Advanced International Taxation 2025 (presented by NYU School of Professional Studies)

Joseph M. Calianno, JD, LLM, MBA, CPA | Andersen Tax LLC

Joe Calianno is a managing director in the US National Tax practice in the Washington D.C. office. He advises clients on all areas of international tax, including provisions related to the Tax Cuts and Jobs Act and cross-border restructuring. Prior to joining Andersen, Joe spent several years as a partner at BDO and Grant Thornton, where he served as the International Technical Tax Practice Leader in both firm’s national tax offices.

Enrica Ma, Esq. | EY

Brandon C. Svetcov, Esq | EY

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

Hyung “Sean” Dokko is a managing director in the Commercial practice of the New York City office. Sean advises clients on international tax matters including advising on international tax issues concerning cross-border operations and transactions. Sean has extensive experience in developing, implementing, and reporting tax planning strategies and crossborder restructurings.

Thomas M. Giordano-Lascari, Esq. | Greenberg Glusker Fields Claman & Machtinger LLP

Thomas Giordano-Lascari is a Partner in the Private Client Services Group with nearly two decades of experience in advising high-net-worth individuals and closely-held businesses with international income tax and estate planning issues. Highly regarded for his expertise in representing global families with footprints in multiple jurisdictions, Thomas assists clients in structuring their worldwide assets to maximize family objectives and minimize income and transfer taxes. Thomas frequently aids clients with pre-immigration planning, foreign investments in the United States, U.S. residency planning and management, and expatriation planning.

Michael J.A Karlin, Esq. | Karlin & Peebles, LLP

Michael Karlin is a lawyer with over 45 years of experience advising corporate and individual clients on tax, estate planning and business matters involving a crossborder element. Michael began his career in London in 1975 as an articled clerk and assistant solicitor at the firm of D.J. Freeman & Co. (now part of Locke Lord LLP). He was admitted as a solicitor in 1977. In 1980, he became a member of the California Bar and he has resided in California ever since. After three years with Gelles, Singer & Johnson, a boutique private client firm in Los Angeles, he became an associate and then a partner of Morgan, Lewis & Bockius. He then spent three years (1997-2000) as a principal in the international tax services group of KPMG, before starting his own firm in 2001. That firm is now part of Karlin & Peebles, LLP, co-founded in 2007 by Michael together with Jane Peebles, a well-known domestic and international estate planner and expert on cross-border philanthropy.

William S. Dixon, Esq. | Citigroup Global Markets

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

Sam Kaywood is a partner in the Federal & International Tax Group and a co-chair of the International Team. Sam concentrates his practice on federal income tax and international tax, including cross-border M&A and joint ventures, as well as in-bound investments into the U.S. Sam has worked on virtually all forms of cross-border investments, with substantial experience in Canada, Europe, China, and Latin America. He is particularly active in structuring investments and acquisitions in Latin America, including Brazil, Mexico, Argentina, and Chile.

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

William B. Sherman is a partner in Holland & Knight’s Miami and Fort Lauderdale offices. Mr. Sherman concentrates his practice in the area of domestic and international taxation. He provides sophisticated tax planning for mergers and acquisitions, restructurings, joint ventures and investments for clients in diverse industries, such as private equity, healthcare, hospitality, petrochemicals, aluminum, real estate, transportation, telecommunications, retailing, investment management, pharmaceuticals and numerous others. In addition, Mr. Sherman has experience in a broad range of transactions involving United States investment overseas, foreign investment in the U.S., as well as international, federal, state and local taxation issues involving structuring investment management funds, corporate reorganizations, partnerships, equipment leasing, Subchapter S, executive compensation, stock options, and trusts and estates.

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

Adam Bair is a Principal in PwC’s National Tax Services practice, where he advises highnet-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 frequently presents on topics related to advanced estate planning, entity structuring, and IRS compliance. Adam holds a J.D. and is a licensed attorney with extensive experience navigating the intersection of legal strategy and federal tax law.

