BNA Tax & Accounting gives you an unparalleled foundation on which to base your guidance, drawing on the insights and expertise of more than 1,000 of the world's leading tax and financial accounting experts, including
- Former IRS commissioners and members of regulatory agencies
- Practitioners with leading accounting firms
- Partners from the world's most prestigious law firms
- Leading educators
Many of our authorities provide expert analysis in the form of one of BNA Tax & Accounting’s renowned Portfolios; others offer practical, authoritative answers to a comprehensive range of tax questions in our Tax Practice Series.
All share unstintingly of their own experience and expertise in the form of sample plans, client letters, and other practice tools.
A | B | C | D | E | F | G | H | I | J | K | L | M | N | O | P | Q | R | S | T | U | V | W | X | Y | Z
A
Byrle M. Abbin, Esq.
Heidi K. Abegg, Esq.Heidi K. Abegg, B.A., cum laude, Valparaiso University (1993); J.D., Valparaiso University School of Law (1996); Co-Author, “The Developing Constitutional Standards for ‘Coordinated Expenditures’: Has the Federal Election Commission Finally Found a Way to Regulate Issue Advocacy?,” Election Law Journal (2001); Co-Author, “Free Speech and the Christian Coalition Case,” Free Speech and Election Law News, Summer 1999.
Lobbying and Political Expenditures (Portfolio 613) C. Chester Abell, Jr.
Chester Abell, Jr., CPA, B.S., Accounting and Mathematics, University of Kentucky. Abell is a certified public accountant licensed in the state of Ohio, the commonwealth of Kentucky and the District of Columbia. Chester is a member of the American Institute of Certified Pubic Accountants, the Ohio Society of CPAs and The Kentucky Society of Certified Public Accountants; Abell is a leader in Ernst & Young LLP’s Tax Accounting and Risk Advisory Services group. As the National Director of Tax Accrual and IFRS Tax Services, Chester is one of the firm’s leading authorities on Accounting for Income Taxes (SFAS 109) and on the tax aspects of conversion from U.S. GAAP to IFRS.
Howard Abrams, Esq.Howard E. Abrams, Esq., B.A., University of California at Irvine (1976; summa cum laude); J.D., Harvard Law School (1980; cum laude); Law Clerk to the Honorable Theodore Tannenwald, Jr., Chief Judge, United States Tax Court (1980-82); Professor, Emory Law School, since 1983; Adjunct Professor, University of Georgia College of Law, since 1993; Visiting Professor, Cornell Law School (1987-88); Director of Real Estate Tax Knowledge, Deloitte & Touche (1989-90); Of Counsel, Steptoe & Johnson (2003-04); co-author, Federal Income Taxation of Corporations and Shareholders (Aspen Law & Business: 3d ed. 2000); co-author, Federal Corporate Taxation (Foundation Press: 5th ed. 2002); co-author, Fundamentals of US Taxation (Kluwer Law International: 1999); member, District of Columbia Bar; member, American Law Institute; member, American Bar Association, Tax Section.
Disregarded Entities (Portfolio 704) Salvador D, Aceves, MS Taxation, EdD, Associate ProvostSalvador D. Aceves holds both a Bachelor of Science in Accounting and a Doctorate in Education with an emphasis in International Business from the University of San Francisco. Dr. Aceves also holds a Master in Taxation from Golden Gate University. Dr. Aceves is the Associate Provost responsible for planning, budget, and review for the University of San Francisco. He is also an Associate Professor of Accounting in the University's School of Business, and he is an Adjunct Professor in the University's School of Law. Dr. Aceves is the lead author of Financial Accounting (Houghton Mifflin 2008).
Interest Expense Deductions (Portfolio 536) Alan S. Acker, Esq.Alan S. Acker, University of Illinois (B.S. 1974), Illinois Institute of Technology, Chicago-Kent School of Law (J.D. 1977); member, Ohio, Illinois, and Virginia Bars; member, American Institute of Certified Public Accountants and Ohio CPA Society; Fellow, American College of Trusts and Estates Counsel; adjunct professor of law at Capital University Law and Graduate Center, Columbus, Ohio; contributor to Tax Management Estates, Gifts and Trusts Journal, Estate Planning, and other legal publications; lecturer at various tax seminars.
Accounting for Trusts and Estates (Portfolio 5202)Administrative Powers (Portfolio 820)Estate and Trust Administration — Tax Planning (Portfolio 855)Income Taxation of Trusts and Estates (Portfolio 852)Income Respect of a Decedent (Portfolio 862) Robert E. Ackerman
Bob Ackerman serves as a technical advisor assisting multinational organizations with global transfer pricing planning, tax-effective supply chain practices, documentation, and local-country controversy resolution. Bob has extensive experience in the development and implementation of tax strategies regarding the migration of intangibles and execution of licensing and cost sharing arrangements. Bob's experience also includes a significant emphasis on resolution of international transfer pricing controversies at audit and Competent Authority. Bob has 35 years experience involving international tax and transfer pricing issues with Ernst & Young LLP, Ernst & Young's U.S. practice, and the Internal Revenue Service. Bob was the initial Director of the Advance Pricing Agreement (APA) program at the Internal Revenue Service. Bob holds a M.A. from Syracuse University and is a certified public accountant.
Anita Beth Adams, Esq.Anita Beth Adams, J.D., Columbia University School of Law; B.A., University of Mississippi; Member, New York State Bar Association.
Private Equity Funds (Portfolio 735) Donald C. AlexanderDonald C. Alexander (deceased), B.A., Yale University (with honors, 1942); LL.B., Harvard University (magna cum laude, 1948). Awarded LL.D., St. Thomas Institute (1975) and Capital University (1989). Served as Commissioner of Internal Revenue (1973-1977); member of the Commission on Federal Paperwork (1975-1977), the Interior Department's Coal Leasing Commission (1983-1984), the Martin Luther King, Jr. Federal Holiday Commission (1992-1997); Chairman of the Internal Revenue Service Exempt Organizations Advisory Group (1987-1989); Harvard Law School Visiting Committee (2000-Present); Harvard Board of Overseers’ Committee on University Resources (2002-Present). Member of the American Bar Association, serving as the Vice Chairman of the Tax Section (1968-1969), the American Law Institute, and a fellow of the American College of Tax Counsel and the American College of Employee Benefits Counsel. Member of the District of Columbia, New York and Ohio Bars.
IRS Procedures: Examinations and Appeals (Portfolio 623) Michele J. Alexander, Esq.Michele J. Alexander, J.D., Georgetown University Law Center (1995); B.A., The College of New Jersey (formerly Trenton State College) (1992); Member, New York State Bar Association, Tax Section; Author, “Tax issues in Business Separation Transactions,” appearing in Business Separation Transactions (Law Journal Press); Counsel, Wachtell, Lipton, Rosen & Katz.
Structuring Real Estate Joint Ventures with Private REITs (Portfolio 743) Galit Allemeier, Esq.
Galit Allemeier, Esq., is a State Tax Law Editor at BNA Tax and Accounting.
Michael AllesMichael G. Alles, Ph.D., Stanford Business School; B.S. (First Class in Honors), The Australian National University. A past member of the Executive Committee of the Management Accounting Section of the American Accounting Association, Dr. Alles has co-chaired its annual research symposium. He is a professor in the Department of Accounting and Information Systems at the Rutgers Business School, and has taught accounting at the University of Texas, Southern Methodist University, and New York University.
Continuous Auditing (Portfolio 5405) Peter J. Allman, Esq.Peter J. Allman, B.A., University of Maryland (1976); J.D., The Washington College of Law, The American University (1980); L.L.M., M.S.A., Georgetown University (1981, 1982); member of the District of Columbia, Connecticut, Massachusetts and New York Bars.
Withholding, Social Security and Unemployment Taxes on Compensation (Portfolio 392) Rakesh Alshi
Rakesh G. Alshi, Senior Manager at Deloitte Haskins & Sells, India is a fellow member of Institute of Chartered Accountants of India and is a member of Deloitte’s Global Transfer Pricing Team. He has served at Deloitte’s Chicago Office and has been involved with Deloitte’s offices in Australia, UK and other US offices. He has authored articles on transfer pricing and international tax published in the Economic Times, Financial Express, Kokusai Zhimo (Japan) and Bureau of National Affairs, Washington D.C USA. He regularly presents research papers at study circles sponsored by the Institute of Chartered Accountants of India, the Institute of Company Secretaries of India, and the Chamber of Commerce and Industry.
Peter R. Altenburger
Peter R. Altenburger, University of Zürich (lic. iur., 1969,); University of Michigan Law School (Master of Comparative Law, 1970); European Institute of Business Administration, Fontainebleau, France (M.B.A., 1971); University of Basle (Dr. iur., 1977); admitted to bar, Zürich (1973), Geneva (1990); member, Swiss and International Bar Association, American Bar Association (International Associate), International Fiscal Association, and Tax Chapter Board of the Swiss-American Chamber of Commerce (Zürich).
John AmatoJohn Amato is State Tax Counsel with General Electric Capital Corporation in Stamford, Connecticut where he is responsible for state income and franchise tax audits, appeals, and litigation. Prior to joining GE Capital, Mr. Amato was a senior tax manager at PricewaterhouseCoopers LLP in San Francisco specializing in state income and franchise tax planning and audit defense. Mr. Amato began his career as Counsel with the Massachusetts Department of Revenue in Boston. Mr. Amato received his B.A. from Middlebury College and his J.D. from Case Western Reserve University Law School. Mr. Amato has spoken for various organizations such as the Tax Executives Institute (TEI), the Interstate Tax Corporation, the Council for International Tax Education, and the Equipment Lessors Association. He has co–authored various articles on state taxation which have appeared in such journals as the Journal of State Taxation, the Journal of California Taxation, and Interstate Tax Insights.
Managing State Tax Audits (Portfolio 1730) James AmdurMr. Amdur has extensive experience in federal, state, and local tax planning and proceedings, emphasizing telecommunications and regulated utilities. He is a graduate of Case Western Reserve University (B.B.A., 1957; J.D., 1960) and Georgetown University (LL. M. in Taxation, 1966). Mr. Amdur has been an Attorney–Advisor to the U.S. Tax Court, has practiced law in Cleveland, Washington, D.C., and San Francisco, and served for many years as in–house tax and corporate counsel for a telecommunications corporation. He is a member of the American Bar Association (Section of Taxation), the State Bar of California, and the District of Columbia Bar.
State Taxation of Transportation, Telecommunications, and Energy Companies (Portfolio 1810) Richard E. Andersen, Esq.
Richard E. Andersen, B.A. magna cum laude, Columbia College 1978; J.D., Columbia Law School, 1981; partner, Patton Boggs LLP; adjunct professor of law, New York University School of Law; member ABA, NYSBA, IFA, IBA; speaker on international tax issues, including NYU Institute on Federal Taxation and GWU/IRS Annual International Tax Institute; author, articles and treatises on international taxation, including Thomson/RIA/WGL, Wolters Kluwer and Practising Law Institute publications.
David Anderson
David Anderson qualified as a solicitor in 1985 and co-founded Sykes Anderson in 1989. He is married with two young children. He heads the tax department which is strong in offshore and non-domiciled tax planning. David is well known nationally for French tax planning for UK individuals and UK property investors and advises on the French tax as well as the UK tax position. He is a legal adviser with the French embassy in London. He also deals with tax planning in Switzerland including Swiss federal and cantonal tax on a bespoke basis for high net worth individuals. David is involved in investments and estate planning well into 8 figures. His articles on French and Swiss taxation are published in numerous magazines and internet sites both in Europe and the United States.
Mario J. Andrade PerillaMario J. Andrade P., Universidad Autonoma de Mexico (LL.M. in Corporate Law; M.Sc. in Public Finance); Pontificia Universidad Javeriana (J.D.); Professor of Law, Pontificia Universidad Javeriana (Bogota); Adjunct Professor, Universidad de Nuestra Senora del Rosario (Bogota); member, Colombia Tax Law Institute; member, American Bar Association; Licensed to practice law in the Republic of Colombia; President of International Fiscal Association (IFA) — Colombian Chapter.
Business Operations Colombia (Portfolio 956) Federico -AndreoliFederico Andreoli was mitted to the Bar in 1993 and joined Maisto e Associati in 1995. In the same year, Mr. Andreoli performed an assignment as research associate with the International Bureau of Fiscal Documentation (IBFD). Mr. Andreoli specializes in international tax planning, cross-border financing, and M&A transactions with Studio Maisto e Muscali.
Transfer Pricing: European Rules and Practice, Part 2 (Portfolio 896) Barbara Angus, Esq.
Barbara M. Angus, Esq. is with Ernst & Young LLP's International Tax Services division in Washington, D.C. and is a frequent contributor to BNA's International Journal.
Edwin AntolinEdwin P. Antolin is a senior associate in the Tax Department in Morrison & Foerster's San Francisco office. Mr. Antolin's practice focuses on the resolution of state and local tax controversies and advising clients on the state and local tax ramifications of various business transactions. He has represented individuals as well as multistate and multinational businesses in state and local tax cases before all levels of administrative review in California and before trial and appellate courts, including the United States Supreme Court. He received his B.A. degree in finance from the University of Washington in 1986, and his J.D. degree from the University of California, Hastings College of the Law, in 1994. While at Hastings, he was elected to the Thurston Honor Society, and he served on the Hastings Constitutional Law Quarterly, and as a Note Editor on the Hastings International and Comparative Law Review.
State Environmental Taxes (Portfolio 1690) Toshio Aritake
Toshio Aritake is a special correspondent for BNA.
Martin Armstrong, CPP, MBAMartin Armstrong, CPP, MBA, is Senior Director of Payroll Shared Services for Time Warner Cable in Charlotte, North Carolina. Martin is a vice president with the American Payroll Association, was named that organization's 2008 Payroll Man of the Year, and is an active speaker, teacher and publication writer for the American Payroll Association. He is also past recipient of the APA's Meritorious Service Award and Special Recognition Award.
Payroll Library Abel Adolfo Atchabahian, Dr.Adolfo Atchabahian, Special Consultant to Tax Management, Doctor in Economic Science, University of Buenos Aires; former Judge of the National Tax Court in Argentina (1960-1967) and Professor of Public Finance and Tax Law at the University of Buenos Aires (1957-1967 and 1980-1983); tax expert and Director at the Office of Public Finance of the Organization of American States (1967-1976); former consultant at the U.N. Center on Transnational Corporations; consultant of the Inter-American Development Bank and the International Monetary Fund; member of the International Fiscal Association and former member of its Permanent Scientific Committee; member and former president of the Argentinean Association of Fiscal Studies; author of several books and many articles published in Argentina and abroad relating to economic, public accounting and tax matters; former chief editor of Derecho Fiscal and Derecho Tributario (1981-1998), monthly tax reviews, and Impuestos Nacionales, a loose-leaf publication updated fortnightly (1984-1998); Director of Periódico Económico Tributario, a fortnightly publication, published in Buenos Aires under the auspices of Editorial La Ley-Thomson (2003- ); and Professor of Tax Law in graduate courses for lawyers and certified public accountants in different public and private universities throughout Argentina.
A Strategic Approach to SEC Investigations (Portfolio 5504)Accounting Ethics: Sources and General Applications (Portfolio 5508)Accounting by Partnerships (Portfolio 5209)Accounting Policy & Practice SeriesBusiness Operations Argentina (Portfolio 950) Ernest F. Aud, Jr. Esq.Ernest F. Aud, Jr., B.B.A., University of Notre Dame (1965); J.D., Indiana University (1968); member, Indiana Bar; Certified Public Accountant (Illinois and Indiana); frequent lecturer and author of articles on international taxation and intercompany pricing, and member, World Trade Institute Tax Advisory Panel.
The Possessions Tax Credit Under Section 936 (Portfolio 933) Reuven S. Avi-YonahReuven S. Avi-Yonah (B.A., Hebrew University, 1983; Ph.D., Harvard University, 1986; J.D., Harvard Law School, 1989) is Assistant Professor of Law, Harvard Law School, where he teaches domestic and international taxation. Mr. Avi–Yonah is a member of the New York and Massachusetts bars and co–chairs the tax policy committee of the New York State Bar Association Tax Section. He participated in preparing the Tax Section's reports on proposed legislation on amortization of intangibles and has published several articles and comments on the leading Supreme Court case in this area, Newark Morning Ledger Co. v. United States, 113 S. Ct. 1670 (1993).
The Attribution Rules (Portfolio 554)Collapsible Corporations (Portfolio 793)Transfer Pricing: Judicial Strategy and Outcomes (Portfolio 888)
B
Noah S. Baer, Esq.Noah S. Baer, B.A., Yeshiva University; J.D., Columbia University; M.L.T., Georgetown University; Executive Director, Ernst & Young, National Tax Department; Domestic and International Tax Counsel, Mobil Corporation; Senior Attorney, Office of Chief Counsel (Passthroughs and Special Industries Division), Internal Revenue Service; Senior Litigation Attorney, Office of Chief Counsel, Department of Energy; Litigation Associate, Tenzer, Greenblatt, Fallon & Kaplan, New York, NY; Member, Maryland and District of Columbia bars; Speaker at various natural resource tax conferences.
Oil and Gas Transactions (Portfolio 605) Brian Ballou, Ph. D.Dr. Brian Ballou, Ph.D., Michigan State University (1996); B.S.B.A., Honors, Accounting, The Ohio State University (1988). Dr. Ballou specializes in business risk-based auditing. He has worked as a senior analyst for LEXIS/NEXIS (1991–92), senior associate for Ernst & Young, LLP (1989–1991), and postgraduate intern at the FASB (1988–89). As a public accountant, licensed in Indiana (not actively practicing), he leads seminars for KPMG interns throughout the United States and has served on the AICPA Risk Assessment Task Force. In addition to coauthoring a book on applying a global Enterprise Risk Management (ERM) approach to auditing, Dr. Ballou has published works on governance, risk management, and reporting (GRMR) in Harvard Business Review, the Journal of Accountancy, Issues in Accounting Education, and Management Accounting Quarterly. He has received GRMR-related grants from the Economic Development Administration, KPMG, and PricewaterhouseCoopers. Dr. Ballou is also a Professor of Accountancy and Co-Director of the Center for Governance, Risk Management, and Reporting at the Farmer School of Business, Miami University of Ohio, and co-instructs the only GRMR course series of its kind in the United States.
Coordinating Risk Management and Performance Measurement (Portfolio 5308) Joshua Bamfo
Joshua Bamfo - Senior Economic Consultant - Transfer Pricing, Ernst & Young, Atlanta.
Russell BaniganMr. Banigan is a national director in the Multistate Tax Services Group of Deloitte & Touche LLP, Tri–State Region (New York, New Jersey, Connecticut). Since 1984, he has devoted his full–time efforts to providing multistate tax consultation services, with an emphasis on the financial services industry, merger and acquisition transactions, and advanced tax strategies. Mr. Banigan has served on the State and Local Tax Committee of the American Institute of Certified Public Accountants, and currently serves on the State and Local Tax Committee of the Wall Street Tax Association. He is also a member of the Advisory Board for the Bureau of National Affairs State Tax Portfolio Series. Mr. Banigan has authored numerous multistate tax articles, such as “What You Need to know About the Expanded Investment Capital Regulations,” “New York's NOL Deduction Further Limits the Federal Rules,” and “The Questionable Constitutionality of the California DRD [Dividends Received Deduction] and Interest Offset Rules.” He has addressed various business and professional organizations, such as the Tax Executive Institute and the New York Business Council, on New York and multistate tax issues. Mr. Banigan received his Bachelor of Science, cum laude, in accounting from St. John's University, New York, and a Master of Science in Taxation from Pace University, New York. Acknowledgements: The author gratefully acknowledges Mr. James W. Wetzler, National Director in Charge of Deloitte & Touche's Multistate Tax Group, Tri–State Region, and formerly Commissioner of the New York State Department of Taxation and Finance, and Mr. John P. Dugan, National Director in Deloitte & Touche's Multistate Tax Group, Tri–State Region, and formerly President of the New York State Tax Appeals Tribunal, for their efforts in reviewing the drafts of this portfolio. In addition, the author gratefully acknowledges the assistance of the members of Deloitte & Touche's Multistate Tax Group with various aspects of this portfolio, particularly Mr. Jay Rosen (Senior Manager), Mr. Abraham Teicher (Senior Manager), and Ms. Eileen Mazo (Senior Tax Consultant).
New York State and City Corporation Income Taxes (Portfolio 2200) Robert T. Barbetti
Robert K Barbetti, B.A., MacMurray College (magna cum laude); M.A., Middlebury College; J.D., St. Louis University Schoolof Law; LL.M., Washington University School of Law; Managing Director, J.P. Morgan; member New York Bar; association of the Bar of the City of New York; ABA; speaker on executive compensation, benefit and wealth transfer issues; publishes and lectures on executive compensation and benefits for ALI-ABA, the Practicing Law Institute, the New York State and City Bar Associations, The Conference Board, the New York State Bankers Association; Yale University's School of Law; New York University's School of Law's Tax Institute, Institute on Wealth Management and LL.M. program; editorial board of the Journal of Compensation and Benefits.
Vara Barnes, Esq.
Vara Barnes is an Editor for BNA Tax & Accounting and contributing editor for the Weekly Report.
Lewis T. Barr, Esq.Lewis T. Barr, B.S., Economics, Wharton School of Finance, University of Pennsylvania (1964); J.D., University of Michigan Law School (1967); member of Ohio Bar; American College of Tax Counsel; American Law Institute; American College of Probate Counsel; contributor to various tax publications and lecturer at various tax institutes.
Net Operating Losses and Other Tax Attributes — Sections 381, 382, 383, 384, and 269 (Portfolio 780) Yuri Barrueco, Esq.
Yuri Barrueco, Esq. is with Deloitte Touche Tohmatsu in Mexico City, Mexico and is a frequent contributor to BNA's International Journal.
George BarryGeorge Barry is with the Chicago office of Deloitte & Touche LLP. Previously, Mr. Berry was a principal with Arthur Andersen & Co. in Chicago and the Manager of the Income Tax Legal Division of the Illinois Department of Revenue. He earned his B.A. degree in Economics in 1970, and received a J.D. degree cum laude in 1973 from Northwestern University.
State Taxation of Banks and Financial Institutions (CA, IL, NY, TN) (Portfolio 1800) Gregory L. Barton, Esq.Gregory L. Barton, University of Notre Dame, B.S. (1980); University of Southern California, M.S. (1981); University of Chicago, J.D. (1985); former attorney–advisor, Office of Management and Budget; law clerk, U.S. Court of Appeals for the Seventh Circuit, Judge Richard A. Posner (1985–86); former lecturer, World Trade Institute and University of Southern California Tax Institute; former panelist, Northwestern University Transfer Pricing Conference; member, American Bar Association, Section of Taxation, Committee on Foreign Activities of U.S. Taxpayers; admitted to practice, Illinois, U.S. District Court for the Northern District of Illinois, U.S. Court of Federal Claims, and U.S. Tax Court.
Transfer Pricing: Records and Information (Portfolio 891) Fred Basehore, Jr., CPPFred A. Basehore, Jr., CPP, is Owner/Principal of F.A. Basehore & Associates, which offers payroll consulting to the general public. Fred, a past American Payroll Association "Payroll Man of the Year," is a charter member of the APA National Speakers Bureau, and teaches many APA courses such as Preparing for Year End. He is a member of APA's Strategic Payroll Leadership Task Force-Best Practices Subcommittee, and serves on the Board of Contributing Writers.
Payroll Library Joel Bassett, Esq.
Joel E. Bassett, Esq. is the Technical Editor for BNA's International Journal and a contributing editor of the Weekly Report.
Kathleen Ford Bay, Esq.
Kathleen Ford Bay, B.A., Rice University 1974; J.D., University of
Texas School of Law at Austin, with high honors, 1979; Partner, Potts &
Reilly, L.L.P., Austin, Texas; member Texas and New York Bars; Board Certified
in Estate Planning & Probate by Texas Board of Legal Specialization; member
American College of Trust and Estate Counsel; speaker on estate and gift tax
issues and on non-tax issues related to estate and disability planning,
gifting, guardianships, trusts, and durable powers of attorney, including the
Journal for BNA's Estate Planning, Probate & Trusts L. J.
Michael F. Beausang, Jr. Esq.Michael F. Beausang, Jr., B.S., University of Pennsylvania (1958); LL.B., Georgetown University Law School (1964); LL. M. (Taxation), New York University Graduate School of Law (1967); member, American, Pennsylvania, and Philadelphia Bar Associations; partner, Butera, Beausang, Cohen & Brennan, PC, King of Prussia, Pennsylvania; contributor, Dickenson Law Review, Criminal Law Bulletin, Journal of Taxation, TAXES, The Practical Lawyer, The Journal of the Patent Office Society, and Trusts & Estates; co-author 228-2nd T.M., Patent Transfers — Section 1235; author, 326-2nd T.M., Administrative Powers, and 131-3rd T.M., Jointly Owned Property.
Valuation: General and Real Estate (Portfolio 830) Alice BeckAlice W. Beck is with the Philadelphia office of Wolf, Block, Schorr and Solis–Cohen LLP in the tax department and concentrates her practice in state and local tax law. Before joining the firm, Ms. Beck served as Divisional Deputy Solicitor to the City of Philadelphia where she managed the Tax Division of the City Solicitor's office. Earlier, she clerked for the Honorable Edward G. Biester, Jr. Ms. Beck attended the University of Pennsylvania and graduated cum laude in 1981. She received her law degree in 1984 from the University of Pennsylvania Law School. She is a member of the bar in Pennsylvania and New Jersey. She is also Co–Chair of the Real Property Subcommittee on Taxes Affecting Real Estate of the Philadelphia Bar Association. She is a Fellow of the Academy of Trial Advocacy of Temple University School of Law.
