington, DC

BREAK | 2:45pm – 3:00pm

SESSION 3 – TRANSFER PRICING BASICS | 3:00pm – 4:30pm

Cross-border transactions between related persons are subject to the transfer pricing rules of Section 482. This session addresses the general rules of Section 482 and the specific applications of those rules to certain categories of transactions, including transfers of tangible and intangible property; and services and loans. The session also explores the economic analysis relevant to transfer pricing; correlative relief; and cost-sharing agreements.

Oliver Minguillon, MBA, Managing Director, Economic and Valuation Services (Transfer Pricing), KPMG, New York, NY

DAY 2, TUESDAY, JULY 21, 2026

SESSION 1 – CONTROLLED FOREIGN CORPORATIONS | 8:45am – 12:00pm

The Internal Revenue Code provides various regimes for the taxation of US shareholders of a controlled foreign corporation (CFC). This session explores the definitions of a CFC and US shareholder (including applicable stock ownership and attribution rules), the categories of Subpart F income and applicable exceptions, the net CFC tested income (NCTI, formerly GILTI) rules, and Section 956 inclusions, highlighting the changes introduced by the One Big Beautiful Bill Act, where applicable. The session also addresses the Section 962 election for non-corporate US shareholders, distributions of previously taxed earnings and profits (PTEP), the Section 245A dividends received deduction for corporate US shareholders, and the Section 1248 dividend recharacterization.

Logan E. Gans, Esq., Partner, Holland & Knight, Miami, FL
Lucas Giardelli, Esq., Partner, Mayer Brown, New York, NY

BREAK | 10:15am – 10:30am

LUNCH | 12:00pm – 1:15pm

SESSION 2 – PASSIVE FOREIGN INVESTMENT COMPANIES | 1:15pm – 2:45pm

The US taxation of US persons who are shareholders of passive foreign investment companies (PFICs) is complex and often misunderstood. This session covers the definitional provisions of the PFIC rules and the alternative methods of taxation of US shareholders of a PFIC. Certain proposed regulations addressing the treatment of PFICs held through domestic partnerships are also addressed.

Amitai Barth, Esq., Senior Manager, Deloitte, Washington, DC
Jason Robertson, Esq., Principal, Deloitte, Washington, DC

BREAK | 2:45pm – 3:00pm

SESSION 3 – DIRECT AND INDIRECT FOREIGN TAX CREDIT AND FOREIGN TAX CREDIT LIMITATION | 3:00pm – 4:30pm

The US imposes worldwide taxation on US citizens, residents, and US business entities. This session explores how the provisions of Sections 901, 904, and 960 provide for, and limit the ability of such US taxpayers to claim tax credits for foreign taxes that they pay directly and indirectly.

Adam Bair, Esq., Principal, National Tax Services, PwC, New York, NY
Steven Burns, CPA, Director, National Tax Services, PwC, Washington, DC

DAY 3, WEDNESDAY, JULY 22, 2026

SESSION 1 – FIXING THE PAST: ETHICAL AND OTHER CONSIDERATIONS IN ADDRESSING ERRORS, OMISSIONS, AND FAILURES TO FILE | 8:45am – 9:45am

For clients who have willfully failed to comply with tax or tax-related obligations relating to foreign income or foreign assets, submitting a voluntary disclosure may be a means to resolve non-compliance and limit exposure to criminal prosecution. This panel discusses the ethical responsibilities for tax professionals, including maintaining confidentiality, avoiding conflicts of interest, and the overarching rules of Circular 230, that come into play when advising clients about the pros and cons of voluntary disclosures and other corrective options to consider when addressing omissions and errors in complying with tax obligations.

Barbara T. Kaplan, Esq., Shareholder, Greenberg Traurig, New York, NY
Scott D. Michel, Esq., Member, Caplin and Drysdale, Chartered, Washington, DC
Daniel N. Price, Esq., Managing Member, Law Offices of Daniel N. Price, San Antonio, TX
Alyssa Maloof Whatley, Esq., Director, Frost Law, Atlanta, GA

SESSION 2 – INDIVIDUAL EXPATRIATIONS | 9:45am – 10:45am

Special income, estate, and gift tax rules, set forth in Sections 877A and 2801, limit the ability of US citizens and certain lawful permanent residents to achieve tax benefits by relinquishing their citizenship or terminating their status as lawful permanent residents. This session provides an overview of these provisions.

Bonnie J. Daniels, Esq., Associate, Roberts & Holland, New York, NY
Michael J. Miller, Esq., Partner, Roberts & Holland, New York, NY

BREAK | 10:45am – 11:00am

SESSION 3 – CROSS-BORDER TRANSFERS AND CORPORATE INVERSIONS | 11:00am – 12:00pm

The rules of Sections 367 and 7874 curb the ability of US taxpayers to transfer assets to, or to receive assets from, foreign corporations in transactions that would otherwise qualify as tax-free, and to prevent US business entities from “inverting” to become foreign-owned.

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

LUNCH | 12:00pm – 1:15pm

SESSION 4 – PLANNING FOR FOREIGN INDIVIDUAL INVESTING IN OR MOVING TO THE US | 1:15pm – 2:45pm

Foreign individuals who invest in or move to the US are confronted with structuring and planning to minimize US income and estate and gift taxation, as well as integrating the US rules with their home country tax rules. This session addresses the application of the US rules and planning considerations for such foreign individuals.

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

BREAK | 2:45pm – 3:00pm

SESSION 5 – CASE STUDIES FOR OUTBOUND AND INBOUND INVESTMENT | 3:00pm – 4:30pm

This session incorporates the disparate rules covered in the preceding sessions into case studies dealing with both outbound and inbound investment scenarios and provides a review of the material covered during the entire program.

Alan I. Appel, Esq., Professor of Law, New York Law School, New York, NY
Michael J. Miller, Esq., Partner, Roberts & Holland, New York, NY
William B. Sherman, Esq., Partner, Holland & Knight, Fort Lauderdale, FL