J.P. Gregorcy, CPA | PwC

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

Alan I. Appel specializes in international and domestic tax planning involving taxation of mergers and acquisitions, partnerships, joint ventures, and limited liability companies, as well as tax controversy matters. Prior to joining New York Law School, Professor Appel began his career as a trial attorney in the Office of Chief Counsel, Internal Revenue Service in Washington, D.C. and New York City. On behalf of the American Bar Association (ABA) Tax Section, Professor Appel had the primary responsibility for drafting and submitting comments to the U.S. Treasury Department and IRS concerning the scope of the guidance provided by proposed regulations under Section 1446 of the Internal Revenue Code. He was also asked by the Office of the Chief Counsel to train its attorneys on this issue. Professor Appel published four articles on the Section 1446 regulations in The Journal of International Taxation, Tax Management Memorandum, and the Tax Management International Journal.

Heather Ripley, Esq. | Alston & Bird LLP

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 counsels U.S. and foreign business entities and high-net-worth individuals on tax-efficient structuring for their U.S. and cross-border investments and activities, understanding their U.S. tax and compliance obligations and risks, and rectifying noncompliance issues. She has advised clients on income tax treaty application, FATCA, FIRPTA, and other tax issues for inbound investments into the United States, the anti-deferral regimes for outbound investments (CFC, PFIC), and tax aspects of M&A transactions. Heather also advises clients on various tax information reporting regimes.

Sean J. Tevel | Holland & Knight LLP

Sean Tevel is a private wealth services and international tax attorney in Holland & Knight’s Miami office. Mr. Tevel advises foreign and domestic clients on U.S. federal income, gift and estate tax matters associated with their cross-border investments and businesses.

Mr. Tevel has significant experience with respect to the structuring of U.S. real estate investments, including the application of the Foreign Investment in Real Property Tax Act of 1980 (FIRPTA). He often represents domestic and foreign funds on fund formation and associated structuring considerations for non-U.S. investors. He also regularly advises on joint venture transactions both in a domestic and cross-border context.

Jason Schwartz | Fried, Frank, Harris, Shriver & Jacobson LLP

Jason Schwartz is a tax partner and co-heads the firm’s Digital Assets and Blockchain Practice. He specializes in tax issues relating to financial products, securitizations, funds, treaties, lending, and digital assets.

Jason is ranked Band 5 in Tax by Chambers USA and as a “Next Generation Partner ” by Legal 500 US in Tax: Financial Products. In response to the Chambers USA survey, a client commented that “Jason is a fantastic tax lawyer. He is knowledgeable, smart and responsive.”

Matthew Stevens | EY

Megan L. Brackney, Esq. | Kostelanetz LLP

Megan L. Brackney is a tax controversy attorney with a distinguished track record of delivering exceptional results for clients facing complicated and difficult tax issues. Megan develops innovative strategies to resolve compliance concerns, voluntary disclosures, civil audits, and criminal investigations for individuals, trusts, estates, corporations, and partnerships, including audits conducted under the IRS’s centralized audit regime of the Bipartisan Budget Act. Megan advocates for clients in IRS Appeals, and represents clients in litigation in the U.S. Tax Court and federal district courts. She has successfully defended taxpayers against assessment of tax penalties, including income tax, trust fund recovery, and foreign information return penalties.

Victor A. Jaramillo, Esq. | Caplin & Drysdale

Victor Jaramillo is a Member in Caplin & Drysdale’s Washington, D.C. office and is a member of the firm’s Board of Directors. He advises multinational corporations, financial institutions, and individual clients on a broad range of tax matters, including tax controversies, risk management and international compliance, and cross-border structuring. He also utilizes his Spanish fluency to advise Spanish-speaking clients.

Mr. Jaramillo’s major areas of practice include subpart F, tax treaty issues and competent authority proceedings, FATCA entity classification and compliance, withholding and information reporting, financial products, and individual compliance.

Lawrence A. Sannicandro, Esq. | McCarter & English, LLP.