Pennsylvania Corporate Taxes (Portfolio 2300) Edward J. Beckwith, Esq.Edward Jay Beckwith, partner, Baker & Hostetler, LLP; B.S., Pennsylvania State University (1971); J.D., Georgetown University Law Center (1974); M.L.T., Georgetown University Law Center (1983); Adjunct Professor of Law, Georgetown University Law Center; member, Bar of the District of Columbia (1975); member, American Bar Association (Sections on Taxation and Real Property, Probate and Trust Law); member, American Law Institute; fellow, American College of Trusts and Estates Counsel; Founder and Chair, Advanced Estate Planning Institute, Georgetown University Law Center (1988-Present); member Estate Planning Council, Washington, D.C.; Who's Who in America.
Estate and Gift Tax Charitable Deductions (Portfolio 839)Estate Tax Deductions — Sections 2053 and 2054 (Portfolio 840) Frank BeilFrank J. Beil, CPA, MS (Accounting), University of North Dakota, consults for the FASB in the areas of Revenue Recognition for Products, Services, Multiple Element Transactions, Contractor Accounting, and Accounting for Software Transactions. He is a Senior Lecturer in Accounting and Adjunct Professor of Management at the Carlson School of Management, University of Minnesota. Mr. Beil conducts seminars on Revenue Recognition, Accounting for Pensions, Accounting for Leases, and FASB Update and consults for public and private companies on applying accounting standards.
Revenue Recognition: Fundamental Principles (Portfolio 5100)Revenue Recognition: Product Sales and Service (Portfolio 5101) Dennis I. Belcher, Esq.
Dennis I. Belcher, B. A. from College of William and Mary-1973; J. D., University of Richmond, 1976; Partner in Richmond, Virginia and Tysons Corner, Virginia offices of McGuireWoods LLP; past Chair of the American Bar Association’s Section of Real Property, Estate and Trust Law; President of the American College of Trust and Estate Counsel; member of the Advisory Board of BNA Tax Management, Estate, Gifts and Trusts Magazine; listed in Town & Country Magazine top 45 estate planning lawyers in the United States; named one of America’s “Leading Lawyers” Chambers USA, 2008, 2009; named one of “Best Lawyers in America,” 1987-2009; named Virginia Super Lawyer, Law & Politics, 2007-2009; numerous publications written and seminars taught including Member of the Advisory Committee and frequent speaker at the Heckerling Institute of Estate Planning sponsored by the University of Miami School of Law and ALI-ABA estate planning seminars.
Kevin Bell
Kevin A. Bell is a Staff Writer/Editor at BNA Tax and Accountings Transfer Pricing Report.
Herbert N. Beller, Esq.
Herbert N. Beller practices in Washington with Sutherland Asbill & Brennan LLP, focusing on tax planning and controversy matters for corporations, other business entities and tax-exempt organizations. He is a Senior Lecturer at Northwestern University School of Law, a member of the IRS Advisory Council and a former Chair of the ABA Section of Taxation.
Janet Benedetti, Content Development Specialist
Jan Benedetti received a Bachelor of General Studies degree from the University of Michigan and a J.D. from Washington and Lee University. She practiced law as a legal aid attorney representing indigent clients in civil matters before joining BNA in 1988. She has worked on a variety of publications at BNA as a reporter and editor.
Carrie Benedict
Carrie Benedict, CPA, Master of Accountancy, Case Western Reserve University (2002); B.S. (Accounting and English), Heidelberg College (2001). Candidate for J.D., Ohio State University (May 2010); former assurance manager, Grant Thornton LLP.
Ralph BenkeDr. Ralph L. Benke, Jr., CMA, Ph.D., Florida State University; M.B.A., University of Washington; B.S., Washington State University; Arthur Anderson/Journal of Accounting Education Professor (1988-1997); Professor Emeritus (1997-Present); Director, School of Accounting (1984-1986, 1994); Director, Center for Professional Development (1991-1993); Director, Accounting Information Systems Concentration (1988-1993). Dr. Benke has won numerous teaching awards. His teaching experiences include University of Idaho (1972-1974); Florida State University (1974-1977); University of Georgia (1977-1981); James Madison University (1982-1997). He has served as Founder and Editor of the Journal of Accounting Education (1982-1987) and as Founder and Director of the Center for Research of Accounting Education (1981-1984, 1986-1993).Dr. Benke's publications include: Transfer Pricing: Techniques and Uses (National Association of Accountants: New York, 1980); College Edition of DacEasy Payroll (1995); College Edition of DacEasy 4.3 (1994); The Financial Accounting Cycle (1992); College Edition of DacEasy 3.1 (1991); Faculty Performance Appraisals (1990); Dimensions of Faculty Research (1990); Research in Testing (1990); Research in Accounting Education (1986); Essays on Accounting Education (1986); The Financial Accounting Cycle (1985). He has contributed articles to numerous accounting and financial periodicals including: Accounting, Organizations, and Society; Review of Accounting Information Systems; Journal of Accounting Education; Management Accounting (Lybrand Silver Medal, 1982; Lybrand Gold Medal, 1996); Changes in Accounting Education; Accounting Education; Computers in Accounting; Management Accounting Newsletter; Kent/Bentley Review of Accounting and Computers; Journal of Applied Business Research; Mary Ball Washington Forum Series in Accounting Education (West Florida University); Journal of Cost Analysis; New Accountant; Virginia Accountant; Advances in Accounting; Cost and Management; CPCU Journal; The Accountant's Magazine (Scotland); The Michigan CPA; Managerial Planning; Best's Review; National Public Accountant.
Business Combinations: Goodwill and Other Intangible Assets (Portfolio 5115)Accounting Changes and Error Corrections (Portfolio 5124)The Financial Reporting of Inventories (Portfolio 5168) Beth M. Benko, CPA Esq.Beth M. Benko, B.S.B.A., cum laude, Bowling Green State University (1990); J.D., Marshall-Wythe School of Law of the College of William and Mary in Virginia (1998); member, the Virginia State Bar and the District of Columbia Bar; member, the American Bar Association — Chair, Section of Taxation Tax Accounting Committee Subcommittee on Current Developments; adjunct professor, Georgetown University School of Law; certified public accountant, State of Ohio.
Section 199: Deduction Relating to Income Attributable to Domestic Production Activities (Portfolio 510) Alison Bennett
Alison Bennett has been with BNA more than 17 years, 15 of them on the Daily Tax Report staff covering tax regulations and tax policy. She has a Bachelor of Arts in journalism from the College of Journalism at the University of Maryland, College Park, and a Master of Arts in legislative affairs from the Graduate School of Political Management at the George Washington University, Washington, D.C. Her areas of specialization are international taxes, tax treaties, tax shelters, corporate taxes, and financial products.
David M. Benson, Esq.David M. Benson, B.B.A., George Washington University (1971); J.D., Brooklyn Law School (1974); member, District of Columbia Bar; former Chair, AICPA International Tax Committee; formerly Technical Advisor to Associate Chief Counsel (Technical), Internal Revenue Service, Washington, D.C.; regular contributor to Tax Management International Journal.
The Possessions Tax Credit Under Section 936 (Portfolio 933) Martha BensonMartha L. Benson, CPA, has 20 years of experience as an auditor, administrator, author, professor, and conference speaker in the not-for-profit industry. She has worked as an Audit Manager with Arthur Andersen, Chief Financial Officer of the Dallas Museum of Art, and Chief Financial Officer of the Fort Worth Museum of Science and History. She is a member of the Texas Society of Certified Public Accountants and the American Institute of Certified Public Accountants and has served on the latter's Not-for-Profit Organizations Committee. Her publications include articles in the Journal of Accountancy and three books on accounting for nonprofit organizations. A certified public accountant, licensed in Texas, Ms. Benson teaches at Franklin & Marshall College and the Fels Institute of the University of Pennsylvania.
Accounting for Museums (Portfolio 5201) Renato Berger, Esq.Renato Berger, consultant, TozziniFreire, Teixeira e Silva Advogados, São Paulo, Brazil; University of São Paulo School of Law (LL.B., 1995); Georgetown University Law Center (LL.M., 1997).
Business Operations Brazil (Portfolio 954) Jonathan Bernsen
Jonathan Bernsen is a partner at DeLoitte in Copenhagen.
Turney P. Berry, Esq.Turney P. Berry, partner, Wyatt, Tarrant & Combs, LLP; B.A. (with honors, 1983) and B.L.S. (with university honors, 1983), Memphis State University; J.D., Vanderbilt University (1986); Adjunct Law Professor, Vanderbilt University (2004 to present); Fellow, American College of Trust and Estate Counsel (Estate and Gift, Charitable Planning and Exempt Organizations and Program committees); Delegate, National Conference of Commissioners on Uniform State Laws (NCCUSL); member, Legal Advisory Subcommittee of the Council on Foundations; listed in the publication The Best Lawyers in America; frequent writer and speaker on the local, state, and national levels.
Private Foundations — Self-Dealing Section 4941 (Portfolio 879)Private Foundations — Taxable Expenditures (Sec. 4945) (Portfolio 474)Private Foundations — Self-Dealing Section 4941 (Portfolio 879)Estate Tax Deductions — Sections 2053 and 2054 (Portfolio 840) Luis BetancourtLuis Betancourt, CPA, Ph.D., Accounting, University of Central Florida; MBA, Finance, University of Maryland; BS, Accounting, Salisbury State University. Betancourt is an Assistant Professor of Accounting at James Madison University. He worked in accounting policy at the Office of the Comptroller of the Currency and Freddie Mac. Betancourt has extensive teaching and training experience and has written for many publications, including Journal of Accountancy, and Advances in Taxation.
Mortgage Banking Activities and Mortgage-Backed Securities (Portfolio 5208) J. Elaine BialczakMs. Bialczak is Director for Compton & Associates, LLP, a leading nationwide provider of quality state and local tax services. Prior to joining Compton & Associates, she was General Counsel for DuCharme, McMillen & Associates, Inc., a state and local tax consulting firm. Before joining DuCharme, McMillen, Ms. Bialczak worked as a state and local tax litigator for AT&T, and as State and Local Tax Counsel for The Coca–Cola Company. Ms. Bialczak also served as Assistant Attorney General for the state of Ohio, representing the Ohio Department of Taxation before numerous courts. For many years Ms. Bialczak has lectured at the Tax Executives Institute Education Fund's State and Local Property Tax Course. She has presented papers at both New York University's Annual Institute on State and Local Taxation and at the Institute on State and Local Taxation sponsored by the Georgetown University Law Center Continuing Education Division. Ms. Bialczak has also published articles in the Journal of State Taxation and in the Ohio Tax Review. Ms. Bialczak graduated with honors from the Ohio State University College of Law and is admitted to practice before the United States Supreme Court, the Ohio state courts, and the United States Tax Court.
Sales and Use Taxes: Information Services (Portfolio 1320) Philip J. BieluchPhilip J. Bieluch, founder of Bieluch & Associates, has extensive experience in life insurance product development. Phil is a leading expert on class action litigation involving life insurance products. Further, he regularly advises clients with respect to the taxation of insurance products and has spoken on the topic at numerous legal and actuarial meetings. Having graduated Trinity College of Hartford (B.S. 1976), he went on to become a Fellow of the Society of Actuaries in 1981. He is also a Member of the American Academy of Actuaries, a Fellow of the Conference of Consulting Actuaries, a Chartered Life Underwriter, and a Chartered Financial Consultant.
Annuities, Life Insurance, and Long-Term Care Insurance Products (Portfolio 546) Thomas St. G. Bissell, Esq.Thomas St.G. Bissell, B.A., Harvard College (1964); LL.B., Columbia Law School (1967); LL.M. in Taxation, New York University (1971); Member, New York Bar; Certified Public Accountant, State of New Jersey; Member, Tax Management International Advisory Board, American Bar Association, American Institute of Certified Public Accountants, International Fiscal Association, Canadian Tax Foundation; former Attorney-Advisor, Office of International Tax Counsel, US Treasury Department, Washington, D.C.; retired tax partner, Coopers & Lybrand LLP; author of numerous articles in professional tax publications.
U.S. Income Taxation of Nonresident Alien Individuals (Portfolio 907)International Aspects of U.S. Withholding on Wages and Service Fees (Portfolio 916)International Aspects of U.S. Social Security and Unemployment Taxes (Portfolio 917)Aliens Who Invest the United States Through a Low-Tax Jurisdiction (Portfolio 944)Controlled Foreign Corporations — Section 956 (Portfolio 929) Ervin BlackErvin L. Black, Ph.D., is the PricewaterhouseCoopers Fellow at Brigham Young University. He received his Ph.D. from the University of Washington and has held faculty positions at Brigham Young University, University of Arkansas, and University of Wyoming. Prior to his academic career, Professor Black received his MBA from Brigham Young University and worked for seven years in private industry as a financial and quality analyst, a corporate treasurer for a start-up company, and a stockbroker. His research is primarily in financial and international accounting, with emphasis on examining the usefulness of firm financial characteristics in different settings. Professor Black teaches undergraduate and graduate courses in international accounting, financial statement analysis, financial accounting, and professional research methods.
Business Combinations (Portfolio 5170) Jeanne C. Blackmore, Esq.Jeanne C. Blackmore, B.A. (liberal arts), St. John's College (1989); J.D., University of San Diego School of Law (1993); LL.M. in Taxation, New York University, (1994); member, California Bar Association (1994); KPMG, Mergers and Acquisitions Group, (1994-1997); Ernst & Young, EY National Office of the West, Mergers and Acquisitions Group (1997-1999); Mergers & Acquisitions Responder and Reviewer, Ernst & Young's Online Tax Advisor (1999-2004); Mergers & Acquisitions Segment Leader, Ernst & Young's Online Tax Advisor (2004-Present).
Corporate Overview (Portfolio 750) Kimberly Blanchard, Esq.
Kimberly S. Blanchard, Esq. is with Weil, Gotshal & Manges, LLP in New York, NY and is a frequent contributor to BNA's International Journal.
Mimi Blanco-BestMimi Blanco-Best, CPA, University of Alabama (1978), former practitioner with over ten years' experience with national, regional, and local CPA firms specializing primarily in audits of small to medium sized privately-held businesses; former technical editor in Auditing Standards, American Institute of Certified Public Accountants, who worked on SAS 58, Reports on Audited Financial Statements, SAS 62, Special Reports, and SSAE No. 2, Reporting on Internal Control Over Financial Reporting; consulting author to a publisher of how-to guidance for CPAs; and consultant to the Public Company Accounting Oversight Board who worked on PCAOB Auditing Standard No. 2, An Audit of Internal Control Over Financial Reporting Performed in Conjunction With an Audit of Financial Statements; author of numerous articles in the Journal of Accountancy.
Auditors' Reports (Portfolio 5400) Jonathan G. Blattmachr, Esq.Jonathan G. Blattmachr, partner, Milbank, Tweed, Hadley & McCloy LLP, New York, New York; former chairperson, Trusts & Estates Law Section, New York State Bar Association; member, various committees of the New York State Bar Association and the American Bar Association; member, Alaska Bar, California Bar, and New York Bar. Mr. Blattmachr has served as a lecturer-in-law at the Columbia University School of Law and an Adjunct Professor of Law at New York University Law School. He is a Fellow and former Regent of the American College of Trust and Estate Counsel and past chair of its Estate and Gift Tax Committee. He is the author or co-author of over 250 articles and three books on estate planning topics; former editor of The Chase Review (published by the Chase Manhattan Bank (N.A.)); and a former editor of Probate Notes (published by the American College of Trust and Estate Counsel). He is also co-developer and co-author of Wealth Transfer Plannings, a computerized estate planning software system offering expert advice and document assembly.
Partial Interests — GRATs, GRUTs, QPRTs Section 2702 (Portfolio 836) Marc P. Blum, Esq.Marc P. Blum, A.B., Yale 1964; L.L.B., Columbia Law, 1967; Ph. D., Columbia Business 1969; member Maryland Bar, ABA; CPA; Of Counsel, Gordon, Feinblatt, Rothman, Hoffberger & Hollander, LLC, Baltimore, Maryland; CEO, World Total Return Fund, LLLP; Committee/Board member, Davis Funds, Clinical Trials & Surveys Corp., Rodney Trust Company, Legg Mason Investment Counsel & Trust Co., The Associated: Jewish Community Federation of Baltimore, McDonogh School, Kennedy Krieger Institute, Latin American Studies Association, College of Notre Dame of Maryland, Commonfund Private Capital, LifeBridge Health, Baltimore Courthouse and Law Museum Foundation, Inc., Maryland Research Institute; several private foundations and private capital funds; author of various articles on tax issues and estate planning.
Reporting Requirements Under the Code for International Transactions (Portfolio 947) Matthew Blum, Esq.
Matthew S. Blum, Harvard College, A.B. in mathematics. Member of Ernst & Young LLP's International Capital Markets group. Mr. Blum has written and lectured widely on international tax issues. His publications include “New Tendencies in Tax Treatment of Cross-Border Interest of Corporations in the United States,” 93b Cahiers de droit fiscal international 749 (2008), and “Reporting Requirements Under the Code for International Transactions,” 947 T.M. (2009) (with Canale, Hester and O’Connor).
Bertold BodenheimerBertold Bodenheimer, CPA, B.S., University of Maryland, practices accounting with Caldwell & Bodenheimer, LLC, providing consulting services to government contractors and government agencies on cost accounting issues. Mr. Bodenheimer frequently serves as an expert witness in contract cost litigation. Mr. Bodenheimer served for many years at the Defense Contract Audit Agency, both in the field and at headquarters. He also has served as Chairman of the Armed Services Procurement Regulation (now FAR) Cost Principles Subcommittee and on the staff of the first Cost Accounting Standards Board (CASB).
Cost Accounting Principles for Federal Contracts (Portfolio 5300) Thierry Boitelle
Thierry Boitelle, a partner in Altenburger’s tax practice, specialises in national and international tax, finance, intellectual property and mergers & acquisitions. Additionally, Thierry is a member of the International Fiscal Association (IFA), the American Bar Association (ABA), Dutch Association of Tax Advisers (NOB), Dutch Association of Tax Science and the Dutch Group of Liberal International (LIGN). Thierry received a master’s degree in tax law from Leyden University in 1997 and a bachelor’s degree in Dutch civil law in 1991. He is fluent in Dutch, English, French and German.
Michael Bologna
Michael Bologna is a BNA staff correspondent for the Weekly Report.
Bradley T. Borden, Esq.Bradley T. Borden, B.B.A., M.B.A., Idaho State University; J.D. (Order of the Coif), LL.M. (Taxation), University of Florida Levin College of Law; Associate Professor of Law, Washburn University School of Law (courses include Taxation of Individual Income; Taxation of Partnerships and Partners; Taxation of Property Transactions; Taxation of Corporations and Shareholders; Tax Policy Seminar); Of Counsel, Oppenheimer, Blend, Harrison & Tate, Inc., San Antonio, Texas; admitted to practice, Texas, U.S. Tax Court; Certified Public Accountant; member, American Bar Association Section of Taxation (John S. Nolan Tax Law Fellow; Vice Chair, Sales, Exchanges & Basis Committee); member, Executive Committee, Kansas Bar Association Tax Law Section; author, books on §1031 (Tax-Free Like-Kind Exchanges (Civic Research Institute, 2008); Tax-Free Swaps: Using Section 1031 Like-Kind Exchanges to Preserve Investment Net Worth (DNA Press, 2007)); author, various articles in leading tax journals (including Journal of Taxation; Real Estate Taxation; Tax Management Memorandum; Tax Management Real Estate Journal; Tax Notes; Taxes: The Tax Magazine) and several law reviews (including Florida Law Review; Houston Law Review; Kansas Law Review; South Carolina Law Review; Virginia Tax Review); frequent speaker, tax law topics.
Real Estate Transactions by Tax-Exempt Entities (Portfolio 480)Real Estate Transactions by Tax-Exempt Entities (Portfolio 591) Charles BorekCharles A. Borek, J.D., University of Baltimore (summa cum laude); M.B.A., University of Baltimore (summa cum laude); B.A., Mary Washington College. Mr. Borek is Executive Vice President for Tax Services and principal of Cohen, Rutherford + Knight, P.C., a Bethesda, Maryland accounting and consulting firm. Mr. Borek also practices law with the Law Offices of O'Connor & Borek, LLC. A member of the American Bar Association, American Institute of Certified Public Accountants, Healthcare Financial Management Association, and American College of Healthcare Executives, Mr. Borek has lectured frequently for the American Bar Association, Maryland Institute for Continuing Professional Education of Lawyers, and American Health Lawyers Association. A certified public accountant, licensed in Maryland, Mr. Borek is admitted to the bars of the U.S. Supreme Court, U.S. Court of Appeals for the Fourth Circuit, U.S. District Court for the District of Maryland, U.S. Court of Federal Claims, U.S. Tax Court, and Court of Appeals of Maryland. He teaches at the University of Baltimore School of Law where as a student he had served as Editor-In-Chief of the University of Baltimore Law Review.
Hospital Accounting (Portfolio 5204) Ronald S. Borod, Esq.Ronald S. Borod, B.A., Princeton University (1963) (Magna Cum Laude, Phi Beta Kappa); J.D., Harvard Law School (1966); LL.M. (Taxation), New York University (1967); admitted to bar, Massachusetts and Tennessee; member, Tax and Urban Law, Sections, American Bar Association; member, Massachusetts Bar Association, Boston Bar Association, Tennessee Bar Association, Memphis Bar Association; member, National Association of Bond Lawyers; contributor of articles to New York University and Memphis State University Law Reviews; contributed chapters on “At Risk Limitation on Losses” and “Rehabilitation Expenditures for Historic Structures” in Federal Tax Deductions (Warren, Gorham & Lamont 1983); contributor of articles to Tax Management Real Estate Journal; contributed chapter on “Syndicating REO and Troubled Loan Assets From the Lender's and Buyer's Perspective” to The Workout Game — Managing Nonperforming Real Estate Assets (Executive Enterprises and Land Development Institute 1987); editor of Securitization: Asset–Backed and Mortgage–Backed Securities (Michie 1991, Revised 1994 and 1995); Adjunct Professor of Law, Boston University School of Law; member, Tax Management Advisory Board on U.S. Income.
Rehabilitation Tax Credit and Low-Income Housing Tax Credit (Portfolio 584) Jason K. Bortz
Jason K. Bortz, Hamilton College, B.A., Cornell Law School, J.D.; member of the Order of the Coif, Editor, Cornell Law Review; Previously a partner at Caplin and Drysdale, Washington, DC, a law clerk for Judge Loken, US Court of Appeals, Eighth Circuit; member of District of Columbia Bar, New York Bar and American Bar Association. Contributor to several books—including the 403(b) Answer, Book, 6th Ed. Supp. (Aspen Publishers), Annuities Answer Book, 4th Ed. (Aspen Publishers), and Complete Guide to Nonprofit Organizations, 1st Ed. (Civic Research Institute). He has also published articles on benefits matters in The Journal of Financial Service Professionals, The Journal of Investment Consulting, and other periodicals. He is widely quoted in the benefits trade press. Currently an advisor for Davis & Harman on tax, ERISA, and other aspects of tax-favored retirement plans and executive compensation arrangements. Mr. Bortz focuses primarily on traditional and hybrid defined benefit plans, 401(k) plans, 403(b) programs, 457 plans, IRAs, executive compensation arrangements and retiree health benefits.
Slawomir BorucSlawomir Boruc graduated from the Department of Law and Administration at the University of Warsaw in 1992. He has been working for Baker & McKenzie since July 1992, specializing in resolving tax law problems. He has advised many firms, including firms in the IT, chemicals, and printing and textile industries, and one of the largest telecommunications companies in the world. He has represented clients before tax authorities and in tax cases before the Supreme Administrative Court. He is a member of the Warsaw District Chamber of Legal Advisors and of the National Chamber of Tax Advisors. According to Practical Law Company (PLC 2005, 2006 and 2007), Slawomir Boruc is a recommended Tax Advisor. Chambers Global 2006 and 2007 refers to him as a co-head of the best tax group in Poland. Additionally, Legal 500 has listed him individually each year since 2003. According to European Legal Experts 2007, Slawomir Boruc is a leading tax advisor in Poland. In Practical Law Company 2007/2008, he was recognized as the best lawyer in tax law in Poland. He was also awarded by International Financial Law Review (IFLR1000) 2007/8 in tax advisory.
Business Operations Poland (Portfolio 979) Janine H. Bosley, Esq.Janine H. Bosley, University of Miami (B.S.B.A. 1981, M.P.A. 1982, J.D. 1986); formerly, Senior Attorney, Office of Associate Chief Counsel (Employee Benefits and Exempt Organizations), Internal Revenue Service; Member of the Virginia, United States Tax Court, and United States Supreme Court Bars; Liaison Member of the IRS Employee Benefits Conference Committee, Southeast Region; Vice Chair of the American Bar Association, Tort and Insurance Practice Section, Committee on Employee Benefits; and Member of the American Bar Association Section of Taxation, Committee on Employee Benefits.
Employee Benefits for Small and Mid-Sized Employers (Portfolio 353)Qualified Plans — Taxation of Distributions (Portfolio 370) Herman Bouma, Esq.
Herman B. Bouma, Esq. is with Buchanan Ingersoll & Rooney PC in Washington, D.C. and is a frequent contributor to BNA's International Journal.
Stephen Bouvier
Stephen Bouvier is the London Staff Corresondent at BNA Tax and Accounting's Accounting Policy & Practice Report.
Nancy Bowen
Nancy Bowen joined Fulbright & Jaworski L.L.P.'s Houston office in 1990 and concentrates her practice on all phases of federal tax controversy. She has significant experience in assisting taxpayers in planning and preparing for audits, handling audits (including responding to IRS information document requests and defending formal and informal taxpayer interviews); preparing protests and position papers for use with the IRS Appeals Office; negotiating with the IRS Appeals Office; documenting settlements; and litigating tax controversies, when necessary. She has handled a wide variety of substantive tax matters, including both domestic and international income tax matters, employment tax matters, excise tax matters, and estate and gift tax matters. She has litigated before the U.S. Tax Court, U.S. district courts, the Court of Federal Claims, and appellate courts.
Jane Bowling
Jane Bowling has been a copy editor for the Daily Tax Report since 1998. She previously worked as a legal affairs reporter and editor for the Daily Record in Baltimore, Md., and as an estates and trusts attorney. She holds bachelor's degrees in journalism and mathematics from Morehead State University in Morehead, Ky., and a J.D. from the University of Kentucky College of Law in Lexington. She is licensed to practice law in Maryland.
Kim Marie BoylanKim Marie Boylan, B.S., Georgetown University (1981); J.D., Syracuse University College of Law (cum laude 1986); LL.M., Taxation, Georgetown University Law Center (with honors 1993); member, District of Columbia, Massachusetts and Pennsylvania Bars; Admitted U.S. Tax Court, U.S. Court of Federal Claims, Various U.S. Courts of Appeals; ABA Section of Taxation; Certified Public Accountant; clerk for the Hon. Robert J. Yock, U.S. Court of Federal Claims (1986-1987). Frequent lecturer on tax and accounting policy issues.
The Section 7525 Tax Practitioner-Taxpayer Privilege and Related Issues (Portfolio 5511) Kathryn A. Bradley, Esq.Kathryn A. Bradley, B.A., Arizona State University (summa cum laude, 1995); J.D., Arizona State University (cum laude, 1999); Member: State Bar of Arizona (Chair of Probate and Trust Section, 2005), State Bar of Nevada, Maricopa County Bar Association, and Clark County Bar Association.
Charitable Remainder Trusts and Pooled Income Funds (Portfolio 865) Christian Brause, Esq.Christian Brause, First and Second State Examinations in Rhineland-Palantinate, Germany; doctorate in law (Dr. jur.), Johannes Gutenberg University at Mainz; LL.M. (Int. Taxation), New York University School of Law; former Member of the Bar of Frankfurt a. M., Germany; Member of the Tax Section of the New York Bar Association.
Hedge Funds (Portfolio 736) Samuel BraverSamuel W. Braver is a shareholder with Buchanan Ingersoll PC, representing clients in commercial litigation. Mr. Braver has been elected to the Judiciary Committee of the Allegheny Bar Association and is a member of the Academy of Trial Lawyers of Allegheny County. He has served as a faculty member for the National Institute of Trial Advocacy training programs and lectures for the Pennsylvania Bar Institute. Mr. Braver has developed and participated in Alternative Dispute Resolution Procedures and has served as an arbitrator for the American Arbitration Association and for federal and state court arbitration proceedings. Mr. Braver received a B.A. from the University of Pittsburgh and a J.D. from Duquesne University.
Preparing for and Defending Accounting Liability Litigation (Portfolio 5500) Katherine Breaks
Katherine Breaks, Senior Manager, Federal Tax Legislative and Regulatory Services, Washington National Tax Practice.
Wayne Bremser
Wayne G. Bremser, Ph.D., University of Pennsylvania Wharton School. Professor of Accountancy and Information Systems, Villanova University School of Business; Chairperson of Department of Accountancy, Villanova University School of Business (2004-2007). Published work has appeared in R&D Management, The Accounting Review, the Journal of Accountancy, Electronic Commerce Research and Applications, and other journals. Dr. Bremser has also authored numerous books on budgeting and control. Accolades include the Critical Incidents Award and the Distinguished Faculty Research Award, both from Villanova. Dr. Bremser serves on a variety of committees and boards, including the American Accounting Association. Research and consulting interests include performance measurement, innovation, and international accounting implementation issues.
Jed Brickner, Esq.
Jed W. Brickner, Esq. is a Partner and head of the Employee Benefits and Executive Compensation Group (the “Benefits Group”) of the New York Office of Latham & Watkins LLP (“L & W”).
Luis F. Briones, Esq.Luis Briones Fernández, born Madrid, Spain, 1954; admitted to Madrid Bar; education: Deusto University, Bilbao, Spain (Law Degree, 1976); ICADE, Madrid, Spain (MBA, 1978); Harvard University, USA (LL.M. and International Tax Program, 1986).
Business Operations Spain (Portfolio 984) James Bristol
Waller Lansden Dortch & Davis LLP, Nashville
Lawrence Brody, Esq. Lawrence Brody, partner, Bryan Cave LLP; B.S., University of Pennsylvania (Wharton) (1964); J.D., Washington University School of Law (1967); LL.M. in Taxation, New York University School of Law (1968); Partner, Bryan Cave LLP, an international law firm, resident in the St. Louis office, and member of its Private Client Service Group and its Technology, Entrepreneurial & Commercial Practice Client Service Group; adjunct professor, Washington University School of Law, teaching Estate Planning and Drafting; visiting adjunct professor, the University of Miami Law School, teaching a course on Life Insurance; author or co-author, numerous articles and books on the use of life insurance in estate and employee benefit planning, including two BNA Tax Management Portfolios, two books for the National Underwriter Company, and a number of volumes in the ABA Insurance Counselor Series; fellow, American College of Trust and Estate Counsel (ACTEC) and American College of Tax Counsel; frequent participant, ALI-ABA programs and Society of Financial Professionals programs and teleconferences; speaker, all major life insurance industry programs (including the MDRT, the Top of the Table, AALU and the International Forum), many local estate planning council meetings, a number of state bar association conferences, and many national estate planning programs; member, Advisory Committee for the Philip E. Heckerling Institute on Estate Planning of the University of Miami School of Law; member, Editorial Boards of BNA Tax Management's Estates, Gifts, and Trusts Journal, and the Society of Financial Service Professionals CLU Journal; designated, Accredited Estate Planner by the National Association of Estate Planners and Councils, and one of 10 individuals awarded its Distinguished Accredited Estate Planner designation in the initial class, in 2004.
Compensating Employees with Insurance (Portfolio 386)Section 2035 Transfers (Portfolio 818)Compensating Employees with Insurance (Portfolio 828) Darwin C. Broenen
Darwin C. Broenen, B.S., Marquette University, 1954; M.B.A., University of Chicago, 1957; C.P.A. (District of Columbia, Florida and Wisconsin); frequent lecturer and author of articles on international taxation issues.
Gregory K. Brown, Esq.Gregory K. Brown, University of Kentucky (B.S. 1973), University of Illinois (J.D. 1975); member, Illinois Bar. Past Chairman, member, Legislative and Regulatory Advisory Committee, The ESOP Association. Past Member, Board of Directors, The ESOP Association. Past Chairman, Chicago Bar Association, Employee Benefits Committee. Member, ABA Tax Section, Employee Benefits Committee.
ESOPs (Portfolio 354) Karen B. BrownKaren B. Brown, B.A., Princeton University; J.D., LL.M., New York University, the Donald Phillip Rothschild Research Professor of Law at the George Washington University School of Law, where she teaches courses in Federal Income Taxation, Corporate Taxation, and International Taxation. Before joining the faculty at George Washington University, Professor Brown was Professor of Law and Associate Dean for Academic Affairs at the University of Minnesota Law School and Professor of Law at Brooklyn Law School. She has published numerous articles concerning corporate and international taxation. Professor Brown is co-author of an international tax transactions treatise and co-editor of a book on taxation reform. She is a member of the International Fiscal Association.
The Attribution Rules (Portfolio 554)Innocent Spouse Relief (Portfolio 645) Kenneth BrownMr. Brown is a tax partner with Ernst & Young, where he is the West Region Director of State and Local Tax Services and a member of the National State Tax Committee. He is a member of the California Society of CPA's Tax Committee and the Tax Committee of the California Chamber of Commerce; on the Board of Directors of Cal–Tax; and a Director of the Advisory Boards of both the San Jose State University Masters of Tax program and the University of Southern California's School of Public Administration. He is the author of a quarterly column on state taxation published by the California Society of CPA's. He received his B.S. and M.B.A. (Taxation), with honors, from the University of Southern California.
Income Taxes: Consolidated Returns and Combined Reporting (Portfolio 1130) Charles M. Bruce, Esq.Charles M. Bruce, B.A., Washington & Lee University; J.D., George Washington University Law Center; member, The District of Columbia Bar, American Bar Association (Section of Taxation, Committee on Foreign Activities of U.S. Taxpayers), International Fiscal Association, International Bar Association (Section of Business Law, Taxation Committee); formerly, Counsel, Senate Finance Committee, Attorney–Advisor, United States Tax Court, Adjunct Professor, Georgetown University Law Center, and Visiting Professor, Institut für Auslandishes und Internationales Finanz und Steuerwesen.
Foreign Sales Corporations (Portfolio 934) Stefan Brunsbach
Dr. Stefan Brunsbach is with PricewaterhouseCoopers LLP in New York, NY and is a frequent contributor to BNA's International Journal.
Charlene BuddCharlene S. Budd, Ph.D., The University of Texas at Austin; MBA, Baylor University; BBA (summa cum laude), Baylor University; AA (Applied Arts), McLennan Community College. As the owner of Budd Management Systems, Dr. Budd is a frequent consultant in practice improvement initiatives. She is a Professor Emeritus at Baylor University, where she taught courses in management accounting and project management. Dr. Budd is the chair of the Business Environment and Concepts Subcommittee of the American Institute of Certified Public Accountants and Chair of the Finance & Metrics Committee of the Theory of Constraints International Certification Organization (TOC-ICO). She is certified in all areas of Theory of Constraints by the TOC-ICO and as a Project Management Professional by the Project Management Institute. Dr. Budd completed extensive training with the Avraham Y. Goldratt Institute in Theory of Constraints concepts, including Critical Chain Project Management and Management Skills, and is a former member of the Institute's JEMBA group. She is a member of numerous organizations including the Financial Executives Institute, Institute of Management Accountants, and Project Management Institute. Dr. Budd has authored and co-authored numerous books and articles on accounting.
Internal Reporting and Improvement Initiatives (Portfolio 5313) Charles Budd
Charles I. Budd, Masters of Divinity (summa cum laude), Baylor University; B.A. (Psychology), Baldwin-Wallace College. Mr. Budd is a former Chief Executive Officer of technology companies including Financial Information Trust, InterContinental Computer Systems, Inc., and Technology Connections, Inc. Mr. Budd is currently a principal in the consulting firm, Budd Management Systems. As a consultant on project management and information systems projects, he has led seminars, conducted workshops and presentations around the world, and co-authored two books. Mr. Budd is a certified Project Management Professional (PMP), a certified Systems Analyst, and holds a Jonah certification in the Theory of Constraints. He is currently active in the Project Management Institute as well as several information systems and civic volunteer organizations.
Beverly R. Budin, Esq.Beverly R. Budin, B.A., University of Pennsylvania (1965); J.D., Stanford University Law School (1969); Board of Regents, American College of Trust and Estate Counsel; past Editor, ACTEC Journal; adjunct professor, Villanova University Law School; contributing editor, Tax Management Estates, Gifts and Trusts Journal; member, Tax Management Estates, Gifts and Trusts Advisory Board; past Chair, Estate and Gift Taxes Committee, Section of Taxation, American Bar Association; member, Tax Committee, Orphans’ Court Section, Philadelphia Bar Association; member, Pennsylvania, Florida and Massachusetts Bars.
Life Insurance (Portfolio 826) Bobby BurgnerBobby L. Burgner is Tax Counsel and Director of State and Local Taxes for General Electric Company in Atlanta, Georgia. Prior to joining GE, he was a partner and Southeast Region Director of State and Local Services with Arthur Andersen & Co. in Atlanta, Georgia. He is a CPA and attorney, and has been appointed a member of both the AICPA and ABA committees on state and local taxation. Mr. Burgner graduated from the University of West Florida (B.A. accounting; Phi Kappa Phi; magna cum laude) and Georgetown University Law Center (J.D.; magna cum laude; Order of the Coif; Sewell Key Award). While attending Georgetown, he served as state tax manager for MCI Communications Corporation, and later as state tax manager in the national tax office of another national accounting firm. From 1989 through 1995 Mr. Burgner resided in Atlanta, where he headed the state and local tax practice for Arthur Andersen in the Southeast Region. In 1995, he joined General Electric Company as Tax Counsel and Director of State and Local Taxes.
Income Taxes: Special Problems Formulary Apportionment (Portfolio 1180) Frederick R. Burke, Esq.Frederick R. Burke is a managing partner of Baker & McKenzie LLP's Vietnam offices. He obtained his Bachelor of Arts Degree with Honors from Stanford University, his Juris Doctor Degree from Columbia University School of Law and his Masters Degree of International and Public Affairs from Columbia University School of International Affairs. He was admitted to practice in New York (1987) and Washington, D.C. (1988) and registered as a foreign lawyer in Vietnam since 1996. Fred Burke has almost twenty years' experience in the planning, negotiation and operation of foreign investment projects as well as in the related issues of trade, securities, finance, construction, taxation, regulatory compliance, labor, intellectual property and technology transfer. He is currently a Vice Chairman of the Executive Committee of Hong Kong Business Association in Vietnam, Co-Chairman of the Executive Committee of the Vietnam Business Forum and Senior Advisor, and Chairman of the Legal Committee of the American Chamber of Commerce in Vietnam. Languages: English, Mandarin, Vietnamese, French, German and Italian.
Business Operations Vietnam (Portfolio 994) Hannah Burke
KPMG LLP's Energy Sustainability Tax practice
Steven Burkholder
Steven Burkholder is the Norwalk, Connecticut Staff Correpondent at BNA Tax and Accounting's Accounting Policy & Practice Report.
Craig Burley
Craig Burley is an associate in Gowlings’ Hamilton office where he is a member of the National Tax Group. Craig's practice focuses on Canadian and cross-border corporate, partnership and trust tax. He specializes in providing tax advice to active businesses and investment funds in the context of acquisitions, reorganizations, restructurings and cross-border financing , as well as cross-border issues relating to executive secondments and transfers and non-residents providing services in Canada. Gowling Lafleur Henderson LLP ("Gowlings") is ranked by International Tax Review as one of Canada's leading international tax advisory firms and is the sole Canadian member of Taxand, a global network of leading tax advisors. Gowlings is one of Canada's largest national law firms; In addition to its pre-eminence in corporate and business law, Gowlings is recognized for its expertise in information technology, energy and infrastructure, international trade, advertising and media, professional liability and the environment.
Peter Burt, Federal Tax Law Editor
Peter E. Burt is a Federal Tax Law Editor at BNA Tax & Accounting where he works on issues related to personal and trade or business income, deductions, credits, and incentives. Peter came to BNA Tax Management from Thomson West, where he spent several years as a member of Thomson West's tax law editorial team. Prior to entering the legal publishing industry, he was in private law practice focusing on estate and business succession planning, commercial transactions, and litigation. Peter received a B.A. in Political Science from Brigham Young University and J.D. and LL.M. (in Taxation) from Thomas M. Cooley Law School.
Herbert BuzanichHerbert Buzanich, University of Vienna (Master of Laws 1998); Doctor of Jurisprudence (2001); LL.M. International Tax (NYU 2004); member, Austrian Bar; member, New York State Bar; member, International Fiscal Association.
Business Operations Austria (Portfolio 952)
C
Michael J. Caballero, Esq.
Michael J. Caballero, B.S. in Mathematics, magna cum laude, University of Notre Dame, 1991; J.D., cum laude, Georgetown University, 1994; LL.M. in Taxation, New York University, 2000; Partner, Paul, Hastings, Janofsky & Walker LLP, Washington, D.C.; admitted in Washington, D.C. and New York.
Oguz Caginalp, Esq.Oggie Caginalp, B.A., Tufts University; M.B.A. New York University Graduate School of Business; J.D., Boston College Law School; LL.M (in Taxation), New York University School of Law; Attorney, Tax Department, Brown & Wood; Attorney, Tax Department, Rogers & Wells; Vice President and Senior Tax Counsel, Corporate Tax Division, Citibank, N.A; Vice President, Capital Structuring Group, Citibank, N.A, Senior Vice President and Head of Tax, Commerzbank Capital Markets Corporation (2000-present).
The Mark-To-Market Rules of Section 475 (Portfolio 543) David Cairns, FCA
David Cairns provides consulting and training services on International Financial Reporting Standards (IFRS) and has authored several authoritative texts on IFRS. He was the secretary-general of the International Accounting Standards Committee (IASC) from 1985 to 1994 and is a member of the IASB's Working Group on Accounting Standards for Small and Medium-sized Entities. He is a member of the UK's Financial Reporting Review Panel and is Visiting Professor in Accounting at the London School of Economics and Political Science. Prior to joining the IASC, Mr. Cairns was a partner in Stoy Hayward (now BDO Stoy Hayward) and chairman of the firm's international accounting and auditing committee. He has also worked for Société Générale, Black and Decker, Carlsberg and Pannell Kerr Forster. In 1995, he was appointed OBE for his services to the accountancy profession.
Massimo G. Calderan, Esq.Massimo G. Calderan, University of Zürich (lic. iur., 1986); admitted to bar (Zürich 1991, St. Gallen 1995 and Zug 1995); member, Swiss, Zürich and International Bar Association; Association Internationale des Jeunes Avocats (“AIJA”), Swiss-Italian Chamber of Commerce (Zürich), Swiss-Spanish Chamber of Commerce (Zürich).
Business Operations Switzerland (Portfolio 986) Allen Calhoun, Esq.
Allen Calhoun, Esq. is an Editor at BNA Tax & Accounting and contributor to the Weekly Report.
Jay Camillo
Ernst & Young LLP, Atlanta
German CamposGermán Campos, Universidad de Santiago de Chile (Certified Public Accountant, 1989, and Commercial Engineer, 1992); Professor, Universidad de Chile, Pontificia, Universidad Católica de Chile, and Universidad de Santiago de Chile; Member, Instituto de Derecho Tributario and International Fiscal Association.
Business Operations Chile (Portfolio 997) Michael Carnevale, CPA Esq.Michael K. Carnevale, Esq., University of Michigan (1982); University of Detroit (1990). Certified Public Accountant (New York, New Jersey, Michigan); Partner, Deloitte Tax LLP; member, American Institute of Certified Public Accountants, Michigan Society of Certified Public Accountants, American Bar Association, Michigan Bar Association, and National Association of Real Estate Investment Trusts.
Real Estate Investment Trusts (Portfolio 742) John L. Carr, Jr. Esq.John L. Carr, Jr., B.S., Auburn University (1969); J.D., University of Georgia (1978); Editor, University of Georgia Law Review (1977-78); member, International Fiscal Association.
Indirect Foreign Tax Credits (Portfolio 902) James E. Carreon, Esq.James E. Carreon, J.D., Southwestern University School of Law; B.S. and B.A., University of Southern California; State Bar of California; Adjunct Professor, Golden Gate University, Master of Tax Program.
Related Party Transactions (Portfolio 564) Elizabeth A. Case, Esq.Elizabeth A. Case, B.A., Millsaps College; M.B.A., Southern Methodist University; formerly Special Assistant to the Deputy Chief Counsel, Internal Revenue Service; Participant, AICPA Partnership Taxation Technical Resource Panel.
Limited Liability Companies (Portfolio 725) Patrick Cauwenbergh, Esq.Patrick Cauwenbergh is an International Tax Partner with Deloitte Belastingconsulenten and is the head of the transfer pricing and tax effective supply chain group within Deloitte. He has participated in transfer pricing assignments for Europe-based companies (including many of the largest Belgian controlled groups) regarding their relations with other EU-countries, Eastern Europe countries, the United States, Japan, etc. He obtained a Ph.D. in law on “international transfer pricing” at the University of Antwerp, where he is a Professor of International Tax Law, and obtained a Master in International and European Taxation at the Ecole Supérieure des Sciences Fiscales in Brussels. In addition, he has prior experience in the corporate tax aspects of the financial industry (hybrid financing, global trading, cash pooling, charge out of corporate fees, cost sharing, leasing transactions, etc.). He has published two monographs and authored several articles on international transfer pricing and is Guest Professor at the Universities of Gent and Leuven and a regular speaker at seminars on related topics.
Transfer Pricing: European Rules and Practice, Part 2 (Portfolio 896) Karen E. CederothKaren E. Cederoth, B.S., Eastern Illinois University; M.A., taxation, DePaul University; tax partner, International Tax Service Line, Deloitte Tax LLP, Chicago, Illinois; formerly with Arthur Andersen, Chicago; formerly with Container Corporation of America, responsible for international compliance; Instructor, DePaul University, Masters in Tax Program.
The Allocation and Apportionment of Deductions (Portfolio 906) Clark J. Chandler, Ph. D.Clark J. Chandler, Dickinson College, B.A. (1974); University of Michigan, M.A. and Ph.D., Economics (1978). Dr. Chandler is a principal with KPMG LLP's Washington national Tax/Economic Consulting Services practice. He has testified extensively and worked for both tax authorities and multinational corporations in the area of international transfer pricing.
Transfer Pricing: Economic, Managerial, and Accounting Principles (Portfolio 889) Stephen Charbonnet
Stephen G. Charbonnet -- Tulane University, J.D., Loyola Marymount University, B.B.A.. Currently at KPMG LLP's Washington National Tax office.
Betty ChavisBetty Chavis, Ph.D., is a Professor of Accounting and serves as the Chair of the Department of Accounting at California State University, Fullerton. Dr. Chavis teaches and conducts research in the areas of financial accounting and reporting, international accounting, and financial statement analysis. She was an Accounting Academic Fellow with the SEC in the Division of Corporation Finance in Washington, D.C. in 2001-2002. Professor Chavis received her Ph.D. in Accounting from the University of Southern California. In addition to the current Share-Based Compensation research, Dr. Chavis is actively researching convergence issues between US GAAP and IFRS. Her research has been published in several academic journals including the Journal of Accounting, Auditing and Finance. She has also presented seminars on US GAAP, Sarbanes-Oxley regulation, SEC reporting and International Financial Reporting in the United Kingdom, Germany and China.
Accounting for Share-Based Compensation (Portfolio 5109) C. V. ChenC. V. Chen, Managing Partner, admitted 1975, Member of Taipei and Kaohsiung Bar Associations, R.O.C.; Education: S.J.D., Harvard Law School (1972); LL.M., Harvard & University of British Columbia; LL.B., National Taiwan University. Experience: Managing Partner and CEO, Lee and Li Attorneys-at-Law, Taipei, Taiwan; Member of the Committee of Taxation Policy and Regulation Consultation, Ministry of Finance, R.O.C.; Adjunct Professor of Law, National Chengchi University & Soochow University Graduate School of Law (1972–present), Taiwan; Lecture Professor of Law at the Management Schools of Peking University and Tsinghua University, China; President, (April 2000–present), The Red Cross Society of the Republic of China; Chairman, Taipei European School Foundation, Taiwan, Republic of China (1994–present); Director (December 1993–present), Vice Chairman (February 1992–December 1993), first-term Vice Chairman & Secretary General (November 1990–February 1992), Straits Exchange Foundation; Director, Lee and Li Foundation; President, The Chinese Society of International Law (January 2004–present); Board of Director, Yuan Ze University (Taiwan) (1990–present); Honorary President, Harvard Club of Republic of China on Taiwan (1989–present); Numerous articles on transnational legal problems.
Business Operations in the Republic of China (Taiwan) (Portfolio 958) Xinyu Chen
Xinyu Chen is deputy division director of the Shenzhen municipal office of China's State Administration of Taxation.
Robin A. Chesler, Esq.Robin A. Chesler, Esq., B.A., Harvard-Radcliffe University (1986, magna cum laude); J.D., University of California, Boalt Hall School of Law (1989); Partner, Baker & McKenzie, LLP; co-author, The Final Software Revenue Characterization Regulations, Tax Management International Journal (February 1999); co-author, Characterization of Computer Software Revenue in International Transactions, TAXES, The Tax Magazine (December 1996); member, State Bar of California, American Bar Association Section on Taxation.
Federal Taxation of Software and E-Commerce (Portfolio 555) Bernard ChesnaisBernard Chesnais obtained Master degrees in general law studies (University of Bretagne – Rennes, 1969), sociology (University of Bretagne – Rennes, 1970), and tax law (Ecole Nationale des Impôts), as well as a Diplôme d'Etudes Comptables Supérieures (Ecole Nationale des Impôts). He is a former tax inspector at the Direction des Vérifications Nationales et Internationales; partner, Salans.
Business Operations France (Portfolio 961) Spencer Chong
Spencer Chong is a transfer pricing partner in PricewaterhouseCoopers' China transfer pricing network.
R. Lee Christie, Esq.Lee Christie is a partner in the Chicago office of Hopkins & Sutter whose practice focuses on tax matters for insurance industry clients, including property and casualty insurers, life and health insurers, HMOs, Blue Cross organizations, insurance trade associations, and insurance guaranty associations. He graduated from Illinois Wesleyan University in 1981 and Harvard Law School in 1984. Lee has served as Chair of the Subcommittee on Life Insurance Companies of the ABA Tax Section Committee on Insurance Companies.
Annuities, Life Insurance, and Long-Term Care Insurance Products (Portfolio 546) James T. Chudy, Esq.James T. Chudy, B.S. with Honors, Phi Beta Kappa, University of Wisconsin–Madison (1981); J.D., Harvard Law School (1984); Executive Editor, Harvard Civil Rights-Civil Liberties Law Review; The Association of the Bar of the City of New York (Council on Taxation, Secretary, 1990–1993).