Larry has favorably resolved hundreds of federal and state tax controversies, many of which involved sophisticated and complex tax issues that established legal precedent. Lawrence (Larry) Sannicandro focuses his practice on federal and state tax controversies, including representation in audits, administrative appeals, collection matters, summons proceedings, criminal tax investigations and prosecutions, and litigation in the United States Tax Court, federal district and appellate courts, and state tax tribunals. He has extensive experience providing tax-related advice with respect to original tax return reporting positions on a broad range of substantive tax issues, amending tax returns, filing and litigating claims for refund, challenging civil tax penalties, reporting foreign assets and income, and making voluntary disclosures.

Melissa L. Wiley, Esq. | Lowenstein Sandler LLP

Melissa Wiley has over 20 years of experience in tax controversy and litigation on a wide range of civil tax matters at the federal and state level. She represents clients at all levels of administrative controversy with the IRS, including audits and cases before the IRS Office of Appeals, and has significant experience handling penalty and international information reporting matters. Her experience includes litigation in the U.S. Tax Court, Court of Federal Claims, and various federal district courts, representing clients facing government and thirdparty subpoenas and investigations. She also counsels on voluntary disclosures of prior tax noncompliance.

An actuary by training, Melissa has practiced at a Big Four accounting firm, first as an Assistant General Counsel and later as a Senior Manager in the firm’s National Tax department; as well as in the Tax practice of an AmLaw 20 global law firm. A respected authority on tax controversy topics, Melissa frequently presents on IRS filing requirements, penalties, and enforcement, as well as on ethics and the Corporate Transparency Act. She is active in numerous professional organizations such as the AICPA and the ABA Tax Section, where she previously served as Vice Chair for Committee Operations and is currently a member of the Nominating and Appointments to the Tax Court Committees. She is also the chair of the DC Bar Tax Audits & Litigation Committee and the Regent for the Federal Circuit for the American College of Tax Counsel.

Melissa’s pro bono work includes assisting local children and caretakers through the Children’s Law Center, where she served on the board for a decade and has provided pro bono services in custody and abuse/neglect matters for more than 15 years.

DAY 1: THURSDAY, JULY 17

CONTROLLED FOREIGN CORPORATION PLANNING | 8:25am – 9:45am; 10:00am – 11:30am

Subpart F imposes numerous rules that impose US taxation on US shareholders of CFCs. This session addresses planning opportunities and traps for the unwary, earnings and profits limitations, and the use of various exceptions, including the same-country exception, the look-through rule for certain other payments between related CFCs, the active rent and royalty exception, and the high-tax exception. The discussion also addresses rules applicable to foreign base company sales and services income. The session covers the addition of “GILTI” rules pursuant to which US shareholders of CFCs are taxable on a far broader class of income than under the older Subpart F rules, including the definition of GILTI, the scope of the high-taxed exception, the ability to offset GILTI tax with foreign tax credits, expense apportionment, application of the GILTI rules to partners of partnerships, and current regulatory guidance.

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., Partner, EY Americas Director of International Tax and Transaction Services (ITTS), National Tax Department, Washington, DC

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

Break | 9:45am – 10:00am

Break | 11:30am – 11:45am

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

A principal focus of the Tax Cuts and Jobs Act 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 the TCJA, 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, Karlin & Peebles, Los Angeles, CA

Lunch | 1:00pm – 2:15pm

INTERNATIONAL MERGERS AND ACQUISITIONS: US TAX CONSIDERATIONS AND PLANNING TECHNIQUES | 2:15pm – 3:30pm; 3:45pm – 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 the TCJA, 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 18

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

J.P. Gregorcy, CPA, Director, National Tax Services, PWC, Chicago, IL

Break | 10:15am – 10:30am

“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

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, Fried Frank, Washington, DC

Matthew Stevens, Esq., Principal, EY, Washington, DC

Break | 3:00pm – 3:15pm

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.

Megan L. Brackney, Esq., Partner, Kostelanetz, New York, NY

Victor A. Jaramillo, Esq., Partner, Caplin & Drysdale, Washington, DC

Lawrence A. Sannicandro, Esq. Partner, McCarter & English, Newark, NJ

Melissa L. Wiley, Esq., Partner, Lowenstein Sandler, Washington, DC