Stock Purchases Treated as Asset Acquisitions — Section 338 (Portfolio 788) Richard H. Clark
Richard H. Clark Professor of Law, Emory University, 1986-present; member, Advisory Committee of the University of Miami Philip E. Heckerling Estate Planning Institute; faculty member, American Bankers Association National Graduate Trust School; member, American Law Institute; adviser, Restatement of the Law (Third) of Property — Wills and Other Donative Transfers; former Council member, Real Property, Probate & Trust Law Section of the American Bar Association; Academic Fellow and Former Regent, American College of Trust and Estate Counsel; Academician, The International Academy of Estate and Trust Law; Editor-in-Chief, Real Property, Probate & Trust Journal, 1987-89; member, Tax Management Advisory Board on Estates, Gifts and Trusts; author, Wealth Transfer Planning and Drafting (2005), Federal Wealth Transfer Taxation (4d ed. 2004), Income Taxation of Trusts, Estates, Grantors and Beneficiaries (1987), Casner & Pennell, Estate Planning (6th ed. 2001), co-author, 834 T.M., Transfer Tax Payment and Apportionment (2001), author, various articles and Institute chapters.
George Clarke
George Clarke --U.S. Marine, 1988 - 1992 (active) J.D., Georgetown University Law Center, magna cum laude, 2003; B.S., Edgewood College, magna cum laude, 1998; George Clarke practices in the white collar, internal investigations, and tax areas and focuses on the defense of civil and criminal tax matters (including voluntary disclosure). Other elements of his practice include civil tax litigation and the defense of non-tax federal criminal matters, including allegations of impropriety under the Foreign Corrupt Practices Act (FCPA) and other criminal laws of the United States. Mr. Clarke has substantial experience advising clients on the defense of foreign tax and non-tax criminal investigations and the effect those investigations have in the United States (particularly with respect to U.S. tax liability accrual provisions such as FIN 48). Clarke is currently with Miller & Chevalier.
Christopher P. Cline, Esq.Christopher P. Cline, partner, Holland & Knight LLP; B.A., San Francisco State University, 1987; J.D., Hastings College of the Law, 1991; member of bar, Oregon and California; adjunct professor of law, Northwestern School of Law, Lewis & Clark College, 1997; contributor to Tax Management Estates, Gifts and Trusts Journal, Estate Planning, Probate and Property, and other professional publications.
Powers of Appointment — Estate, Gift, and Income Tax Considerations (Portfolio 825)Dynasty Trusts (Portfolio 838)Disclaimers — State Law Considerations (Portfolio 847)Disclaimers — Federal Estate, Gift and Generation-Skipping Tax Considerations (Portfolio 848)Trustee Investments (Portfolio 861) Grant M. CloweryGrant M. Clowery, C.A. (Canada); CPA (Illinois); Ph.D., Business, University of Chicago; J.D., George Mason University. Dr. Clowery has served as an expert witness and counselor for both the Internal Revenue Service and taxpayers on issues relating to transfer pricing, valuation and financial accounting practice.
Transfer Pricing: Economic, Managerial, and Accounting Principles (Portfolio 889) John CoalsonMr. Coalson is a partner in the Atlanta law firm of Alston & Bird LLP, where his practice focuses exclusively on state and local tax matters. Mr. Coalson is Past Chair of the State Bar of Georgia's Section of Taxation, and he continues to serve as the Taxation Section's Liaison with the Georgia Department of Revenue. He is also a member of the Executive Committee of the National Association of State Bar Tax Sections, and serves on the Advisory Board of the Paul Hartman State and Local Tax Forum at Vanderbilt University. In addition, Mr. Coalson has served as an Adjunct Professor at Emory University School of Law, teaching courses in state and multistate taxation. Mr. Coalson received his B.B.A. degree (with highest distinction) from Emory University, and his J.D. degree (summa cum laude) from the University of Georgia. He is admitted to practice in Georgia. The authors gratefully acknowledge the contributions and assistance of the late Helene Z. Cohen, Esq., formerly a partner at Alston & Bird LLP, in the preparation
Unclaimed Property (Portfolio 1600)State Taxation of Banks and Financial Institutions (CA, IL, NY, TN) (Portfolio 1800) Bruce A. Cohen, Esq.Bruce A. Cohen, B.A., Case Western Reserve University (1984) (Phi Beta Kappa, summa cum laude); J.D., Columbia University (1987); Associate International Tax Counsel and Attorney Advisor, Office of Internal Tax Counsel, Department of the Treasury, 1995-1997; Partner, Baker & McKenzie LLP, 2001-2007; Harlan Fiske Stone Scholar; member, Internal Fiscal Association; member, State Bar of California, District of Columbia Bar, Illinois State Bar Association, Tax Court Bar, American Bar Association Section on Taxation.
Federal Taxation of Software and E-Commerce (Portfolio 555)Research and Development Expenditures (Portfolio 556) Diane Goulder Cohen, Esq.
Diane Goulder Cohen, B.A., The Ohio State University, 1972, summa cum laude; J.D., Cornell University College of Law, 1975; Partner, The Wagner Law Group, Boston, MA; member Ohio Bar; Life Fellow Ohio State Bar Foundation; ABA Section of Taxation; speaker on ERISA and employee benefit issues; author, articles on ERISA and employee benefits, including Benefits Law Journal.
I. Mark Cohen, Esq.I. Mark Cohen, B.S., California State University, Long Beach (1980); J.D., University of Arizona, College of Law (1984); LL.M. (in Taxation), College of William and Mary, Marshall-Wythe School of Law (1989); Judge Advocate, United States Navy, 1984-1988; Tax Manager, Goodman & Company, CPAs, 1988-1989; Associate Attorney, Adams, Porter & Radigan, 1989-1991; Founder and Principal of Cohen & Burnett, P.C., 1991-present; Past President, Northern Virginia Estate Planning Council; Member, Legislative Committee, Trusts and Estates Section, Virginia State Bar; Member, American Bar Association; Member, Virginia State Bar; Member, Arizona State Bar. Mr. Cohen is the Virginia Reporter to the UTC.
Uniform Trust Code (Portfolio 864) Robert T. Cole, Esq.Robert T. Cole, B.S., Wharton School of Finance, University of Pennsylvania (1953); LL.B., Harvard Law School (1956); Academic Postgraduate Diploma in Law, London School of Economics (1959); senior counsel in the Washington, D.C. office of Alston & Bird LLP; former member of Cole Corette & Abrutyn; former International Tax Counsel of the U.S. Treasury Department; editor and principal author of Practical Guide to U.S. Transfer Pricing.
Income Tax Treaties — Administrative and Competent Authority Aspects (Portfolio 940) Jason Connery
Jason R. Connery is with KPMG LLP in Washington, D.C. and is a frequent contributor to BNA's International Journal.
Douglas Connolly, Esq.
Douglas P. Connolly, Esq. is Editor for Estates, Gifts and Trusts and Foreign Income at BNA Tax & Accounting, and a contributing editor for the Weekly Report.
Peter J. Connors, Esq.Peter J. Connors, B.A., Catholic University; J.D., University of Richmond; LL.M (in Taxation), New York University School of Law; Senior Tax Accountant, Arthur Andersen & Co.; Attorney, Tax Department, Bondy & Schloss; Tax Manager, J.C. Penney & Co.; Senior Manager, KPMG; Principal and Director of International Capital Markets Tax Services, Ernst & Young LLP; Tax Partner, Baker & McKenzie (1995 to 2001); CPA (New York).
The Mark-To-Market Rules of Section 475 (Portfolio 543)The Branch-Related Taxes of Section 884 (Portfolio 909) Kevin R. Conzelmann, Esq.Kevin R. Conzelmann (A.B., Xavier University; J.D., Harvard Law School; LL.M., New York University, School of Law) is the Tax Counsel of Omnicom Group Inc.
Amortization of Intangibles (Portfolio 533) Lynn A. Cook, Esq.
Lynn Cook B.A., State University of New York at Fredonia; J.D., Pace School of Law; LL.M., Taxation, Georgetown Law Center; Watson Wyatt Worldwide, Research and Innovation Center, Arlington, VA; member VA Bar, NYS Bar; formerly a Tax Law Specialist in the IRS Employee Plans Technical Division, Washington, DC national office; member IRS Mid-Atlantic Pension Liaison Group.
Manal Corwin
Manal S. Corwin is with KPMG, LLP in Washington, D.C. and is a frequent contributor to BNA's International Journal.
William H. CowperWilliam H. Cowper, George Washington University, J.D., with high honors, 1983; State University of New York at Buffalo, B.S., 1978. He is a member of Order of the Coif. Cowper is currently Vice President and Corporate Counsel on Employee Benefits Law for Prudential Insurance Company. Previously he was an Associate at Dow Lohnes & Alberston from 1983-1990. Mr. Cowper was admitted to District of Columbia in 1983 and is co-Author of Tax Management Portfolio IRS Determination Letter Procedures.
Qualified Plans — IRS Determination Letter Procedures (Portfolio 360) Toby Cozart, Esq.Toby Cozart, B.A., University of North Carolina (1974); J.D., Duke University (1978); M.S. in Philosophy, University of North Carolina (1979); LL.M. in Taxation, New York University School of Law (1981). Law office, Piedmont, California. Previously: Tax Counsel, GATX Capital Corporation, San Francisco, California; Partner, Lillick, McHose & Charles, San Francisco, California; Associate, Morgan, Lewis & Bockius, New York, New York; Staff Counsel, Subcommittee on Oversight, Committee on Ways and Means, U.S. House of Representatives, Washington, D.C.; Member of the Bars of the District of Columbia, New York, California, and the United States Tax Court.
Equipment Lease Characterization (Portfolio 545)Equipment Leasing: Substance and Form (Portfolio 544) Bridget J. CrawfordBridget J. Crawford, Esq., Assistant Professor, Pace University School of Law (2003- ); Milbank, Tweed, Hadley & McCloy LLP (Associate, 1996-2003); Lecturer in Law, University of Pennsylvania School of Law (2001); University of Pennsylvania School of Law (J.D. 1996); Elected Member, Moot Court Board; Yale College (B.A. magna cum laude 1996); Member: American Bar Association, Sections on Real Property, Probate and Trust Law and Taxation; New York State Bar Association, Trusts and Estates Law Section; Association of the Bar of the City of New York, Non-Profit Organizations Committee (1997-2000); Publications include “Model Estate Planning Documents” in Appendix to David Westfall and George P. Mair, Estate Planning Law and Taxation (5th ed. 2003) (with James S. Sligar); “Grantor Trusts and Income Tax Reporting Requirements: A Primer,” Prob. Prac. Rep. (May 2001) (with Jonathan G. Blattmachr); “Wilderness No More: Alaska as the New ‘Offshore’ Trust Jurisdiction,” J. of Soc'y Advanced Legal Stud. (Nov. 1999) (with Jonathan G. Blattmachr); “Selected Estate Planning Strategies for Persons With Less than $3 Million,” Estate Planning (July 1999) (with Jonathan G. Blattmachr and Georgiana J. Slade).
Estate Planning for Authors and Artists (Portfolio 815) Roy Crawford, IIIMr. Crawford is Special Counsel for Heller, Ehrman, White and McAuliffe in San Francisco. He formerly was a partner in the San Francisco, California office of Brobeck, Phleger & Harrison. Mr. Crawford has served as the Chairman of the State and Local Tax Committee of the ABA Taxation Section, and as a special consultant to the City of New York in the area of taxation of banking institutions. Mr. Crawford is a co–author of 1910 T.M., California Franchise and Corporation Income Taxes, and 1920 T.M., California Sales and Use Taxes, and the author of “Reorganization and Sale of a Business,” which appears in California Taxation (Matthew Bender). He also sits on the editorial advisory boards of the Journal of State Taxation and the Journal of Bank Taxation. Mr. Crawford received his law degree from the University of Pennsylvania and his L.L.B. degree from Stanford University.
Income Taxes: The Distinction Between Business and Nonbusiness Income (Portfolio 1140)California Franchise and Corporation Income Taxes (Portfolio 1910)California Sales and Use Taxes (Portfolio 1920) Nina J. CrimmNina J. Crimm, Professor of Law, St. John's University School of Law (New York). A.B., Washington University (1972); J.D. and M.B.A., Tulane University (1979); LL.M. in Taxation, Georgetown University Law Center (1982); previously Tax Attorney with former Washington, D.C. firm of Ginsburg, Feldman and Bress; Attorney/Advisor at the United States Tax Court for Judge Irene F. Scott and Chief Judge Arthur L. Nims; author of Tax Court Litigation: Practice and Procedure (Little, Brown and Co., 1992 and supplements) and of numerous published law review and journal articles.
Tax Issues of Religious Organizations (Portfolio 484) Robert J. Crnkovich, Esq.Robert J. Crnkovich, B.S., J.D., Marquette University; LL.M. in Taxation, Georgetown University Law Center; Adjunct Professor, Georgetown University Law Center; member, State Bars of Wisconsin, California, and District of Columbia.
Limited Liability Companies (Portfolio 725) Frank Cummings, Esq.Frank Cummings, B.A. with high honors, Hobart College (1951), Phi Beta Kappa; M.A., Columbia University (1955); L.L.B., Columbia University School of Law (1958), Harlan Fiske Stone Scholar; Articles Editor, Columbia Law Review; Chairman, ALI-ABA Annual Course in Employee Benefits Litigation; Co-Chairman, ALI-ABA Annual Course in Employment & Labor Relations Law for the Corporate Counsel & General Practitioner; member, The American Law Institute, American Bar Association; former Chairman, District of Columbia Bar Association (Labor Committee); Association of the Bar of the City of New York, District of Columbia Bar and the State Bar of New York; Lecturer in Law, University of Virginia Law School; former member, U.S. Department of Labor Advisory Council on Employee Welfare and Pension Benefit Plans.
Pension Plan Terminations — Single Employer Plans (Portfolio 357) Joseph J. Czajkowski, Esq.Joseph J. Czajkowski, Georgetown University (B.A., 1971); studied in the Faculty of Law, University of Fribourg (Switzerland); Boston College Law School (J.D., 1975); Georgetown University Law Center (LL.M. Taxation, 1979); admitted to bar, District of Columbia (1976), Texas (1992); member, American Bar Association Section on Taxation, International Fiscal Association, and Tax Chapter Board of the Swiss-American Chamber of Commerce (Zürich).
Business Operations Switzerland (Portfolio 986) Capitol Tax Partners
Capitol Tax Partners is Washington’s largest independent consulting firm specializing in tax legislative and regulatory matters. The firm’s principals offer their clients an intimate knowledge of the tax-writing and rulemaking process. They have more than 100 years of experience in senior positions with the congressional tax-writing committees and the United States Treasury Department, and many years of experience representing private sector clients regarding tax matters before Congress, Treasury and the Internal Revenue Service.
D
Dominic L. DaherDominic L. Daher holds a Master of Laws in Taxation from New York University School of Law, a Juris Doctor from Washington University School of Law, and both Master and Bachelor of Accountancy degrees from the University of Missouri-Columbia. Mr. Daher writes for various scholarly and professional journals, and he serves on the Editorial Advisory Boards for some of the leading tax journals in the nation. Mr. Daher also teaches an array of tax courses in the University of San Francisco's School of Business and School of Law, and he is one of the authors of The Hornbook on Federal Income Taxation (West Group 2008).
Accounting for Not-for-Profit Organizations (Portfolio 5200)Accounting for Combinations of Not-for-Profit Organizations (Portfolio 5203) Roland S. Dahlman, Esq.Roland S. Dahlman, LL.B. 1970 and LL.D. 2006 (Stockholm), LL.M. 1974 (Harvard University); Advokat. Member of the Swedish Bar and of Dahlman Advokatbyrå, Stockholm, Sweden.
Business Operations Sweden (Portfolio 985) David C. D'Alessandro, Esq.
David C. D'Alessandro, B.A. summa cum laude, Economics, Boston College, 1991; J.D., University of Michigan Law School, 1994; Partner, Vinson & Elkins LLP, Dallas, Texas; Member: Texas Bar, National Association of Stock Plan Professionals, SouthWest Benefits Association, Employee Benefits/Executive Compensation Section of the Dallas Bar Association; Chairman: Employee Benefits and Executive Compensation Committee of the Tax Section of the State Bar of Texas; Speaker on a variety of executive compensation and employee benefits topics at symposiums and conferences for various organizations including the American Bar Association and The Conference Board.
Susan J. Daley, Esq.Susan J. Daley, B.A., University of Connecticut (summa cum laude 1978); J.D., Harvard Law School (1981); member, American Bar Association, Section of Taxation (chair, Securities Law Subcommittee of the Employee Benefits Committee); member, Chicago Bar Association, Federal Taxation Committee (former chair), Employee Benefits Committee (former chair); Illinois State Bar Association Employee Benefits Section Council (former chair); member, American College of Employee Benefits Counsel; member, National Association of Stock Plan Professionals (Chicago Chapter President); member, BNA Pension & Benefits Advisory Board.
Securities Law Aspects of Employee Benefit Plans (Portfolio 362) Robert T. DanforthRobert T. Danforth; B.A., Washington University (1980); J.D. with High Honors, Duke University (1986); Order of the Coif; Article Editor, Duke Law Journal, 1985-86; Law Clerk, Judge Stephanie K. Seymour, United States Court of Appeals for the 10th Circuit, 1986-87; Adjunct Assistant Professor, University of Tulsa College of Law, 1986; Associate, Arnold & Porter, Washington, D.C., 1987-91; Associate (1992-96) and Of Counsel (1997), McGuireWoods LLP, Charlottesville and Tysons Corner, Virginia; Lecturer, University of Virginia School of Law, 1995-97; Assistant Professor of Law (1997-2002) and Associate Professor of Law (2002-present), Washington and Lee University School of Law; Academic Fellow, American College of Trust and Estate Counsel; member, Tax Management Advisory Board on Estates, Gifts and Trusts.
Taxation of Jointly Owned Property (Portfolio 823)Transfer Tax Payment and Apportionment (Portfolio 834) J. William Dantzler, Jr. Esq.
J. William Dantzler, Jr., B.S., Clemson University, 1974; J.D., New York University, 1979; Tax Partner and Head of Global Tax Practice, White & Case LLP, New York, New York; domestic and international corporate tax practice with emphasis on mergers and acquisitions and tax controversies, including transfer pricing; speaker and author on U.S. and international corporate tax issues.
Kathleen David
Kathleen David is Editor of BNA Tax & Accounting's IRS Practice Adviser Report.
Kristi DavidsonKristi A. Davidson, an associate with the firm's Commercial Litigation Group, focuses her practice in securities litigation, misappropriation of trade secrets, real estate tax exemptions, and claims against accounting firms. A member of the Allegheny County Bar Association, Ms. Davidson has chaired committees involving real estate tax appeals and quality of practice issues. Ms. Davidson received a B.S. from Truman State University and a J.D. from the College of William & Mary.
Preparing for and Defending Accounting Liability Litigation (Portfolio 5500) Bruce N. Davis, Esq.Bruce N. Davis, B.A., University of Virginia (high honors 1980, Phi Beta Kappa); J.D., Harvard Law School (1983); LL.M. (in taxation), Southern Methodist University (1987); Former Chairman, Subcommittee on §§338, 367 and 1491, Committee on Foreign Activities of U.S. Taxpayers, American Bar Association; Principal Special Assistant to the Associate Chief Counsel (International), Internal Revenue Service (1988-1991); member of board of advisors of various international tax publications, and frequent speaker and writer on international tax issues.
Outbound Transfers Under Section 367a (Portfolio 919)Other Transfers Under Section 367 (Portfolio 920) Glenn Davis, Esq.
Glenn Davis is Executive Editor, Federal Tax Services, at BNA Tax and Accounting (a.k.a. Tax Management). Glenn joined Tax Management in February 1985 as a Tax Law Editor and was promoted to Managing Editor in July 1986. He assumed his current duties in October 1991. Prior to joining BNA, Glenn spent three years as a Tax Law Specialist in the IRS National Office’s Employee Plans and Exempt Organizations Division, as well as several years’ general law practice. Glenn holds a Master of Laws in Taxation degree from the Georgetown University Law Center, a J.D. from the University of Maryland School of Law, and an A.B. from Brandeis University.
Mario A. de CastroMario A. de Castro, University of Miami School of Law (LL.M. in Taxation); Temple University of Law (J.D. 1994); Tulane University (B.A. 1990); member, American Bar Association; member, Florida Bar; Licensed to practice law in the State of Florida, U.S. Court of Appeals for the Eleventh Circuit, United States Tax Court; United States District Court for Southern District of Florida, and in the Republic of Colombia (pursuant to ICFES Resolution issued 1999).
Business Operations Colombia (Portfolio 956) J. Gary DeanJ. Gary Dean is a Multistate Tax Services Partner in the Philadelphia Office of PricewaterhouseCoopers LLP. Mr. Dean serves as the National Technical Services Leader of the Firm's Multistate Tax Services Practice, in which capacity he is responsible for all aspects of multistate tax planning, research, and compliance. Mr. Dean is a Lecturer in Law in the Graduate Tax Program at Villanova University and a frequent speaker before business and professional organizations, including the Committee on State Taxation, Tax Executives Institute, the Georgetown University State and Local Tax Institute, and the California Tax Policy Conference. In addition, he has discussed state tax issues on national television and has been accepted as an expert witness in state litigation matters. Gary is a member of the State Tax Advisory Board of Commerce Clearing House, the Editorial Board of the Journal of S Corporation Taxation, and an editor for the “State Tax Topics” column of the Pennsylvania CPA Journal. Gary received a B.A. from Duke University, an M.B.A. from the Wharton School of the University of Pennsylvania, and an M.S.T from Villanova University.
Income Taxes: State Formulary Apportionment Methods (Alabama Through Michigan) (Portfolio 1160)Income Taxes: State Formulary Apportionment Methods (Minnesota Through Wyoming) (Portfolio 1170) James P. DeBree, Jr. CPAJames P. de Bree, Jr., B.S., California State University Northridge (1975). Certified Public Accountant (California); Partner, Deloitte Tax LLP; member, American Institute of Certified Public Accountants, California Society of Certified Public Accountants, National Association of Real Estate Investment Trusts; author of numerous articles on REITs and REIT taxation; frequent speaker on REIT-related matters.
Real Estate Investment Trusts (Portfolio 742) Jocelyn Delsouiller, Esq.Jocelyne Delsouiller, graduated 1972 Geneva, Swtitzerland, admitted to the Geneva Bar 1974, legal counsel in Paris, 1979. admitted to the Paris Bar 1992. Corporate partner Campbell, Philippart, Laigo & Associes, Paris, France.
Business Operations France (Portfolio 961) John DerOhanesian
John DerOhanesian is a senior manager in KPMG's International Corporate Services Group in San Diego, California.
Winnie Di
Winnie Di is a transfer pricing partner in PricewaterhouseCoopers' China transfer pricing network.
Louis H. Diamond, Esq.Louis H. Diamond, Esq.; LL.M. in Taxation, Georgetown University Law Center; J.D., Cum Laude, George Washington University National Law Center; B.A., George Washington University; Managing Member of Diamond ESOP Advisors PLLC, is one of the leading ESOP (Employee Stock Ownership Plan) attorneys in the country. Mr. Diamond is a past chairman of the ESOP Association’s Legislative and Regulatory Advisory Committee. He previously served as attorney advisor at the United States Tax Court, is a Charter Fellow of the American College of Employee Benefits Counsel and a Fellow of the American College of Tax Counsel. His work with ESOPs is all encompassing, ranging from representing owners selling stock to an ESOP, employees pooling ESOP funds to purchase their division/subsidiary from corporations large and small, banks and others making ESOP loans and ESOPs themselves and their trustees. Representing the employees of the Illinois Institute of Technology Research Institute (now Alion Science and Technology) in a $130 million employee buyout of its operating assets is among Mr. Diamond’s most notable ESOP achievements.
Accounting Methods — General Principles (Portfolio 570) Brett R. Dick, Esq.Brett R. Dick, B.A., University of Michigan (1967); J.D., University of Michigan Law School (1970); member, American Bar Association, Section of Taxation, Committee on U.S. Activities of Foreigners and Tax Treaties, Subcommittee on Source of Income; member, State Bar of California, Foreign Taxation Subcommittee; member, San Francisco Foreign Tax Club; member, San Francisco Tax Club; speaker at various conferences on international taxation.
U.S. Income Taxation of Foreign Governments, International Organizations and Their Employees (Portfolio 913) Beth J. Dickstein, Esq.Beth J. Dickstein, B.S., University of Illinois (1985, with highest honors); J.D., University of Pennsylvania Law School (1988, cum laude); Certified Public Accountant; member of the Tax Section of the American Bar Association.
Qualified Plans — Investments (Portfolio 377) James H. Ditkoff
James H. Ditkoff; Senior Vice President, Finance and Tax, Danaher Corporation,Washington, DC. Also served as Vice President-Finance and Tax from January 1991 to December 2002 and has served as Senior Vice President-Finance and Tax since December 2002.
William G. DodgeWilliam G. Dodge, University of Georgia, Master of Accountancy (Tax) (1979); Walsh College, B.A. (1976); Director, Global Transfer Pricing Team; Co–Director, U.S. Transfer Pricing Team, Deloitte & Touche LLP, Washington, D.C. Formerly Partner–in–Charge, U.S. Corporate Tax Group, Deloitte & Touche, London, England. Member, Tax Management Advisory Board (Transfer Pricing). Mr. Dodge is regular speaker at seminars and has worked in New York, London, and Tokyo where he served many of Deloitte & Touche's largest U.S. and non–U.S. clients.
Transfer Pricing: Records and Information (Portfolio 891) Ingmar Doerr
Dr. Ingmar Dörr is a senior associate in Lovells’ International Tax Practice, based in Munich. He is admitted to work as an attorney-at-law and as a certified tax advisor in Germany. Main focus of his activity lies on the national and international tax law and the consultation of German and international clients in M&A/Private Equity and financing Transactions as well as the development and conversion of tax models. He is a graduate of University of Munich and wrote his doctoral thesis on the subject of European company taxation at the Max Planck Institute Munich. Ingmar is an author of numerous professional publications and a member of the International Fiscal Association.
D. Kevin Dolan, Esq.D. Kevin Dolan, B.A., University of Virginia; J.D., University of Michigan; Senior Vice President for Tax Policy, Merrill Lynch & Co.; former partner, Weil, Gotshal & Manges LLP; former Associate Chief Counsel (Technical and International), Internal Revenue Service; former partner, Arthur Young and Co., Washington, D.C.; former Attorney-Advisor, Office of International Tax Counsel, U.S. Treasury Department.
The Creditability of Foreign Taxes — General Issues (Portfolio 901) Joseph DonovanJoseph X. Donovan is a Principal in the Boston office of PricewaterhouseCoopers LLP. Before joining PricewaterhouseCoopers LLP in 1984, Joe was Deputy Chief of the Legal Bureau of the Massachusetts Department of Revenue. He also served as Tax Counsel in the Rulings & Regulations Bureau of the Department. Author of the Massachusetts Sales and Use Tax Manual, he is the former chair of the State Tax Committee of the Massachusetts Society of CPAs and serves on the advisory board of State Tax Notes. Joe also served as an advisor on state tax matters to Governor Weld's Council on Economic Growth and has written and lectured widely on state and local tax matters. Joe received an A.B. from Cornell University and a J.D. from the University of Michigan Law School.
Income Taxes: State Formulary Apportionment Methods (Alabama Through Michigan) (Portfolio 1160)Income Taxes: State Formulary Apportionment Methods (Minnesota Through Wyoming) (Portfolio 1170) Glenn W. Dowd, Esq.Glenn W. Dowd, Central Connecticut State University (B.A. cum laude, 1984), University of Connecticut School of Law (J.D. high honors, 1989); member, Connecticut Bar; associate, Day, Berry & Howard.
Reductions Force (Portfolio 398) Michael Drake
Michael Drake is an accounting doctoral scholar at Texas A&M University. Prior to entering the doctoral program, he worked at an international public accounting firm.
William A. Drennan, II Esq.William A. Drennan, B.S. in Business Administration, summa cum laude, St. Louis University (1982); J. D., magna cum laude, St. Louis University School of Law (1985), LL.M. in Taxation, Washington University School of Law in St. Louis, Missouri (1997), Chair, Administrative Advisory Committee, Archdiocese of St. Louis Charitable Gift & Bequest Council; fellow, American College of Tax Counsel and American College of Trust & Estate Counsel; member, Association for Advanced Life Underwriting and Mensa; adjunct professor at the Washington University School of Law Graduate Tax Program; Senior Editor of “The Insurance Counselor” Series of books published by the Real Property, Probate and Trust Law Section of the American Bar Association; Co-author of “Taxation and Funding of Nonqualified Deferred Compensation: A Complete Guide to Design and Implementation”; passed Missouri CPA exam in 1984.
Estate Planning for the Corporate Executive (Portfolio 808) Pamela Jensen Drucker, Esq.Pamela Jensen Drucker, B.S., Arizona State University (1986); J.D., Arizona State University College of Law (1997); LL.M. (Taxation), New York University (1998); member, California Bar, American Bar Association (Tax Section), Los Angeles County Bar Association (Tax Section officer (2004- ); Chair Foreign Tax Committee (2003-2004)); contributor, various tax publications.
Civil Tax Penalties (Portfolio 634) Amy DunbarAmy Dunbar, Ph.D. (Accounting), University of Texas at Austin; B.A. (Economics), Macalester College. Dr. Dunbar is an accounting professor at the University of Connecticut. She has written articles for publications including The Encyclopedia of Taxation and Tax Policy; Financial Reporting Watch; Journal of Public Economics; National Tax Journal; Public Finance Review; Tax Adviser; Tax Notes; Journal of the American Taxation Association; and Taxation for Accountants. She is on the editorial board of Accounting Horizons and the Journal of the American Taxation Association. Dr. Dunbar has received a number of teaching awards, and is a past vice-president of the American Taxation Association.
Accounting for Income Taxes: Uncertain Tax Positions (FIN 48) (Portfolio 5002)Accounting for Income Taxes: Uncertain Tax Positions � Selected Topics (Portfolio 5003) Harley Duncan
Harley Duncan, B.A., South Dakota State University – 1972; Master of Public Affairs, University of Texas, 1978. Managing Director, KPMG LLP, Washington National Tax. Executive Director of Federation of Tax Administrators, 1988-2008. Frequent speaker on state and local tax and fiscal policy issues, author of articles on state and local taxation, tax administration and federal-state tax coordination.
David S. Dunkle, Esq.David S. Dunkle, B.A., Virginia Military Institute (Honors in English 1966); J.D., University of North Carolina Law School (member of Law Review 1969); LL.M. (Taxation) Georgetown Law Center (1970); member Alabama State Bar, North Carolina State Bar, American Bar Association (Section of Taxation); contributor to The Journal of Taxation, TAXES, Law Office Economics and Management, The North Carolina Bar Association BAR NOTES, and The North Carolina Law Review; author of treatise: Guide to Pension and Profit Sharing Plans, Shepard's/McGraw–Hill, 1984.
VEBAs and Other Self-Insured Arrangements (Portfolio 395) Carolyn M. DuPuy, Esq.Carolyn M. DuPuy, B.A., Mount Holyoke College; J.D. and M.L.T., Georgetown University Law Center; partner, Weil, Gotshal & Manges LLP; former Senior Technical Reviewer, Office of the Associate Chief Counsel (International), Internal Revenue Service.
The Creditability of Foreign Taxes — General Issues (Portfolio 901) Michael C. Durney
Michael C. Durney; Hastings College of Law, University of California (1968; Juris Doctor; Editorial Board, Hastings Law Journal); University of California at Berkeley. Bar Admissions: District of Columbia and California Bars; admitted to practice before the U.S. Tax Court, the U.S. Court of Federal Claims and the U.S. Supreme Court. Served as Deputy Assistant and Acting Assistant Attorney General for the Tax Division of the U.S. Department of Justice: Trial Attorney, U.S. Department of Justice—Tax Division. Member of U.S. Court of Federal Claims Advisory Council, 1993–; District of Columbia Bar; the State Bar of California: Federal (Chairman: Court and Tax Procedure Committee, 1977-1982; Section of Taxation, 1982-1984; Senior Advisory Committee, 1984–) and American (Member, Sections of: Taxation; Chairman, Subcommittee on Legislative and Administration Proposals, 1993–, Litigation) Bar Associations. Currently at Moore & Bruce LLP, Washington, D.C.
E
Jim Eads
Jim Eads, B. S. B. A. University of Arkansas-Fayetteville, 1970 and J. D. University of Arkansas-Fayetteville, 1973; Currently-Executive Director of the Federation of Tax Administrators, Formerly-Director, Public Affairs for Ryan & Co., President & Executive Director of the New Mexico Tax Research Institute, International Director of Electronic Commerce of the Large and Mid-Size Business Division of the Internal Revenue Service, Partner in the National Tax Department of Ernst & Young, Senior Attorney & Government Relations Counsel with AT&T Corp., Senior Tax Attorney with Sears, Roebuck & Co., Chief Counsel of the Revenue Division of the Arkansas Department of Finance & Administration. Past President of the National Tax Association and former Chairman of the Electronic Commerce Task Force of the Council on State Taxation. Currently serves on the State Tax Advisory Board of CCH, the Advisory Board of the Georgetown Institute of State & Local Tax and the Advisory Board of the Paul J. Hartman State & Local Tax Forum. Formerly served on the Board of Directors of the National Taxpayers Conference and the New Mexico Society of Association Executives. Taught state tax law as an adjunct professor of law at the University of New Mexico School of Law for two years.
David Early-Hubelbank, Esq.
David Early-Hubelbank, B.A., Wesleyan University (1986); J.D. (with distinction), Hofstra University School of Law (1992); Editor-in-Chief, Hofstra Law Review; LL.M. (in Taxation), New York University School of Law (1997).
Joseph Ecuyer, Federal Tax Law Editor
After years in private practice in New Orleans in both the tax and ERISA areas, Joe joined BNA Tax & Accounting in 2005 where he is currently a Tax Law Editor in the U.S. Income Group. He works mainly on issues related to personal and business income, deductions and credits. Joe earned a B.S. in Accounting from Louisiana State University, a J.D. from the University of Michigan Law School, and an LL.M. (in Taxation) from New York University School of Law. After graduating from NYU, Joe worked as an Attorney-Advisor for Judge David Laro of the United States Tax Court.
Claude Edelson
Claude Edelson, CPA, MA and BS, Accounting, University of Illinois. Edelson is currently Assistant Director of Accounting Policy at the Federal Home Loan Bank of Chicago. He joined FHLBC in 2005 after working in the accounting policy field for a number of financial institutions for over 20 years.
Stephen M. Edge, Esq.Steve is a corporate tax partner at Slaughter and May where he has an extensive tax consultancy practice which includes advising on business and transaction structuring, dealing with in-depth tax investigations and tax litigation and doing a large amount of work in the transfer pricing/thin capitalisation area.
Transfer Pricing: European Rules and Practice (Portfolio 895) Bruce N. Edwards, Esq.Bruce N. Edwards, B.A., The Colorado College; J.D., University of Washington School of Law; LL.M. (in Taxation), New York University; former Law Clerk to the Honorable Shiro Kashiwa, Associate Judge, the United States Court of Claims (now the Court of Appeals for the Federal Circuit); former New Decisions Editor, The Journal of Taxation; selected as Super Lawyer, Washington Law & Politics (2005, 2004, 2003); author, “Understanding and Making the New Section 646 Election for Alaska Native Settlement Trusts,” 18 Alaska Law Review 219 (Duke University 2001); “Understanding and Using ‘Partnership Redemptions' in the Context of Section 1(h),” 45 Tax Mgmt. Memo. No. 19, 1 (Sept. 20, 2004); 568-3rd T.M., Involuntary Conversions; 594-2nd T.M., Tax Implications of Home Ownership; Tax Practice Series: Chapter 1510, Tax Free Exchanges; Chapter 1520, Involuntary Conversions; Chapter 2650, Taxation of Timber; Chapter 3880, Tax Court Litigation; Chapter 3890, Refund Litigation; Chapter 3850, IRS Audit Procedures; Chapter 3860, Statute of Limitations; member, Washington and Alaska Bars; member, American Bar Association (Section of Taxation, Committee on Court Procedure); member, American College of Tax Counsel.
Involuntary Conversions (Portfolio 568)Tax Implications of Home Ownership (Portfolio 594)Timber Transactions (Portfolio 610) Andrew Eisenberg
Andrew M. Eisenberg is a partner with Jones Day in Washington, DC and adjunct professor of Corporate Tax at Georgetown University Law. Mr. Eisenberg is a frequent contributor to BNA Tax & Accounting's Tax Management Memorandum.
William E. Elwood, Esq.William E. Elwood, B.S., Pennsylvania State University (1965); J.D., University of Pennsylvania Law School (1968); LL.M. (Taxation), Georgetown University (1975); also attended Universität zu Köln Cologne, Germany (1963) and the Hague Academy of International Law (1967); formerly Technical Attorney, Tax Court Litigation Division, Office of Chief Counsel, Internal Revenue Service (1970-1974); and associated with Lee, Toomey & Kent, attorneys, Washington, D.C. (1974-1977); Tax Counsel and subsequently Assistant General Counsel, Communications Satellite Corporation, Washington, D.C. (1977-1985); Vice President and Tax Counsel, Primark Corporation, McLean, Virginia (1985-1987); Served as National Federal Tax Chairman, Tax Executives Institute (1984-1985); Corporation Department Editor, The Tax Times (1984-1987); Articles Editor, The Tax Lawyer (1976-1980); member of the District of Columbia, Michigan and Pennsylvania Bars; American Bar Association, Section of Taxation, and Metropolitan Detroit Bar Association.
Employee Fringe Benefits (Portfolio 394) Bruce ElyBruce P. Ely, B.S., cum laude, in 1977 from the University of Alabama and his J.D. degree in 1980 from the University of Alabama School of Law. In 1981, he received his LL.M. in Taxation from New York University School of Law; past Chairman of the Tax Section of the Alabama State Bar and serves as state and local tax adviser to the 5,000 member Business Council of Alabama; state tax editor for the Business Entities Journal and a contributing editor to State Tax Notes, State Income Tax Alert, and BNA Multistate Tax Report; Fellow of the American College of Tax Counsel, member of the BNA Multistate Tax Advisory Board, Trustee of the American Institute on Federal Taxation; active member of both the Partnerships Committee and State and Local Tax Committee of the ABA's Section of Taxation. Mr. Ely was a principal author of the Alabama S Corp. Act, the Alabama LLC Act, and the Alabama LLP Act, and co-authored the ABA's Model State S Corp. Income Tax Act and The Alabama LLC Handbook; lecturer at the law schools of New York University, Georgetown University, and Vanderbilt University, and has served as an adjunct professor at the University of Alabama School of Law.
Choice of Entity: An Overview of Tax and Non-Tax Considerations (Portfolio 1550) Howard E. Engle, CPAHoward S. Engle, B.S., University of Illinois; M.S., taxation, DePaul University; partner, Deloitte Tax LLP, Chicago, Illinois; Visiting Lecturer, Graduate Tax Program, University of Illinois; frequent speaker on international tax issues; editor, International Tax Developments column, Journal of Corporate Taxation; author, numerous articles on international tax.
The Allocation and Apportionment of Deductions (Portfolio 906) Richard L. English, Esq.Richard L. English, partner, Stinson, Morrison, Hecker LLP; A.B., Washington University (1982); J.D., University of Kansas (1985); fellow, American College of Trusts and Estates Counsel; member, Missouri Bar; Estate Planning Society of Kansas City, past director; American Bar Association; Lawyers' Association of Kansas City; lecturer, Fratcher Symposium, University of Missouri-Columbia; Missouri Bar Association Probate Institute; local CLE programs; contributing author, Techniques for Estate Planning with Life Insurance (Research Institute of America).
Section 2035 Transfers (Portfolio 818) Christopher E. Erblich, Esq.Christopher E. Erblich, Esq., B.S. in Business Administration, summa cum laude, Washington University (1990); J.D., cum laude, St. Louis University School of Law (1994); chairman of the St. Louis Tax and Estate Planning practice group at Husch & Eppenberger, LLC; formerly an adjunct professor teaching Estate Planning at St. Louis University School of Law; member, Estate Planning Council of St. Louis, American Bar Association: Taxation Section, Association for Advanced Life Underwriting, Bar Association of Metropolitan St. Louis, and Civic Entrepreneurs Organization; author of “To Bury Federal Transfer Taxes without Further Adieu,” Seton Hall Law Review, Vol. 24, 1994; co-author of “Cash Values Can Reduce Interest Deductions under New Section 264(f),” Taxation Section, American Bar Association, 1998, and “Deferring Compensation with Heavenly Help,” Life Insurance Answer Book, 1998; passed Missouri CPA exam in 1990.
Estate Planning for the Corporate Executive (Portfolio 808) Joseph M. Erwin, Esq.Joseph M. Erwin, University of Arkansas, B.A. (with honors), 1976; Southern Methodist University School of Law, J.D., 1979, LL.M. (Taxation), 1980. Member of the bars of Arkansas, Texas, U.S. Virgin Islands, U.S. Tax Court, U.S. Court of International Trade, U.S. Court of Appeals for the Third Circuit, U.S. Court of Appeals for the Eighth Circuit. Private law practice, Little Rock, Arkansas, 1980-1991. Assistant Attorney General (Tax), U.S. Virgin Islands Department of Justice, 1991-1994. Private law practice, St. Thomas, 1994-1996. Tax Manager, CSC Continuum Inc., 1996-1997. Senior Manager, International Corporate Services, KPMG LLP, Austin, Texas, 1997-1998, Dallas, Texas, 1998-2000 and 2002-2003; Senior Manager, KPMG Deutsche Treuhand-Gesellschaft AG, U.S. Corporate Tax Group, Frankfurt am Main, Germany, 2000-2002.
Business Operations in the Territories and Possessions of the United States (except Puerto Rico) (Portfolio 995) Donald M. Etheridge, Jr. Esq.Donald McGee Etheridge, Jr., A.B. (magna cum laude) and J.D., Duke University; LL.M. (Taxation), Georgetown University; member of State Bar of Georgia and North Carolina Bar; member of North Carolina (Chairman, Tax Section, 1988-1989) and American Bar Associations; Certified Public Accountant (North Carolina); Senior Lecturer of Law, Duke University Law School, 1984-1994; Partner with Alston & Bird LLP, with practice concentrating in sophisticated estate planning and representation of non-profit organizations and foundations.
Private Foundations — Section 4940 and Section 4944 (Portfolio 878)Charitable Income Trusts (Portfolio 866) Pamela EversPamela S. Evers, LL.M., Environmental Law, Northwestern School of Law of Lewis & Clark University; J.D., Southern Methodist University; M.B.A., Emory University. Ms. Evers practices law in Texas and the District of Columbia. She also teaches in the Department of Accountancy and Business Law at the University of North Carolina Wilmington.
Contingent Environmental Liabilities: Disclosures and Accounting (Portfolio 5136) Ernst & Young LLPThis publication has been carefully prepared but it necessarily contains information in summary form and is therefore intended for general guidance only; it is not intended to be a substitute for detailed research or the exercise of professional judgment. The information presented in the publication should not be construed as legal, tax, accounting, or any other professional advice or service. Ernst & Young LLP can accept no responsibility for loss occasioned to any person acting or refraining from action as a result of any material in this publication. You should consult with Ernst & Young LLP or other professional advisors familiar with your particular factual situation for advice concerning specific audit, tax or other matters before making any decision.
Accounting for Income Taxes: FAS 109 (Portfolio 5000)
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Peter FaberMr. Faber is a partner in the New York City office of the law firm of McDermott, Will&Emery. He graduated from Swarthmore College with high honors and from Harvard Law School, cum laude. He has served as Chairman of the American Bar Association Section of Taxation and is a member of the Section's Committees on Corporate Taxes (of which he is a past Chairman) and on State and Local Taxes. He is a former Chairman of the New York State Bar Association Tax Section.Mr. Faber is a member of Governor Cuomo's Council on Fiscal and Economic Priorities and is Chairman of the New York Chamber of Commerce and Industry's Committee on Taxation and Public Revenue. He serves on the Board of Directors and the Executive Committee of the Chamber of Commerce. In addition, Mr. Faber has served on the Governor's Temporary Commission to Review the New York Sales and Use Tax Laws and as a member of the New York State Legislature's Tax Study Commission's Policy Advisory Group. He currently serves as a member of the New York State and City Tax Appeals Tribunals' Advisory Committees and two advisory committees to the New York State Tax Department.Mr. Faber has lectured on state and local taxation at the Georgetown University Institute on State and Local Taxation, The Interstate Tax Conference, the National Tax Association, The NYU Annual Institute on State and Local Taxation, and before many other professional groups. He is the author of many articles on state and local taxation.
Mergers and Acquisitions: Income Tax Problems (Portfolio 1520) Pascal Faes, Esq.Pascal Faes, JD, University of Ghent (1984); Special Degree in Economics, University of Brussels (V.U.B.) (1987); Master in Tax Law, University of Brussels (U.L.B.) (1991).
Business Operations Belgium (Portfolio 953) Charles E. Falk, Esq.Charles Edward Falk, B.A. (in economics), University of Kansas (1970); M.S. (in accounting), The University of Virginia (1976); J.D., Washington and Lee School of Law (1979); LL.M. (in taxation), New York University School of Law (1981); LL.M. in Corporation Law (Bankruptcy and Securities Laws), New York University School of Law (1991); Principal, Mortenson and Associates, Cranford, N.J.; member, New Jersey and Virginia Bars; Certified Public Accountant, New Jersey and Virginia; author, Tax Management Portfolio, Tax Planning for the Development and Licensing of Patents and Know–How, No. 557.
Tax Planning for the Development and Licensing of Patents and Know-How (Portfolio 557)Tax Planning for the Development and Licensing of Copyrights, Computer Software, Trademarks and Franchises (Portfolio 558) George A. Famalett
George Famalett currently serves as Tax Partner at PricewaterhouseCoopers in San Jose, CA. He specializes in state and local taxation for Fortune 500 companies.
George Farrah, CPA, Executive Editor, State Tax and Accounting
George Farrah joined BNA in 1988, developed the State Tax Portfolios, the Weekly State Tax Report, and the Multistate Tax Report, which launched in 1994. He also developed BNA's State Tax Library, which launched in April 2000. More recently, he developed the Accounting Policy & Practice Report. Prior to joining BNA, George worked as a CPA in both the public and private sector. George received a B.S. degree in accounting from the University of Connecticut and an M.S. in Taxation from Georgetown University.
Laura Farrell-LegrandMs. Farrell is a senior manager with Ernst & Young. She is a Practice Leader for the firm's California State and Local Tax Group and serves as the firm's California State Tax Coordinator. She received her B.S. from Boston University, Summa Cum Laude, and M.S. (Taxation) from Bentley College.
Income Taxes: Consolidated Returns and Combined Reporting (Portfolio 1130) Lawrence FeeLawrence H. Fee, B.A., University of Illinois at Chicago (1976); J.D., John Marshall Law School (1980); LL.M., John Marshall Law School (1984); Editorial Advisory Board, Journal of Property Tax Management; Member: Chicago Bar Association, State and Local Tax Committee, Federal Communications Bar Association.
Sales and Use Taxes: Services (Portfolio 1310) Suzanne C. Feese, Esq.
Suzanne C. Feese, B.A., Agnes Scott College - 1984; J.D., Yale University - 1987; member Georgia Bar, ABA.
Steven Felgran
Steven D. Felgran, Ph.D., is a member of KPMG LLP's global transfer pricing services practice and is a principal with the firm's offices in Boston and New York.
Robert A. Ferencz, Esq.Robert A. Ferencz, B.S., University of Illinois (1968); J.D., University of Michigan Law School (1973, magna cum laude, Order of the Coif, associate editor, Michigan Law Review); Certified Public Accountant; member of the Tax Section of the American Bar Association; member of the Illinois Bar.
Qualified Plans — Investments (Portfolio 377) Brett Ferguson
Brett Ferguson began covering tax legislation for the Daily Tax Report in 2007 after six years as an economics and Treasury Department reporter at BNA. He has been with BNA since 1999 and previously reported on commodities futures markets in Chicago. Brett is a graduate of Northern Illinois University, where he majored in both economics and journalism.
Jayson L. FernandezJayson L. Fernandez, A.B. (1991) and J.D. (1995), second honors, Ateneo de Manila University; Senior Associate, specializing in taxation, Romulo, Mabanta, Buenaventura, Sayoc & de los Angeles and member, Tax Management Association of the Philippines.
Business Operations the Philippines (Portfolio 978) Joseph L. Ferst, CPA
Joseph L. Ferst, B.S., State University of New York atBinghamton, 1975; Service Line Leader, National Federal TaxServices, Deloitte Tax LLP, Atlanta, Georgia; member AICPA,NYSSCPA, NAREIT, ULI; speaker on real estate, partnershipand financial instruments tax issues; author, books andarticles on real estate, partnership, and financialinstruments taxation, including contributions to BNA RealEstate Journal, Real Estate Investment Trusts Handbook, TheHandbook of Commercial Mortgage-Backed Securities, TheAppraisal Journal, Journal of Real Estate Taxation, andJournal of Taxation of Financial Institutions publications.
Karen Fickes, Managing Editor, U.S. Income Portfolios
Karen is Managing Editor of the U.S. Income Group. As such, she is responsible for the U.S. Income Series Portfolios dealing with individual income taxation, the Real Estate Series Portfolios, Natural Resources Portfolios, and Green Incentives Navigator. Karen received her B.B.A. from the University of Texas, J.D. from the University of Arkansas, and LL.M. in taxation from the University of Florida.
J.P. Finet
J.P. Finet, a graduate of the Moritz College of Law at the Ohio State University, served as news editor for Ohio Lawyers Weekly and as a legislative analyst for the Michigan Senate Fiscal Agency before joining BNA in 2006. As the Daily Tax Report’s senior legal editor, he covers tax rulings from the state and federal courts, with an emphasis on federal tax issues before the federal courts of appeal and the U.S. Supreme Court. He also has written for daily newspapers in Ohio, Indiana, and Arizona. He holds a Bachelor of Arts I from the Ohio State University School of Journalism.
Felicia A. Finston, Esq.Felicia A. Finston, Arizona State University (B.S. in Personnel Management, magna cum laude, 1982); University of Utah (M.S. in Human Resource Management, with honors, 1983); University of New Mexico School of Law (J.D., with honors, 1986); member, State Bar of Texas, Dallas Bar Association, State Bar of Arizona, Maricopa County Bar Association, American Bar Association, and SouthWest Benefits Association.
Plan Qualification — Pension and Profit-Sharing Plans (Portfolio 351) Robert B. Fleming, Esq.
Robert B. Fleming; President of the National Elder Law Foundation; member of the Board of Directors of the National Academy of Elder Law Attorneys; certified as an Estate and Trust specialist by the State Bar of Arizona, and by the National Elder Law Foundation as a Certified Elder Law Attorney; was President of the Pima County Bar Association and the Young Lawyers Section of the State Bar of Arizona; co-author (with Lisa Davis) of The Elder Law Answer Book, and (with Prof. Kenney Hegland) of Alive and Kicking: Legal Advice for Boomers; has been selected as a fellow of both the American College of Trust and Estate Counsel and the National Academy of Elder Law Attorney; past Chair of both the Mental Health and Elder Law and the Probate and Trust Sections of the State Bar of Arizona; is currently a partner in the Tucson law firm of Fleming & Curti, P.L.C., with a practice limited to trust (and special needs trust) administration, guardianship, conservatorship, estate planning, and probate.
Sean Foley
Sean Foley is a member of KPMG's global transfer pricing services practice. Foley, a principal in charge of the practice, is with KPMG LLP in Washington, D.C.
Sean Forbes
Sean Forbes is a BNA staff correspondent for the Weekly Report.
James W. Forsyth, Esq.James W. Forsyth, B.S. (summa cum laude), West Liberty State College (1983); J.D. (Order of the Coif), West Virginia University College of Law (1986); LL.M. (Taxation), University of Florida College of Law (1989); admitted to practice in Pennsylvania and West Virginia; member, American Bar Association, Section of Taxation, Committee on Partnerships; member, Allegheny County and Pennsylvania Bar Associations; member, West Virginia Bar Association; certified public accountant (1988); member, American Institute of Certified Public Accountants; member, West Virginia Society of Certified Public Accountants; adjunct lecturer, West Virginia University College of Law (1993-2001).
Stock Rights and Stock Dividends — Sections 305 and 306 (Portfolio 765) Sharon Fountain, Esq.
Sharon F. Fountain, Esq. is a Managing Editor for Compensation Planning at BNA Tax & Accounting, and a contributing editor for the Weekly Report.
Carol Ann Fowler, Esq.Carol Anne Fowler (deceased), B.A., Duke University; Phi Beta Kappa; J.D. (with distinction), Emory University School of Law; Order of the Coif and Comments Editor for the Emory Law Journal; former member of the State Bar of Georgia, American and Atlanta Bar Associations, American Academy of Hospital Attorneys, and National Health Lawyers Association; former associate at Sutherland, Asbill & Brennan LLP, practicing in the areas of tax-exempt organizations and health care law, including planning and reporting for public charities and private foundations.
Private Foundations — Section 4940 and Section 4944 (Portfolio 878) Dorine Fraai
Dorine Fraai is a senior tax manager for Horlings in Amsterdam, the Netherlands. Dorine works primarily in international tax law and has a diverse practice, focusing on international structures and foreign companies investing in the Netherlands and Dutch companies investing in different jurisdictions. She has more than 12 years of experience in international tax firms and has worked for various tax law firms. Dorine publishes articles on a regular basis for BNAI’s Tax Planning International Review regarding various issues, such as the Dutch co-operative in international holding structures. Additionally, she coordinates an international tax publication for Nexia International, which is a worldwide network of independent auditors, business advisors and tax consultants. On occasion, Dorine organises and speaks at a number of tax conferences on Dutch tax issues for an international audience.
Lawrence Frank
Lawrence A. Frank is the Publications Editor for BNA's International Journal and Weekly Report.
Maibrit Frebel
Dr. Maibrit Frebel is with PricewaterhouseCoopers AG in Frankfurt am Main, Germany, and is a frequent contributor to BNA's International Journal.
Diane Freda
Diane Freda has worked for newspapers and newsletters over a 15-year reporting career in which she covered regulation and legislation affecting the Wall Street securities markets, and as a local government reporter. She has been with BNA since 2005, specializing in tax-exempt organizations, regulations affecting tax practitioners, and taxpayer issues such as private debt collection. She is a graduate of William and Mary, Williamsburg, Va.
Jose Luis de Salles Freire, Esq.José Luis de Salles Freire, partner, TozziniFreire, Teixeira e Silva Advogados, São Paulo, Brazil; University of São Paulo School of Law (LL.B., 1971); Southwestern Legal Foundation (Academy of American and International Law, 1975) and New York University School of Law (M.C.J., 1976). Member of the Advisory Board of the International and Comparative Law Center of the Southwestern Legal Foundation.
Business Operations Brazil (Portfolio 954) Anjanette T. Frias, Esq.Anjanette T. Frias, B.A. (cum laude), Creighton University (1993); J.D., Emory University School of Law (1996); member, Tennessee Bar Association (1996-2002); co-author, “Consolidated Return Election Offers Tax Advantages—With Complexity,” Tax Strategies (Sept. 2001); Ernst & Young, LLP (1996-2001); Responder, Mergers & Acquisitions Segment, Ernst & Young's Online Tax Advisor (2001-2003).
Corporate Overview (Portfolio 750)Dividends — Cash and Property (Portfolio 764) Lois Fried, CPPLois Fried, CPP, works as a senior client educator for Automatic Data Processing, Inc., (ADP) in San Francisco, Calif. She helped the American Payroll Associaition early on with lobbying efforts in Washington, D.C.
Payroll Library David B. Friedel, Esq.David Friedel, LL.M., in Taxation, from Georgetown University; J.D. (magna cum laude) from the American University Washington College of Law; B.S. in Economics from the University of Pennsylvania Wharton School of Business and a B.S.E. from the University of Pennsylvania School of Engineering and Applied Science. Member of the District of Columbia and Virginia State bar associations. Formerly Attorney/Advisor, Office of Chief Counsel, Internal Revenue Service.
Earnings and Profits (Portfolio 762) Mark FrigoDr. Mark L. Frigo is the Director of The Center for Strategy, Execution, and Valuation in the Kellstadt Graduate School of Business. Dr. Frigo is also a Ledger & Quill Alumni Foundation Distinguished Professor of Strategy and Leadership in the School of Accountancy at DePaul University. He received his B.S. in Accountancy from the University of Illinois and an MBA in Accountancy from Northern Illinois University. He completed postgraduate studies in the Kellogg Graduate School of Management at Northwestern University. Dr. Frigo received his Ph.D. in Economics and Econometrics from Northern Illinois University. He is a CPA (Certified Public Accountant), a CMA (Certified Management Accountant), and a leading expert in strategy design and execution and the Balanced Scorecard. He is an advisor to executive teams and boards of directors. He also has extensive experience as a management consultant with KPMG and in the corporate sector where he was responsible for strategic planning. He has served as a principal researcher for the Institute of Management Accountants (IMA) for its performance measurement surveys and field-based research, which was published in Strategic Finance and the Harvard Business School Press Balanced Scorecard Report. He is the editor of the Strategic Management section of Strategic Finance.Dr. Frigo intensively researched the role of internal auditing in corporations and has written three research monographs for the Institute of Internal Auditors Research Foundation including “A Balanced Scorecard Framework for Internal Auditing Departments.” Dr. Frigo was presented the Economics Award for Outstanding Teaching in the Kellstadt Graduate School of Business at DePaul University and was the recipient of the Illinois CPA Society Outstanding Educator Award. The author of five books and over 60 articles, his work is published in leading business journals including Harvard Business Review.
Using the Balanced Scorecard Framework (Portfolio 5304) George FritzGeorge P. Fritz, A.B. (magna cum laude), Xavier University. Mr. Fritz is a retired partner with PricewaterhouseCoopers LLP. Since retiring in 1999, he has served as a consultant, primarily to professional accounting organizations, including the Public Oversight Board, the Panel on Audit Effectiveness, and the American Institute of Certified Public Accountants (AICPA). He was a member of the AICPA's Accounting Standards Executive Committee (AcSEC) from 1991 to 1996 and the Auditing Standards Board from 2004 to 2007. He chaired several AcSEC task forces, including one on software revenue recognition. Mr. Fritz also participated in the“Generally Accepted Accounting Principles” (GAAP) Codification project of the Financial Accounting Standards Board.
Revenue Recognition: Software (Portfolio 5103) Edward FroelichEdward L. Froelich, B.A., Thomas Aquinas College (1988); M.A., Philosophy, Catholic University of America (1991); J.D., University of Virginia School of Law (1994); LL.M., Taxation, Georgetown University Law Center (1999); member, Maryland and District of Columbia Bars; Admitted U.S. Tax Court, U.S. Court of Federal Claims; Chair-elect, Section of Taxation, Federal Bar Association, Co-editor, FBA Section of Taxation Report (2004-2006); ABA Section of Taxation; clerk for the Hon. John P. Wiese, Senior Judge, U.S. Court of Federal Claims (1994-1995); trial attorney, Tax Division, U.S. Department of Justice (1995-1999).
The Section 7525 Tax Practitioner-Taxpayer Privilege and Related Issues (Portfolio 5511) Francois Froment-Meurice
Richard C. Fung, Esq.Richard C. Fung, Amherst College (B.A., cum laude, 1991); Columbia University School of Law (J.D. 1994); Associate, Skadden, Arps, Slate, Meagher & Flom LLP (1994-2001); Senior Manager, Ernst & Young LLP, National Office West, Mergers & Acquisitions; contributing author, Practising Law Institute: Tax Strategies for Corporate Acquisitions, Dispositions, Spin-Offs, Joint Ventures, Financings, Reorganizations & Restructurings (2001).
Personal Holding Companies (Portfolio 797)
G
William Galanis, Esq.William Galanis, LL.M., in Taxation, (with distinction), from Georgetown University; J.D. from the Columbia School of Law, Catholic University; B.S. in Accounting, (cum laude) from Mt. St. Mary's College. Member of the District of Columbia and Maryland State bar associations. Formerly Attorney/Advisor, Office of Chief Counsel, Internal Revenue Service.
Earnings and Profits (Portfolio 762) Maryann GallMaryann B. Gall is a tax partner with Jones, Day, Reavis & Pogue, resident in the Columbus, Ohio office. Mrs. Gall's practice is concentrated in the areas of state and local taxation with emphasis on tax litigation. She graduated from The Ohio State University in 1967 and received her law degree from OSU's College of Law in 1970, with honors. Mrs. Gall was an Assistant Attorney General in the Taxation Section of the Ohio Attorney General's Office from 1971 until 1974, when she was appointed Chief of the Taxation Section. When she represented the Ohio Tax Commissioner, she argued over 50 cases before the Supreme Court of Ohio. From 1975 to 1976, she was Chief Counsel to the Ohio Attorney General. Thereafter, she has been in private practice, and since 1983, has been a partner at Jones Day, specializing in state tax matters. She is the editor of Banks Baldwin Law Publishing Company's Ohio Tax Service, a quarterly Ohio tax publication, and serves as the editor of the Taxation Chapter (Title 57) of the Ohio Revised Code. Mrs. Gall is a member of the CCH State Tax Advisory Board, the Board of the New York University Institute on State & Local Taxation, and the National Institute on State & Local Taxation. She is a frequent lecturer for the Committee on State Taxation, the Institute of Property Taxation, and Tax Executives Institute.
Limitations on States' Jurisdiction to Impose Sales and Use Taxes (Portfolio 1420)Recovery of Attorney's Fees State Tax Controversies (Portfolio 1590) Gregory W. Gallagher, Esq.Gregory W. Gallagher, University of Illinois College of Law, J.D., 1997 summa cum laude, Order of the Coif, Harno Fellow; Associate Editor, Law Review; University of Illinois, B.S., 1994 University Honors (Bronze Tablet). As a partner in Kirkland's Chicago tax group, Gregory W. Gallagher's area of practice focuses on transactional matters at the federal and state levels. In the federal tax area, Mr. Gallagher has been involved in a wide variety of matters, including mergers and acquisitions, spin-offs, executive compensation, debt restructurings, bankruptcies and tax controversies before the IRS and U.S. Tax Court. He has obtained rulings from the Internal Revenue Service with respect to numerous transactions. At the state level, he advises clients with respect to nexus issues and has been involved in audits and litigation involving state income tax and sales and use tax issues. Mr. Gallagher was mentioned in the article, Big Suits: UAL Bankruptcy for his role in UAL Corp.'s bankruptcy filing. He was also Adjunct Professor at IIT/Chicago-Kent College of Law, "Corporate Tax" (2005 - 2006). Gallagher is a frequent lecturer at seminars and conferences, including Tax Executives Institute and Practising Law Institute. He is author and co-author of various publications and articles including "Partnership Joint Ventures of Operating Business," Tax Planning for Domestic & Foreign Partnerships, LLCs, Joint Ventures & Other Strategic Alliances 2005 (published annually) and "INDOPCO - The Treasury Finally Acts," 80 Taxes 47 (March, 2002).
Start-Up Expenditures (Portfolio 534) Carlo GalliCarlo Galli was admitted as CPA in 1996. After having worked with the International Bureau of Fiscal Documentation (IBFD), he joined Maisto e Associati in 1995. He headed the London office of the firm between 1998 and 2000 and is now based in Milan. Mr. Galli specializes in tax planning for multinational groups, M&A transactions, and capital markets.
Transfer Pricing: European Rules and Practice, Part 2 (Portfolio 896) John A. Galotto, Esq.John A. Galotto, B.A., Johns Hopkins University (1988); J.D., Columbia Law School (1993); Senior Editor, Columbia Law Review; Trial Attorney, U.S. Department of Justice, Tax Division, Civil Trial and Criminal Enforcement Sections, 1995-2000; Special Assistant U.S. Attorney, District of Columbia, 1999; Law Clerk to U.S. District Court Judge Edward Rafeedie, Central District of California, 1993-1994; co-author: “Right To Counsel: Courts Adhere to Bright-Line Limits,” ABA Criminal Justice Magazine, Summer, 2001 at 4; co-author, “Sensible Decision on Admissibility of Witness Guilty Pleas Repudiated in Third Circuit, but Dissenters Offer Hope in Other Circuits,” White Collar Crime Reporter, June/July 2000, at 1; co-author, “The COSO Report on Internal Control: Implications for Public Companies and Executives,” Insights, August 1993, at 29; member, American Bar Association, Section of Taxation, Committee on Court Procedure; member, bars of the District of Columbia, New York and Illinois.
Obtaining Information from the Government — Disclosure Statutes (Portfolio 625) Samir Gandhi
Samir Ghandi, Bachelor of Commerce, University of Mumbai, India; Fellow Member of the Institute of Chartered Accountants of India; co-authored publications on Transfer Pricing Law and Practice in India by CCH, BNA and IBFD and contributed to several articles on transfer pricing and international taxation in International Tax Review and BNA Tax Management and in other Tax Journals and Financial Dailies. Partner, Transfer Pricing, Deloitte Transfer Pricing group in Mumbai, India.
James M. Gannon, CPAJames Gannon, B.S., University of Illinois; B.A., accountancy, M.A., public accounting-tax, University of Texas at Austin; tax partner, Washington International Tax Group, Deloitte Tax LLP, 2002–present; partner, Arthur Andersen, 1998-2002, staff, Arthur Andersen, 1987-1998; member, AICPA and Illinois Society of CPAs.
The Allocation and Apportionment of Deductions (Portfolio 906) Mitchell M. Gans
Before joining the Hofstra faculty, Professor Gans had been an associate in the Tax and Trust and Estates Departments at the New York City law firm of Simpson, Thacher & Bartlett and law clerk to Associate Judge Jacob D. Fuchsberg, New York State Court of Appeals. He is an Academic Fellow at the American College of Trust and Estate Counsel. He is also an Adjunct Professor of Law at the NYU School of Law. Professor Gans is a leading scholar in the estate-and-gift tax area. On behalf of the NYU School of Law, he recently taught an eight-week course on valuation methodology by satellite television to IRS attorneys throughout the country. Gans continues to provide lectures for the IRS on transfer- and income-tax issues. He is a frequent lecturer for ALI-ABA, NYU, the American College of Trust and Estate Counsel, the ABA and other groups. Professor Gans has published articles in the Emory Law Journal, Notre Dame Law Review, Virginia Tax Review, Florida Tax Review and Tax Notes, among others.
Marc D. Ganz, J. D. LL. M.Marc D. Ganz, B.A., University of Wisconsin - Madison (1991); J.D., A.C. in International Affairs, Washington University (1994); LL.M. in Taxation, New York University (1995); formerly Attorney-Advisor to the Honorable William M. Fay, U.S. Tax Court, Washington, D.C.; Member of the New York Bar; Member of the Telecommunications Tax Forum.
U.S. International Taxation of Telecoms (Portfolio 946) Lauren Gardner
Lauren Gardner, who joined BNA in 2008, covers corporate tax, domestic tiered issues, IRS administration, tax credits, passthrough entities, real estate, and insurance for Daily Tax Report. She earned a B.A. in Foreign Language and Communication Media (French and Print Journalism) and a B.A. International Studies from the American University, Washington, D.C.
Karen Garre-Lohnes, Esq.Karen Garre-Lohnes, B.S., Accounting, Louisiana State University; J.D., summa cum laude, Boston University School of Law; Editor, Boston University Law Review; member, ABA Partnership Tax Committee; author, articles published in International Tax Journal, University of Southern California Tax Institute's Major Tax Planning, The Tax Advisor.
Limited Liability Companies (Portfolio 725) Joanne GarveyMs. Garvey received an A.B. with honors (1956) and an M.A. (1957) from the University of California, Berkeley. She received her J.D. in 1961 from Boalt Hall (University of California, Berkeley). Ms. Garvey specializes in state and local taxation. She has represented clients at all administrative levels, as well as in court and has been involved in numerous tax and business transactions, nationally and internationally, for domestic and foreign clients. Ms. Garvey has assisted in matters of tax legislation, particularly the California water's–edge legislation, and has testified at numerous legislative hearings in the State of California, as well as prepared testimony for clients at both the state and federal levels. Ms. Garvey was lead counsel for the taxpayer in Barclays Bank Ltd. v. California Franchise Tax Board, 512 U.S. 298 (1994). Ms. Garvey has also authored several amicus curiae briefs before the United States Supreme Court on issues of state taxes.She is a member of the Tax Sections of the American and California Bar Associations, the State Bar of California and the American Law Institute. Ms. Garvey was Governor of the State Bar of California from 1971 to 1974 and served as Vice President in 1973–74. She was chair of Law in a Free Society, a national civic education program, and the Governing Board of the California Continuing Education of the Bar. She served as President of the Bar Association of San Francisco in 1981. She is a Governor of the American Bar Association and the former California State Delegate to the House of Delegates of the America Bar Association and a Fellow of the American Bar Foundation. She is the first recipient of the Joanne Garvey award of the California State Bar Tax Section for lifetime achievement. She is listed in Who's Who in America and Best Lawyers of America. Ms. Garvey thanks Joan K. Irion of Heller, Ehrman, White & McAuliffe, Los Angeles, California, for her valuable assistance and contributions, as well as David Rakonitz and Richard Yee of Heller, Ehrman, White & McAuliffe, San Francisco, for their assistance.
California Water's-Edge Election for Unitary Reporting (Portfolio 1940) Daniel T. GaryDaniel T. Gary is a partner in KPMG's Transaction Services practice, focusing on accounting for valuation-related events such as acquisitions, impairments and fresh start accounting for emergence from bankruptcy. He also is deeply experienced with the requirements of registrants with the Securities Exchange Commission. In his full-time role as a service delivery partner, he is closely involved with a wide range of technical issues as well as operational challenges involving implementation of new standards. Dan's prior tenures as an auditor and a corporate controller enable his understanding of all aspects of an issue. He speaks frequently on accounting for business combinations and has been published and quoted in numerous publications. Brian Heckler, David Hori and Michele Meadows from KPMG LLP Transaction Services provided valuable insights and practical examples in the development of this Portfolio. Their contributions and perspectives are gratefully acknowledged.
Business Combinations (Portfolio 5170) Richard W. GenetelliRichard W. Genetelli is the founder of The Genetelli Consulting Group, a state and local tax consulting firm located in New York City. Prior to forming the firm, Mr. Genetelli spent 20 years with Coopers & Lybrand, where he served as a national and regional leader of the firm's state and local tax practice.Mr. Genetelli is a graduate of Pace University, where he also earned a Master of Business Administration degree. He is a member of many tax organizations and serves on the Advisory Boards of BNA Tax Management, New York University, the Multistate Tax Analyst, and the Journal of State Taxation. Mr. Genetelli has authored numerous articles regarding state and local taxation for the New York Institute on State and Local Taxation, the American Institute of Certified Public Accountants, and the American Trucking Association. His articles have also been published in BNA Tax Management's Multistate Tax Report, the CPA Journal, the Journal of State Taxation, the Journal of New York Taxation, Financial Executive, Payroll Exchange, RIA State and Local Taxes Weekly, and Boardroom Reports.Qualified as an expert witness, Mr. Genetelli testifies on behalf of taxpayers litigating state and local tax issues throughout the country. He is also a professor of graduate and undergraduate courses at the Lubin School of Business, Pace University, and a frequent lecturer on state and local taxes across the country. Mr. Genetelli regularly speaks for Tax Executives Institute, the Council on State Taxation, the New York State Society of Certified Public Accountants, the American Institute of Certified Public Accountants, New York University, and the New York State Business Council.
Personal Income Taxes: Alabama Through Michigan (Portfolio 3010)Personal Income Taxes: Minnesota Through Wyoming (Portfolio 3020) Thomas Gierath
Thomas Gierath is a partner in the Munich office of Dechert LLP. His practice covers all areas of domestic and international taxation.
Mr. Gierath focuses his practice primarily in the structuring and negotiating of domestic and cross-border private equity and M&A transactions including post-closing reorganizations, recapitalizations and exits whether on the sellers' or on the buyers' side. He is experienced in structuring management participations in venture capital investments and in buy-out transactions.
Timothy GillisTim Gillis practices in the Atlanta office of Sutherland, Asbill & Brennan in the area of federal, state, and local taxation, with considerable work in the tax controversy and litigation areas. Prior to attending law school, Mr. Gillis practiced as a CPA in the Atlanta office of a Big 6 accounting firm. Mr. Gillis received his B.S. in accounting, summa cum laude, from Pensacola Christian College in 1985. He received his J.D., magna cum laude, from the Georgetown University Law Center in 1991. At Georgetown, Mr. Gillis was a member of the Order of the Coif, served on the Georgetown Law Journal, and received the Tamm Memorial Award for his note entitled, “Collecting the Use Tax on Mail–Order Sales.”Mr. Gillis has written a number of articles in the multistate tax area, including ones published in International Legal Strategy and The Atlanta Lawyer. In addition, Mr. Gillis is a co–author of the Georgia chapter of the ABA Sales and Use Tax Deskbook. Mr. Gillis is a member of the State and Local Tax Committee of the American Bar Association's Tax Section and has taught Tax Accounting Methods as an adjunct professor in the Emory Law School's LLM program. He has also lectured on various topics in taxation at various continuing education seminars.
State Taxation of Service Providers (Portfolio 1820) John Gimigliano
B.A., Miami University of Ohio; J.D., University of Cincinnati; LL.M.(Taxation), Georgetown. Professor Gimigliano is Principal-In-Charge of Americas Climate Solutions and Energy Sustainability Tax Practice. Prior to that, he was the Senior Tax Counsel for the Committee on Ways and Means, where he focuses on issues involving energy, cost recovery, accounting methods, tax credits, corporate reorganizations, the corporate alternative minimum tax, net operating losses and several other areas. Since joining the Committee in 2005, Professor Gimigliano has served as lead tax counsel on the Energy Policy Act of 2005 and has played a central role in hurricane relief legislation and in the enactment of the Tax Increase and Prevention Reconciliation Act (TIPRA). Prior to joining Ways and Means hew was a member of Ernst & Young’s tax practice for 11 years and from 2001 to 2005 he was National Director of Ernst & Young's Electric and Gas Energy tax practice. He has been a frequent speaker at industry tax conferences and has published a number of articles related to energy and utility taxation.
Nadine Gjurich, Esq.
Nadine Gjurich, Esq. is a State Tax Law Editor at BNA Tax and Accounting.
David Glad
David M. Glad, also an associate with the firm's Commercial Litigation Group, represents business clients in a wide range of complex matters. Mr. Glad is a certified public accountant and a member of the Allegheny County Bar Association and the American and the Pennsylvania Institutes of Certified Public Accountants. He received a B.S. in accounting from Duquesne University and a J.D. from Cornell University.
Alan GlazerAlan S. Glazer, A.B., Franklin & Marshall College; M.A. and Ph.D., University of Pennsylvania, served as associate director of the Independence Standards Board's conceptual framework project and has written several articles on auditor independence and accounting ethics. Dr. Glazer is the co-author (with Martha L. Benson) of BNA Tax and Accounting Portfolio 5201, Accounting for Museums (Accounting Policy and Practice Series). He has been teaching financial accounting at Franklin & Marshall College, Lancaster, Pennsylvania, since 1975, where he is the Henry P. and Mary B. Stager Professor of Business. Dr. Glazer's book, Accounting for Museum Collections and Contributions of Collection Items, co-authored with Dr. Henry Jaenicke, Drexel University, was published by the American Association of Museums. Dr. Glazer also assisted in drafting the audit and accounting guide, Not-for-Profit Organizations, for the American Institute of Certified Public Accountants. Dr. Glazer is a member of the American Association of University Professors, the American Accounting Association, and the American and Pennsylvania Institutes of Certified Public Accountants. He serves on the editorial board of the Journal of Accountancy and is a CPA in Pennsylvania.
Accounting for Museums (Portfolio 5201) Brian S. Gleicher, Esq.Brian S. Gleicher, B.S., University of Florida, Fisher School of Accounting (with high honors, 1992); J.D., Georgetown University Law Center (cum laude, 1995). Lead Articles Editor, Tax Lawyer (1995); Chairman of the Federal Bar Association Section of Taxation (2002-2003); Chairman of the Federal Bar Association Section of Taxation's 26th Annual Tax Law Conference (2001); Editor-in-Chief of the Federal Bar Association Section of Taxation Tax Report (1997-2000); Member of the American Bar Association and the District of Columbia and Florida Bars.
IRS Procedures: Examinations and Appeals (Portfolio 623)Transfer Pricing: Records and Information (Portfolio 891) Peter A. Glicklich, Esq.Peter A. Glicklich is a partner resident in the New York office of Davies, Ward, Phillips & Vineberg LLP. His practice is concentrated on the taxation of corporate and international transactions. He advises public and closely held corporations in connection with mergers and acquisitions, cross-border financings, restructurings, reorganizations, spin-offs and intercompany pricing. Mr. Glicklich has dealt with companies in diverse fields, including chemicals, consumer products, real estate, biotechnology, software, telecommunications, pharmaceuticals and finance. As well he has worked with venture funds, investment banks, hedge funds, commodities and securities dealers and insurance companies. He is a contributing editor of the Tax Management International Journal, the Canadian Tax Journal, the Journal of Taxation of Global Transactions, and the International Tax Review, and is a former contributing editor of the Journal of Real Estate Taxation.Mr. Glicklich has written numerous articles on cross-border financing, net loss carryovers, bankruptcy restructurings, the use of conduits, transfer pricing, loss importation, and taxation of internet activities. He also speaks frequently on international and corporate tax topics. Mr. Glicklich presently serves as the New York Regional Vice-President and an Executive Committee member of the USA Branch of the International Fiscal Association, and he is a past Secretary of that Committee. He is also a member of numerous bar associations. Mr. Glicklich received an honors degree from the University of Wisconsin - Madison in 1977 and received his J.D. cum laude from Harvard Law School in 1981.
U.S. Taxation of International Shipping and Air Transport Activities (Portfolio 945) Jeffrey GlickmanJeffrey C. Glickman is an associate in Alston & Bird's State and Local Tax Practice Group. His practice focuses on corporate mergers and acquisitions and multistate tax planning. Mr. Glickman is a frequent author and speaker on state tax topics involving constitutional issues relating to multistate income and sales and use taxation, taxation of passive investment companies, and the state tax aspects of mergers and acquisitions. He has authored or contributed to articles appearing in State Income Tax Alert, Mergers and Acquisitions, and the Journal of Multistate Taxation, and is a production editor for The State and Local Tax Lawyer. Mr. Glickman also serves as an adjunct professor at Emory Law School. Mr. Glickman received his LLM in Taxation (1999) and J.D. (1998) from New York University School of Law. Mr. Glickman received his B.S. (1995), with distinction, from Cornell University. He is a member of the Tax Sections of the State Bar of Georgia, Atlanta Bar Association, and American Bar Association.
Georgia Corporate Taxes (Portfolio 2050) Nancy J. Glover, CPA Esq.Nancy J. Glover, B.S., magna cum laude, University of Utah (1985); M.S.T., DePaul University (1992); J.D., Chicago-Kent College of Law (1998); member, American Institute of Certified Public Accountants and the Illinois Institute of Certified Public Accountants; frequent guest speaker, Tax Executives Institute, Inc. (TEI), FSC/DISC Tax Association, Inc. (FDTA), and Council for International Tax Education (CITE).
Section 199: Deduction Relating to Income Attributable to Domestic Production Activities (Portfolio 510) Joseph R. Goeke, Esq.Joseph R. Goeke, Xavier University, B.S. (1972); University of Kentucky, J.D. (1975); former Special International Trial Attorney, Internal Revenue Service; frequent lecturer, including Tax Executives' Institute, World Trade Institute, Georgetown University Law Center, National Foreign Trade Council, and International Fiscal Association; member, American Bar Association, Section of Taxation; admitted to practice, Kentucky, Illinois, U.S. District Court for the Northern District of Illinois, U.S. Court of Federal Claims, and U.S. Tax Court.
Transfer Pricing: Records and Information (Portfolio 891) Sandra M. GoldbergSandra Goldberg, LL.B., University of Ottawa, 1982; Associate Partner, Deloitte & Touche LLP, Ottawa, Ontario; member Law Society of Upper Canada since 1984, Canadian Tax Foundation, International Fiscal Association; speaker on transfer pricing issues; author, articles on transfer pricing, competent authority and permanent establishments; named in Euromoney’s 2008 list of World’s Leading Transfer Pricing Advisors.
U.S. Income Tax Treaties — Competent Authority Functions and Procedures of Selected Countries (Portfolio 941) Sanford H. Goldberg, Esq.
Sanford H. Goldberg; J.D. and Kent Scholar, Columbia University; magna cum laude graduate, Wharton School of the University of Pennsylvania; past President of the USA branch of the International Fiscal Association and Vice President of its worldwide parent; an elected member of the International Academy of Estate and Trust Law and the Society of Trust and Estate Practitioners; edits the International Tax sections of the Journal of Taxation and the Canadian Tax Journal; has taught at the NYU Masters in Taxation Program; on the advisory boards at Florida Law School and Fordham University; Fellow of the American College of Tax Counsel; named in The Best Lawyers in America; widely recognized for providing tax and estate planning to U.S. and non-U.S. individuals and families, working with multiple-country heirs andbeneficiaries, dual wills, foreign trusts and other foreign entities; has represented clients in executive compensation negotiations and functions regularly in the capacity of independent counsel to key officers in order to avoid a conflict of interest between general counsel and the corporation.
William GoldmanMr. Goldman is a partner in the Tax Department of McDermott, Will & Emery's Washington, D.C. office, where he practices in federal and state tax controversy matters, including both administrative representation and litigation. He was chairman of the Committee on Affiliated and Related Corporations of the American Bar Association's Tax Section and has lectured and written articles on a wide variety of tax topics. After serving in the United States Army, Mr. Goldman was an attorney in the Appellate Section, Tax Division, of the U.S. Department of Justice (1968–1972). He then went into private practice in Washington, D.C., with the law firm of Lee, Toomey & Kent (which merged with McDermott, Will & Emery in 1994). Mr. Goldman received his bachelor's degree from Cornell University in 1962, and graduated, cum laude, from Harvard Law School in 1965. He was admitted to the Bar of the State of New York in 1965 and the District of Columbia Bar in 1972.
Income Taxes: Consolidated Returns and Combined Reporting (Portfolio 1130) Stuart J. Goldring, Esq.
Stuart J. Goldring, B.B.A., University of Michigan, 1979; J.D., University of Michigan Law School, 1982; LL.M. (in Taxation), New York University School of Law; Partner, Weil, Gotshal & Manges LLP, New York, New York; adjunct professor, New York University Law School; member, New York Bar, ABA, New York State Bar Association (serve on Executive Committee of the Tax Section, and co-chair of Committee on Bankruptcy and Losses), Association of the Bar of the City of New York; co-author, Tax Planning for Troubled Corporations: Bankruptcy and Nonbankruptcy Restructurings (CCH 2009); author of numerous articles, and speaker, on trouble company and restructuring tax issues.
Deborah J. Goldstein, Esq.
Deborah J. Goldstein, A.B., Princeton University, 1974; J.D., Harvard Law School, 1978; LL.M. in Taxation, New York University Law School, 1985; Partner, Winston & Strawn LLP, New York, New York; member New York Bar, District of Columbia Bar, ABA, NYSBA, the International Fiscal Association, and the Association of the Bar of the City of New York, for which she serves as a member of the Committee on Taxation of Business Entities; author and speaker on international and domestic tax issues.
Michael G. Goldstein, Esq.Michael G. Goldstein, B.A. Tulane University (1968); J.D. University of Missouri School of Law (1971); LL.M. in Taxation, Washington University School of Law in St. Louis, Missouri (1972); member, American Law Institute, Association for Advanced Life Underwriting; fellow, American College of Tax Counsel and American College of Trust & Estate Counsel; chairman of the nationally recognized ALI/ABA Seminar on Uses of Insurance in Estate and Business Planning; Senior Editor of “The Insurance Counselor” Series of books published by the Real Property, Probate and Trust Law Section of the American Bar Association; Co-author of “Taxation and Funding of Nonqualified Deferred Compensation: A Complete Guide to Design and Implementation”; formerly an adjunct professor at the Washington University School of Law Graduate Tax Program.
Estate Planning for the Corporate Executive (Portfolio 808) Todd Golub
Todd D. Golub; New York University School of Law (LL.M. [Taxation]) (1994); Indiana University (B.S.) (1989); Indiana University (J.D. [cum laude]) (1992); member of the Chicago Bar Association, Former Chairman and Vice-Chairman, Corporate Tax Subcommittee; American Bar Association, Section on Taxation; Chicago Bar Association, Federal Tax Committee; American Bar Association, Subcommittee on At-Risk Rules and Passive Activity Losses; Mr. Golub currently is a Partner with Baker & McKenzie LLP and his practice focuses on federal, international and state income tax planning matters for complex transactions and entities.
Silke Golz, Esq.
Silke Golz, diploma in business economics, University of Bochum, 2000; Transfer Pricing Director, Deloitte & Touche GmbH, Stuttgart; speaker at international and national Transfer Pricing events; author of numerous articles on Transfer Pricing especially about Advance Pricing Agreements.
Samuel J. Goncz, Esq.
Samuel J. Goncz, B.A., Grove City College (Summa Cum Laude 1989); J.D., Washington and Lee University (Magna Cum Laude 1992); member, Pennsylvania Bar, Allegheny County Probate and Trust Council; Buchanan Ingersoll & Rooney PC, Pittsburgh, PA (Shareholder, 2003-present; Counsel, 2001-02; Associate, 1992-2000); contributor to Tax Practice Series.
Carlos Gonzalez-Padro, Esq.Carlos Gonzalez-Padro, B.B.A. with a major in accounting, University of Puerto Rico (1991); J.D., University of Puerto Rico (1994); LLM in Taxation with an Employee Benefits Certificate, Georgetown University Law Center (2001). Certified Public Accountant; Member, Georgia, Puerto Rico, and Washington, DC Bar Associations; Member of the American Bar Association Section of Taxation; advisor to the U.S. Treasury Department and the IRS on Puerto Rico plan initiatives; frequent lecturer and author of various articles on employee benefits in Puerto Rico.
International Pension Planning — Puerto Rico (Portfolio 324) Jordan GoodmanMr. Goodman is a partner in the Chicago law firm of Horwood, Marcus & Berk, Chartered, where he concentrates his practice on state and local tax planning and the resolution of state and local tax disputes for multistate and multinational corporations. He advises businesses in various industries on the tax ramifications and benefits of organizational structures and has lectured on state and local taxation before business and professional associations. Mr. Goodman is co–author of the chapter entitled Illinois Income Tax Considerationsfor the Illinois Institute of Continuing Legal Education publication Organizing and Advising Illinois Businesses and the chapter entitled Illinois Sales and Use Tax in the American Bar Association's Sales and Use Tax Handbook. He received his B.S. in accounting with high honors from Indiana University and his J.D. from the University of Illinois. Mr. Goodman is also a Certified Public Accountant.
Sales and Use Taxes: The Machinery and Equipment Exemption (Portfolio 1330)Illinois Corporation Income Taxes (Portfolio 2100)Illinois Sales and Use Taxes (Portfolio 2110) Jonathan E. Gopman, Esq.Jonathan E. Gopman, shareholder, Greenberg Traurig, P.A.; B.A., University of South Florida; J.D., The Florida State University College of Law (with High Honors); Masters of Law in Estate Planning, University of Miami; member, The Florida Bar (Real Property, Probate and Trust Law Section and Tax Section); North Carolina State Bar; frequent lecturer and author and co-author of numerous articles on tax and estate planning topics.
Estate Tax Payments and Liabilities (Portfolio 832) Murray L. Gordon, Esq.Murray L. Gordon, B.A. (cum laude), Brandeis University (1970); J.D., Loyola University (1975); LL.M. (Taxation), New York University (1976); member, Illinois Bar; Certified Public Accountant (Illinois); frequent lecturer on domestic and international corporate taxation, and member, World Trade Institute Tax Advisory Panel.
The Possessions Tax Credit Under Section 936 (Portfolio 933) Richard A. Gordon, Esq.Richard A. Gordon, B.A., New York University, 1964; LL.B., Duke University, 1967; tax principal, Washington International Tax Group, Deloitte Tax LLP, 2002-2005 (retired); tax partner, Director of International Specialty, Arthur Andersen, Washington, D.C., 1985-2002; Deputy Chief of Staff and International Tax Counsel, Joint Committee on Taxation, United States Congress, 1981-1985; Special Counsel for International Taxation, Internal Revenue Service, and Assistant to the Commissioner of Internal Revenue Service, Washington, D.C., 1979-1981; Associate, White & Case, Washington, D.C., 1976-1979; Attorney-Advisor, Office of International Tax Counsel, Office of Assistant Secretary of the Treasury (Tax Policy), 1972-1976; Attorney-Advisor, Legislation and Regulations Division, Office of the Chief Counsel, Internal Revenue Service, 1970-1972; Associate, Reynolds, Richards, LaVenture, Hadley & Davis, New York, 1967-1970; member, ABA; author and speaker on international tax issues.
The Allocation and Apportionment of Deductions (Portfolio 906)Foreign Corporation Earnings and Profits (Portfolio 932) Jeanne GorrissenMs. Gorrissen received her J.D. from the University of Pennsylvania Law School in 1973 and her LL.M in Taxation from Temple University School of Law in 1993. Between 1984 and 1991, Ms. Gorrissen was Deputy New Jersey Attorney General representing the New Jersey Division of Taxation before state courts (both general jurisdiction and the tax court) and federal courts (both general jurisdiction and the bankruptcy court). She also served as law clerk to the Hon. Charles R. Simpson at the United States Tax Court from 1973 to 1975.Ms. Gorrissen has written several articles concerning the state tax aspects of bankruptcy for the Journal of State Taxation, New Jersey Lawyer, Newsletter of the Debtor–Creditor Section of the New Jersey Bar Association, and Newsletter of the Tax Section of the New Jersey Bar Association. She served as the 1991 Chairman of the Northeastern States Government Bankruptcy Attorneys Committee. In addition, she is a regular speaker on the topic of bankruptcy for numerous conferences and seminars.
State Tax Aspects of Bankruptcy (Portfolio 1540)State Tax Audit and Collection Procedures: General Principles (Portfolio 1720) Ronald D. Gorsline, Esq.Ronald D. Gorsline, B.S. in Secondary Education, Bob Jones University (1982); J.D., cum laude, Indiana University (1988); Associate Editor, Indiana Law Review; published, Tax Law Journal, Summer 1987 article entitled “Section 170(j) of the Internal Revenue Code: A conflict in Analysis Regarding the Deductibility of Gifts to an Individual for the use of a Charity;” admitted, Tennessee Bar (1988), State Bar of Georgia (1989), and United States District Court, Eastern District of Tennessee.
Tax Issues of Educational Organizations (Portfolio 482) Bruno GouthiereBruno Gouthiere, Ecole Nationale d´Administration, the University of Paris, Master in Law and BS in Economics, and the Institut d'Etudes Politiques of Paris; partner with CMS Bureau Francis Lefebvre, international tax department, since 1989; previously, he was acting as Chief of Staff, International Tax Relations, Tax Policy Department, Ministry of Finance; author of reference books in international tax law, such as “Les Impôts dans les affaires internationales”, "Les Holdings", "Transfer Pricing Rules and Practice in France" (Tax Management, BNA), "Advance Rulings in France" (IBFD), "The International Guide to Holding Companies" (IBFD), co-author of various books on “Wealth” (Memento du Patrimoine), “Civil Companies” (Memento Sociétés Civiles), and of numerous articles in French and foreign legal, tax and financial reviews; member of various associations of tax practitioners such as the International Fiscal Association (“IFA”) and the Fiscal Committee of the European Fiscal Confederation (“CFE”).
Transfer Pricing: European Rules and Practice (Portfolio 895) Brent Gow, CPPBrent R. Gow, CPP, is the director, payroll consulting and compliance for Starbucks Coffee Company, in Seattle, Wash. Brent was a vice president with the American Payroll Association, was named that organization's "1990 Payroll Man of the Year," and is an active speaker, teacher, and contributing editor for the APA. Brent serves as chair of BNA's Advisory Board for Payroll Library Services.
Payroll Library Audrey GramlingAudrey A. Gramling, Ph.D., CPA, CIA, University of Arizona; M.P.A., Georgia State University; B.B.A., University of Toledo; Member, American Accounting Association, Institute of Internal Auditors; Task Force Member of the COSO Project on Monitoring Controls; served as an Academic Accounting Fellow in the Office of the Chief Accountant, U.S. Securities and Exchange Commission; has held faculty positions at the University of Illinois at Urbana-Champaign, Wake Forest University, and Georgia State University; serves as a Research Fellow of the ERM Initiative at North Carolina State University. Dr. Gramling teaches executive training courses for banks, public accounting firms, and audit committees. She has made numerous presentations on Internal Control Reporting and Auditing Requirements Under Sarbanes-Oxley including presentations to public companies, Georgia State University's Center for Enterprise Risk Management and Assurance Services, and Georgia Society of CPAs. Dr. Gramling conducts research related to both internal and external auditing issues, including external auditor independence, internal control reporting, and factors affecting the market for audit services. Dr. Gramling's research has been published in academic and professional journals including Contemporary Accounting Research; Journal of Accounting Research; Auditing: A Journal of Practice and Theory; Accounting Horizons; Journal of Accounting, Auditing & Finance; Journal of Accounting Literature; Internal Auditing; and Issues in Accounting Education.
Management's Reporting on Internal Control Over Financial Reporting (Portfolio 5317) Luis Granados, Esq.Luis Granados, Brown University (A.B. 1975), Georgetown University Law Center (J.D. 1978); member, District of Columbia and Maryland Bars. Past Chairman, Legislative and Regulatory Advisory Committee, The ESOP Association.
ESOPs (Portfolio 354) Terry Greene
Terence (Terry) Greene is a member of the Federal Income Tax Group and the Public Finance Group. He concentrates his practice on federal income taxation of business taxpayers, including business tax planning, mergers and acquisitions, taxation of financial institutions and products, tax-exempt financing and tax litigation. In particular, Terry focuses on the tax structuring of a wide range of business transactions including taxable and tax-free mergers and acquisitions, dispositions, public offerings, financing transactions, venture formations and reorganizations. He has extensive experience advising banks, insurance companies, and other financial institutions on a wide variety of industry-specific issues and he advises clients in all industries on capitalization and tax accounting issues, consolidated return issues, net operating loss utilization and tax-favored investments.Terry is a frequent speaker and author on federal income tax topics including tax-exempt financing, corporate tax planning, capitalization issues, financial institution taxation, alternative dispute resolution and tax litigation.
Katherine T. Greenfield, Esq.
Katherine Greenfield graduated magna cum laude with a degree in International Affairs from the George Washington University and received her law degree from the University of Michigan. She is a member of the Oregon State Bar. Ms. Greenfield currently provides legal support and manages equity plan administration for Merix Corporation.
Christine Grimaldi
Christine Grimaldi joined Daily Tax Report as a congressional tax reporter in 2008. She graduated from the George Washington University with a bachelor’s degree in journalism. She previously reported for Congressional Quarterly, the Palm Beach Post through the Cox Newspapers Washington Bureau, and Greater Media Newspapers. She also worked for AARP Bulletin Today and for the Brian Ross Investigative Unit at ABC News in New York and Washington, D.C.
Christopher GrissomChristopher R. Grissom is a senior associate in the Birmingham, Alabama office of Bradley Arant Rose & White LLP. His practice involves state and local tax planning, LLCs, and federal and state tax disputes. Mr. Grissom received his B.S. in 1993 from the University of Alabama's Culverhouse School of Accountancy and his law degree, cum laude, in 1997 from the University of Alabama School of Law, where he was a student editor of The American Journal of Tax Policy. He is a contributing editor to State Tax Notes, State Income Tax Alert, Journal of Multistate Taxation, and BNA Multistate Tax Report. In addition, he is a member of the ABA Section of Taxation and the Alabama State Bar Section of Taxation.
Choice of Entity: An Overview of Tax and Non-Tax Considerations (Portfolio 1550) Donald Griswold
Donald M. Griswold, B.A. University of Chicago, 1979; J.D. Boston University, 1983; currently partner, Reed Smith LLP, Washington D.C. in its nationwide State Tax Group; formerly national partner in charge, state & local tax technical services at a Big 4 accounting firm; more than 25 years experience in state tax planning, consulting, and litigation in state and federal courts around the country; frequent speaker at many state tax conferences.
Jean-Marc Groelly
Jean-Marc Groelly, a partner in our tax practice, specialises in international tax law, with a particular focus on the tax aspects of structured finance transactions, including securitisations, CDOs and CLOs. In addition, he provides tax advice in the context of M&A, real estate, private equity and venture capital transactions. Jean-Marc received a master's degree in business law (maîtrise de droit des affaires) from Jean Moulin University (Lyon III) in 1997. In 1998, he earned a post-graduate degree in business and tax law (diplôme d'études supérieures spécialisées (DESS) and a diplôme de juriste conseil d'entreprise (DJCE)) from Jean Moulin University (Lyon III). Jean-Marc was admitted to the Luxembourg Bar in 2003 and joined NautaDutilh in January 2006, after having spent more than six years with several US-UK firms. He has more than 10 years of experience in Luxembourg taxation matters. Jean-Marc is fluent in English, French and German.
Virginia C. Gross, Esq.Virginia C. Gross, B.S., Texas A&M University (1986); J.D., University of Texas School of Law (1990); shareholder, Polsinelli Shalton & Welte, P.C., Kansas City, Missouri; legal practice concentrates on tax issues for nonprofit and for-profit organizations; frequent writer and speaker on nonprofit tax issues.
Private Foundations — Distributions Sec. 4942 (Portfolio 880) Mary GrossmanMary B. Grossman, J.D., CPA, B.S.B.A., University of North Carolina at Chapel Hill (1976); M.S., Accounting, San Diego State University (1981); J.D., Loyola University Chicago School of Law (1997). Ms. Grossman has practiced as a CPA with international accounting firms and in private industry. She has advised on accounting for a wide variety of financial instruments. Ms. Grossman serves as the Chapter 13 Standing Bankruptcy Trustee for southeastern Wisconsin.
Accounting and Disclosure for Derivative Instruments (Portfolio 5112) Elizabeth Grover
Elizabeth Grover is a copy editor for Daily Tax Report. She began her career at BNA in 1997 as a reporter covering employee benefits regulatory policy and legislation for BNA’s Pension & Benefits Reporter, and then spent six years covering health care policy issues on Capitol Hill for BNA’s Health Care Daily Report and Health Care Policy Report. She holds a master’s degree in public policy from George Mason University in Fairfax, Va. and a bachelor’s degree in history from the Catholic University of America in Washington, D.C.
Ronald L. Groves, Esq.
Ronald L. Groves of Ropes & Gray, Boston; Louisiana State University (B.S. 1964); Tulane University School of Law (LL.B. 1966); Harvard University School of Law (LL.M. 1967); Senior Attorney–Advisor, Office of Tax Legislative Counsel, U.S. Treasury Department (1970–72).
Corrado GuerraCorrado Guerra, Law Degree, University “La Sapienza” (1996); LL.M. (International, European and Comparative Law), Vrije Universiteit Brussel (2000); previously associated with Morgan, Lewis & Bockius, Lovells Boesebeck Droste and Jones Day, Brussels, Belgium.
Business Operations the European Union (Portfolio 999) Dan GuyDan M. Guy, CPA, Ph.D., University of Alabama (1971); MBA, East Carolina University (1967); Member, American Institute of Certified Public Accountants, Texas Society of CPAs, New Mexico Society of CPAs, National Association of Corporate Directors; former Vice-President, Auditing, American Institute of Certified Public Accountants; currently has a litigation consulting practice in Santa Fe, New Mexico; author of Practitioner's Guide to GAAS (Wiley), Guide to International Standards on Auditing and Related Services (Practitioner's Publishing Company), and Audit Committees: A Guide for Directors, Management, and Consultants (CCH). In 1998, Dr. Guy received the John J. McCloy Award for outstanding contributions to audit quality in the U.S. In 2001, he received the Distinguished Service Award from the Auditing Section of the American Accounting Association for a lasting and significant impact over a 20 to 25 year span in the field of accounting.
Auditors' Reports (Portfolio 5400)
H
Susan HaffieldSusan Haffield is a partner in the Minneapolis office of PricewaterhouseCoopers. She serves as the state and local tax practice site leader and specializes in sales and use tax. Susan provides consulting services focusing on tax strategy and planning, audit defense, refund analysis, re-engineering, and e-commerce. She has also been actively involved with the Streamlined Sales Tax Project since its inception and has published several articles on the subject. Susan is actively involved with many business and taxpayer organizations such as the, Minnesota Chamber of Commerce, Illinois Chamber of Commerce, Illinois Civic Federation, Iowa Taxpayer's Association, and Minnesota Society of CPA's. She is also a frequent speaker for organizations such as Council On State Taxation, Institute for Professionals in Taxation, Tax Executive Institute, and New York University. Susan graduated from Moorhead State University in Accounting and Business Administration. She began her career with Arthur Andersen and has also worked in the tax department at Cargill Inc.
Sales and Use Taxes: Streamlined Sales Tax System (Portfolio 1270) Kelly Hales
Ernst & Young LLP, Houston
Russell E. HallRussell E. Hall, J.D., Fordham Law School (1978), LL.M. in taxation, New York University School of Law (1979), B.A., S.U.N.Y. at Albany (1975); member, New York State Bar; member, Retirement Security Committee, ERISA Industry Committee; member, Tax Law Section, American Bar Association; member, International Pension and Employee Benefit Lawyers Association (IPEBLA).
International Pension Planning (Portfolio 320) Thomas Hamilton
Thomas Hamilton; PhD, CRE, FRICS, is associate professor of real estate at the University of St. Thomas-Minnesota College of Business in St. Paul, MN. He received an MS in Real Estate and a PhD in Urban Land Economics from the University of Wisconsin-Madison. He also received an MS in Finance from the University of Wyoming. Professor Hamilton has published several articles on property tax assessment issues, contributes to BNA Tax & Accounting's Real Estate Journal and consults regularly with energy and telecommunication companies.
Rick HandelRick Handel is the Chief Counsel for Policy for the South Carolina Department of Revenue and an adjunct professor of law with the University of South Carolina School of Law. A graduate of the University of Michigan, Rick received a master's degree from Michigan State University, a law degree summa cum laude from Ohio State University, and was a Gerald Wallace Scholar at New York University where he received a Master of Laws in Taxation. A former partner with Nexsen Pruet Jacobs & Pollard and Moore & Van Allen, Rick was included in The Best Lawyers in America, received the Outstanding Professor Award from the University of South Carolina School of Law, and is included in Who's Who in American Law. The S.C. Supreme Court has designated him a “Certified Specialist - Taxation Law.” He is the founder of the South Carolina SALT Study Group, an officer of the American Bar Association's SALT Committee, and an active member of its Standards of Tax Practice Committee.
South Carolina Corporate Income Tax (Portfolio 2280) David A. Handler, Esq.
David A. Handler, Northwestern University School of Law, B.S. Degree in
Finance with highest honors from the University of Illinois College of
Commerce; fellow of the American College of Trust and Estate Counsel (ACTEC); member of the professional advisory committees of several non-profit organizations, including the Chicago Community Trust, The Art Institute of Chicago, The Goodman Theatre, WTTW11/98.7WFMT (Chicago public broadcasting stations) and the American Society for Technion - Israel Institute of Technology; among a handful of trusts & estates attorneys listed in Chambers USA: America’s Leading Lawyers for Business, is listed in The Best Lawyers in America and was identified as one of the top 100 lawyers in Illinois in the 2006 list of “Illinois Super Lawyers"; a member of the Tax Management Estates, Gifts and Trusts Advisory Board, and an Editorial Advisory Board Member of Trusts & Estates Magazine for which he currently writes the monthly “tax update” column; co-author of a two-volume book on estate planning, Drafting the Estate Plan: Law and Forms (CCH); authored many articles that have appeared in prominent estate planning and taxation journals, magazines and newsletters, including Lawyer’s Weekly, Trusts & Estates Magazine, Estate Planning Magazine, Journal of Taxation, Tax Management Estates, Gifts and Trusts Journal, The Chase Journal and RIA’s Estate Planner’s Alert. He is regularly interviewed for trade and news periodicals, including The Wall Street Journal, The New York Times, Lawyer’s Weekly, Registered Representative, Financial Advisor, Worth and Bloomberg Wealth Manager magazines. Mr. Handler is a partner in the Trusts and Estates Practice Group of Kirkland & Ellis LLP, Chicago, IL and concentrates his practice on trust and estate planning and administration, representing owners of closely-held businesses, principals of private equity/venture capital/LBO funds, executives and families of significant wealth, and establishing and administering private foundations, public charities and other tax-exempt entities.
R. Arnold Handler, Esq.R. Arnold Handler, B.A., University of Rochester (undergraduate study also at London School of Economics); J.D., Harvard Law School; LL.M (in Taxation), New York University School of Law; Captain, Judge Advocate Generals Corps, U.S. Army; Attorney, Tax Department, Carter, Ledyard & Milburn; Senior Tax Attorney, Mobil Corporation; Senior International Tax Counsel, Citigroup (1990-present).
The Mark-To-Market Rules of Section 475 (Portfolio 543) Gordon Hands
Gordon Hands is a managing director of CUFTanalytics, a transfer pricing consulting firm specializing in intercompany financial transactions, based in Calgary.
Arnold Hanish
Arnold C. Hanish, University of Cincinnati, B.A. Accounting; member of the Indiana CPA Society, the Ohio Society of CPA’s, and the AICPA, chairperson of the Financial Executive’s International – Committee on Corporate Reporting, serves on the FEI-SEC and FEI-PCAOB subcommittees, member of the Standing Advisory Group of the PCAOB from 2004 to 2008 ; Responsible for the global accounting process, including Sarbanes-Oxley, as well as the U.S. payroll, shareholder and stock option services, and business partner support for corporate staff functions, and consulting on business development activities such as M&A and in- and out-license of compound technologies. Included in Treasury & Risk’s 2009 and 2008 articles of the “100 Most Influential People in Finance”, recognized by Business Finance in their articles entitled “Influencers 2007: Transparency Changes Everything,” “2006’s Influencers: 60 Authoritative Voices,” and “2005’s 50 Worth Watching Influencers.” Vice President and chief accounting officer, Eli Lilly and Company.
Steven P. Hannes, Esq.
Steven P. Hannes, Amherst College, B.A. (1967); New York University School of Law, J.D. (1970); formerly Associate International Tax Counsel, Department of the Treasury; Group Chief, Corporation Tax Branch, Internal Revenue Service; Member of National Council and Vice President (Washington Region), International Fiscal Association; member, District of Columbia Bar Association, American Bar Association, Tax Committee of National Foreign Trade Council.
Kathy Hanson, Esq.
Kathy Hanson, Esq. is an editor for Estates, Gifts and Trusts at BNA Tax & Accounting, and a contributing editor for the Weekly Report.
Bertrand M. Harding, Jr. Esq.Bertrand M. Harding, Jr., Duke University (1968); J.D., The George Washington University National Law Center (1975); former Tax Law Specialist, Internal Revenue Service Exempt Organizations Division (1972-1975); former attorney-advisor to Judge Bruce M. Forrester, United States Tax Court (1975-1977); former tax partner, Baker & McKenzie, Washington, D.C. office (1984-1996); lecturer on college and university tax matters; author, The Tax Law of Colleges and Universities, 2d ed., published by John Wiley & Sons, Inc.
U.S. Income Taxation of Foreign Students, Teachers, and Researchers (Portfolio 914) Carol A. Harrington, Esq.Carol A. Harrington, B.S., summa cum laude, University of Illinois; J.D., magna cum laude, University of Illinois Law School; Section of Real Property, Probate and Trust Law, American Bar Association: Section Council, 1992–1996, Chair, Committee on Generation-Skipping Transfers: Legislation and Regulations, 1987–1992; Fellow, American College of Trust and Estate Counsel, Board of Regents 1999-2005; member, Illinois State Bar Association; member, Trust Law Committee, Chicago Bar Association; co-author, Harrington, Plaine & Zaritsky, Generation-Skipping Transfer Tax, Warren, Gorham & Lamont (2001); contributor to various legal publications on estate planning matters and lecturer at various tax and estate planning institutes.
Generation-Skipping Transfer Tax (Portfolio 850) Kenneth L. Harris, Esq.Kenneth L. Harris, A.B. Hamilton College (summa cum laude 1982, Phi Beta Kappa); J.D. University of Chicago Law School (1985); LL.M. New York University School of Law (1988, Graduate Editor, Tax Law Review); Member of Committee on U.S. Activities of Foreign Taxpayers and Standards of Tax Practice; co-author of Standards of Tax Practice (4th Ed. 1997); frequent speaker and writer on federal tax issues.
Partners and Partnerships — International Tax Aspects (Portfolio 910) Steven Harris
Steven D. Harris is a member of KPMG LLP's global transfer pricing services practice and is a principal with the firm's New York and Washington, D.C., offices.
David Harrison
David Harrison is a graduate of Virginia Commonwealth University and came to BNA in 2004 as a Daily Tax Report copy editor. Before that, he was managing editor and then executive editor of Education Daily in Washington, D.C. He also has been a police reporter and education reporter in the Norfolk and Suffolk newsrooms of The Virginian-Pilot and Ledger Star.
Lonie A. Hassel, Esq.Lonie Hassel, B.A. summa cum laude, Catholic University of America (1977), Phi Beta Kappa; J.D. University of Virginia School of Law (1980); Attorney and Assistant General Counsel, Pension Benefit Guaranty Corporation 1980–1988; American Bar Association; District of Columbia Bar.
Pension Plan Terminations — Single Employer Plans (Portfolio 357) James K. Hasson, Jr. Esq.James K. Hasson, Jr., B.A. and J.D., Duke University; Order of the Coif and Comments and Project Editor of Duke Law Journal; member of State Bar of Georgia; member of American, District of Columbia, and Atlanta Bar Associations; former Chair of the Exempt Organizations Committee of Tax Section of American Bar Association; member of Foundation Lawyers Group, National Association of College and University Attorneys, National Health Lawyers Association, and American Academy of Hospital Attorneys; Partner at Sutherland, Asbill & Brennan LLP, representing closely-held businesses, universities, private foundations, hospitals and other religious, charitable and educational organizations.
Private Foundations — Section 4940 and Section 4944 (Portfolio 878) Sandra HazanSandra Hazan graduated from the University of Paris II (Maîtrise de Droit des Affaires et Fiscalité, 1990), the University of Paris I (DEA Droit Anglais et Nord-Américain des Affaires, 1991) and attended the LLM course at Queen Mary & Westfield College, London (1993); partner, Salans.
Business Operations France (Portfolio 961) Thijs J. M. HeijenrathThijs Heijenrath, University of Tilburg, Master’s in tax law; certified tax advisor and member of the Dutch Tax Advisors Association (NOB); member of the Global Transfer Pricing Strategy board of Deloitte; international tax partner with Deloitte Belastingadviseurs BV, Netherlands affiliate of Deloitte Touche Tohmatsu, based in Rotterdam. Mr. Heijenrath leads Deloitte's Transfer Pricing / Tax-Aligned Supply Chain group in the Netherlands and is an active member of the Global Transfer Pricing Strategy board of Deloitte.
U.S. Income Tax Treaties — Competent Authority Functions and Procedures of Selected Countries (Portfolio 941) Michael A. Heimos, Esq.Michael A. Heimos, member, Dean & Heimos, LLC; B.A. cum laude, Benedictine College (1991); J.D., University of Denver College of Law (1995). Co-author, numerous articles, commentaries for BNA Tax Management. Member, Tax Management Estates, Gifts and Trusts Advisory Board; Colorado Catholic Lawyers Guild; French-American Business Association, Denver. Author and co-author, several other pieces for publishers such as West Group Publishing, New York; Chancellor Publishing, London; Asset Protection Journal; American in Britain; and American Bar Association's Asset Protection Strategies.
Immigration and Expatriation Law for the Estate Planner (Portfolio 806)Non-Citizens — Estate, Gift and Generation-Skipping Taxation (Portfolio 837) Dan Heitger, Ph. D.Dr. Dan L. Heitger, Ph.D., Michigan State University (2000); B.S., Accounting and Mathematics, Indiana University (1993). Dr. Heitger worked for Ernst & Young, LLP as a staff associate (1993) and specializes in performance measurement issues and transparent sustainability reporting. He co-founded Indiana Executive Systems, an organization that provides executive education on topics related to governance, risk management, and reporting (GRMR) for large international organizations. His GRMR-related publications have appeared in Harvard Business Review, Behavioral Research in Accounting, the Journal of Accountancy, and Management Accounting Quarterly. Dr. Heitger has also received grants related to risk management and reporting from the Bureau of National Affairs. He is an Associate Professor of Accountancy and Co-Director of the Center for Governance, Risk Management, and Reporting at the Farmer School of Business, Miami University of Ohio, and co-instructs the only GRMR course series of its kind in the United States.
Coordinating Risk Management and Performance Measurement (Portfolio 5308) Walter HellersteinMr. Hellerstein is a Professor of Law at the University of Georgia School of Law and a partner in the firm of Sutherland, Asbill & Brennan. He is formerly Of Counsel to the law firm of Morrison & Foerster. He is a 1967 graduate of Harvard College, where he was elected to Phi Beta Kappa, and a 1970 graduate of the University of Chicago Law School, where he served as Editor–in–Chief of the University of Chicago Law Review. After graduation from law school, Mr. Hellerstein clerked for the Hon. Henry J. Friendly, served as an attorney in the Honors Program of the Air Force General Counsel's Office, and practiced law at Covington & Burling in Washington, D.C. Mr. Hellerstein taught at the University of Chicago Law School before joining the University of Georgia's law faculty in 1978. Mr. Hellerstein has written and practiced extensively in the state tax field. He is the author of State and Local Taxation of Natural Resources in the Federal System: Legal, Economic, and Political Perspectives (American Bar Association Section of Taxation 1986), co–author with Jerome R. Hellerstein of State Taxation, Vols. I & II, and State and Local Taxation (West Publishing Co.), and the author of numerous law review articles on state taxation that have appeared in The Michigan Law Review, The University of Chicago Law Review, The Supreme Court Review, The Tax Lawyer, The Journal of Taxation, The National Tax Journal, The Tax Law Review, the Virginia Law Review, and other journals. Mr. Hellerstein has spoken widely on state tax topics at conferences sponsored by Georgetown University Law Center, New York University Law School, the National Tax Association, the Heart of America Tax Institute, and other organizations. He is a member of the District of Columbia, Illinois, and New York bars.
State Taxation of Corporate Income From Intangibles (Portfolio 1190)Federal Constitutional Limitations on State Taxation (Portfolio 1400) Lori Hellkamp
Lori A. Hellkamp is an associate with Jones Day in its Washington, DC office and a contributor to BNA Tax & Accounting's Tax Management Memorandum.
Michelle HenkelMichelle M. Henkel; B.A., Rhodes College (1986); Senior Accountant, Arthur Andersen & Co. (1986-1989); Manager, National Mortgage Co. (1989-1990); J.D., Emory University School of Law (1993); Federal Tax Controversies, Mayer, Brown, Rowe & Maw (Associate, 1993-1994); Federal Income Tax, Alston & Bird LLP (Associate, 1994-1999; Partner, 2000-present); Member, American Bar Association (Section of Taxation, Banking and Savings Institution Committee, and Court Practice and Procedure Committee); Vice-Chair, Banking and Savings Institution Committee of the American Bar Association's Section of Taxation (2005-2007); Member, Tax Audits and Litigation Committee of the District of Columbia Bar (2005-present); Chair, Section of Taxation of the Atlanta Bar Association (2005-2006); Member, Atlanta Tax Forum (2001-present); Trustee, Thompson West Tax Advisory Board (2003-2005); Member, American Institute of Certified Public Accountants (1986-present); Member, Georgia Society of Certified Public Accountants (1996-present); Admitted to the bars of the District of Columbia, Georgia, and Illinois; Admitted to practice in the U.S. Supreme Court, the Eleventh and Federal Circuit Courts of Appeals, the U.S. Tax Court, the U.S. Court of Federal Claims, the Court of Appeals for the District of Columbia, the Supreme Court of Georgia and the Supreme Court of Illinois; Licensed as a certified public accountant (Tennessee; inactive status); Author and speaker on federal tax and tax controversies topics.
Sarbanes-Oxley: Auditor Independence (Portfolio 5502) Ellen A. HennessyEllen (Nell) Hennessy is an attorney and consultant, and President of ASA Fiduciary Counselors Inc., as well as Senior Vice President of ASA's Corporate Restructuring Practice in Washington, D.C., following her many years of service as Deputy Executive Director and Chief Negotiator for the Pension Benefit Guaranty Corporation. A 1978 law graduate of Catholic University and the recipient of a Masters degree in Taxation from Georgetown University, in private law practice, she was a partner with Willkie, Farr & Gallagher.
ERISA — Fiduciary Responsibility and Prohibited Transactions (Portfolio 365) Peter HenningPeter J. Henning, B.A. (Philosophy), Loyola Marymount University; M.A. (Philosophy), Fordham University; J.D., Georgetown University Law Center. Professor Henning has been on the faculty of Wayne State University Law School since 1994. Prior to entering law teaching, he was a Senior Attorney in the Division of Enforcement at the U.S. Securities & Exchange Commission from 1987 to 1991, and a Trial Attorney in the Criminal Division of the U.S. Department of Justice from 1991 to 1994. He is a co-author of casebooks on criminal law and white collar crime, and a co-author of three volumes of Wright & Miller, Federal Practice & Procedure.
Responding to Department of Justice Investigations (Portfolio 5515) Hemantha Herath
Hemantha S. B. Herath, Ph.D., Auburn University (1999); M.Sc., Auburn University (1994). Associate Professor of Accounting, Brock University, Ontario, Canada. Dr. Herath is an Associate Member of the Chartered Institute of Management Accountants — ACMA, United Kingdom (1992). Published work has appeared in Advances in Investment Analysis and Portfolio Management, Advances in Management Accounting, The Engineering Economist, Advances in Quantitative Finance and Accounting, the Managerial Finance journal, the Managerial Auditing Journal, and the Corporate Finance Review.
Michael D. HerbertMr. Herbert is a State and Local Tax Partner in PricewaterhouseCoopers' San Francisco office. He is a 1980 graduate of U.C. Berkeley's Haas School of Business and a 1984 graduate of the U.C.L.A. School of Law. Mr. Herbert specializes in state and local taxes, with an emphasis on multistate corporate and individual income taxes, sales and use taxes, and California property taxes. He serves as a firmwide expert on California tax law and policy. Mr. Herbert is both an attorney and a certified public accountant.Mr. Herbert is a Past Chairman of the State and Local Tax Committee of the California State Bar Section of Taxation. He also served as a member of the Editorial Board of the Journal of California Taxation. He has co–authored the Tax Management Portfolio California Property Taxes and has written articles on instant unity, business income, withholding, technology contracts, the impact of federal planning techniques on state taxes, audit defense strategies, sales factor planning and trends, and factor distortion.Mr. Herbert has lectured extensively on state tax topics before such groups as the California Tax Policy Conference, the Georgetown University Institute on State and Local Taxation, the U.S.C. Tax Institute, the Paul J. Hartman State Tax Forum, the Tax Executives Institute, and the Committee on State Taxation.
California Personal Income Tax (Portfolio 1900)California Property Taxes (Portfolio 1930) Robert Herman, Esq.
Robert G. Herman, Esq. is a US Income Editor at BNA Tax & Accounting, and a contributing editor for the Weekly Report.
Robert G. Herman, Federal Tax Law Editor
Robert has been a Federal Tax Law Editor at BNA Tax & Accounting since 1999. In that time, he has worked in the Business Entities and in the Estate, Gift, Trusts and Tax-Exempt Organizations groups. At present, Robert is a member of the U.S. Income group where he deals with a wide range of tax issues, including noncorporate alternative minimum tax and energy-related tax incentives. Prior to joining BNA, Robert's practice included estate and trust planning, creation and administration, and small business formation. Robert received his B.S. from Liberty University and J.D. from Willamette University College of Law.
Francisco R. Hernández-Ruiz, Esq.Francisco Hernández-Ruiz, B.S.B.A., Boston College (1962); L.L.B. University of Puerto Rico School of Law (1965); L.L.M. (in Taxation), New York University Law School (1972); Assistant Professor of Tax Law, Interamerican University School of Law (1984–1988); Assistant Professor of Taxation, University of Phoenix (1994–1995); Member of the Board of Bar Examiners (1985–1986); Member of the Evaluating Committee of the Council of Higher Education for the Accreditation of the Graduate Law Program of Catholic University; Member of the Puerto Rico Bar Association; Member of Tax Committee of the Puerto Rico Chamber of Commerce; Member of the Tax Committee of the Puerto Rico Manufacturing Association; frequent lecturer on tax issues; author of various articles on tax laws.
Business Operations Puerto Rico (Portfolio 2650)Business Operations Puerto Rico (Portfolio 980) Richard M. Hervey, Esq.Richard M. Hervey, Dechert LLP, New York, NY; B.A., Herbert Lehman College (1972); M.A., University of California, Berkeley (1975); J.D., Harvard Law School (1978); admitted, New York Bar; member, American Bar Association (Section of Taxation); Committee on Regulated Investment Companies, New York State Bar Association (Section on Taxation).
Taxation of Regulated Investment Companies (Portfolio 740) John Herzfeld
John Herzfeld is a BNA staff correspondent for the Weekly Report.
Barry Herzog, Esq.Barry Herzog, B.A., Yeshiva University (1987); J.D., Columbia University (1991); member, New York State Bar Association, Committee on Corporations; member, American Bar Association, Section of Taxation; member, New York State Bar; co-author, Tax Management Portfolio No. 561, Capital Assets.
Capital Assets (Portfolio 561)Transfers to Controlled Corporations: General (Portfolio 758)Transfers to Controlled Corporations: Related Problems (Portfolio 759) Jerome M. Hesch, Esq.
Jerome M. Hesch practices law in Miami, Florida and is a tax and estate planning consultant for lawyers and other estate planning professionals throughout the country. He is a member of ACTEC, has published numerous articles, several Tax Management Portfolios, and co-authored a law school casebook on Federal Income Taxation, now in its third edition. He has appeared for groups such as the AICPA, the University of Miami Heckerling Institute on Estate Planning, the University of Southern California Tax Institute and the New York University Institute on Federal Taxation. He has participated in several bar association projects, such as the Drafting Committee for the Florida Revised Uniform Partnership Act and preparing the ABA’s comments on the IRS’s proposed private annuity regulations. He received his BA and MBA degrees from the University of Michigan and a JD degree from the University of Buffalo Law School. He was with the Office of Chief Counsel, Internal Revenue Service, Washington, D.C. from 1970 to 1975, and was a full-time law professor from 1975 to 1994. He is currently an adjunct professor of law at the Florida International University and the University of Miami law schools and teaches a course as part of the ABA’s annual, week-long Skills Training for Estate Planners program.
James Hickey, Esq.James P. Hickey, B.B.A., Western Illinois University; MST, DePaul University; member, American Institute of Certified Public Accountants; Illinois and Ohio CPA Societies; Adjunct Professor of Taxation, DePaul University Graduate School of Business, College of Commerce.
Foreign Sales Corporations (Portfolio 934) David A. Hildebrandt, Esq.David A. Hildebrandt, B.S., Brigham Young University (1967); J.D., Order of the Coif, University of Wisconsin (1970); note and comment editor, Wisconsin Law Review (1970); member, American Bar Association Section of Taxation, District of Columbia Bar, State Bar of Wisconsin, U.S. Supreme Court; Certified Public Accountant, Wisconsin (1974).
Qualified Plans — IRS Determination Letter Procedures (Portfolio 360)Qualified Plans — Treatment Mergers, Acquisitions and Other Corporate Transactions (Portfolio 364) Akil Hirani
Akil Hirani is the Head of Transactional Practice and Managing Partner of Majmudar & Co., International Lawyers in India (www.majmudarindia.com). Akil’s particular experience includes M&A, private equity, securities and corporate finance, tax, and investment structuring work. He represents Citigroup, Hitachi Metals and many other international companies and banks in India. Akil has been practicing since 1992. He is qualified to practice law in India, California, and England & Wales, although he is currently on inactive status in the latter two jurisdictions. His work experience includes a clerkship at the State Superior Court of Santa Clara County in San José, California, in 1995, and a stint at the London firm of Lawrence Jones (now known as TLT) in 1996. He has written extensively and spoken on M&A structures, capital raising, issues affecting hedge funds and FIIs, India investment strategies, and related subjects at many international forums, including at seminars held by Terrapin in India and Hong Kong, PLI and ATLAS Legal in the US, and the International Bar Association (IBA).
Georg Hirsch
Georg Hirsch is a member of KPMG's global transfer pricing services practice and is a senior associate with KPMG LLP in McLean, VA.
Linda B. Hirschson, Esq.
Linda B. Hirschson, LL.M., New York University of Law; LL.B., Columbia University School of Law; Shareholder, Greenberg Traurig, LLP, New York, New York; past Regent of the American College of Trusts and Estates Counsel (ACTEC); past Chair, Trusts and Estates Law Section of the New York State Bar Asssociation, develops estate plans for high net worth individuals; assists with forming and administering private foundations and charitable trusts; frequent lecturer and author of numerous articles on estate planning, income taxation and a wide-range of related topics.
Leonard S. Hirsh, Esq.
Leonard S. Hirsh; New York University School of Law; Georgetown University Law Center (Masters of Law, Taxation); writer and speaker on employee benefits and executive compensation topics; taught courses at the New York University Institute on Federal Taxation and at the Practising Law Institute; member of the BNA Tax Management’s Advisory Board on Compensation Planning, Chairman of the Qualified Cash or Deferred Arrangements Subcommittee of the American Bar Association’s Employee Benefits Committee, a Charter Fellow of the American College of Employee Benefits Counsel, a contributing editor for the Journal of Pension Planning and Compliance, and a member of the Board of Editors of Law Firm Partnership and Benefits Report; author of articles “New Prop. Regs. for Section 401(k) Plans Are a Comprehensive Overhaul of Existing Guidance,” for the November 2003 issue of the Journal of Taxation, “Section 409A Final Regs. Provide Comprehensive Guidance for Post-Transition Period,” for the September 2007 issue of the Journal of Taxation; is Executive Director in the Performance & Reward Practice in New York where he leads the Tax Regulatory group.
Bruce I. Hochman, Esq.Bruce I. Hochman, B.A., University of Toronto and University of California at Los Angeles (1949); J.D., University of California at Los Angeles (1952); Graduate Certificate in Taxation, University of Southern California (1957). Assistant U.S. Attorney, Southern District of California, Tax Division (1953–1956). Hearing Officer, Department of Justice (195801968). Member: American Bar Association, State Bar of California. Fellow, American College of Trial Lawyers. Certified specialist, Criminal and Taxation Law, California Board of Legal Specialization. Principal – Hochman, Salkin and DeRoy, P.C., Beverly Hills, California, a firm specializing in federal and state taxation, corporation law and civil, criminal and tax litigation.
Tax Crimes (Portfolio 636) Charlotte Hodges, CPPCharlotte Hodges, CPP, specializes in expatriate assignments and multi-state taxation, and is a member of the American Payroll Association's Hotline Referral Service and on the Government Affairs Task Force Data Privacy and Security Subcommittee. She also is a past president of the Washington Metropolitan Area Chapter of the APA (WMAC-APA), and most recently was the Manager, Payroll Shared Services, for Northrop Grumman Corporation Information Technology in Herndon, Va.
Payroll Library Mark Hoffenberg
KPMG Washington National Tax office
John Hollas
John Hollas is the managing director of the Ceteris Western Canada Region, based in Calgary, as well as the firm's North American energy industry leader. Hollas is also a managing director of CUFTanalytics, a transfer pricing consulting firm specializing in intercompany financial transactions, based in Calgary.
Philip J. Holthouse, Esq.Philip J. Holthouse, B.S., University of Southern California (summa cum laude, 1981); M.B.T., University of Southern California (1986); J.D., Loyola Law School — Los Angeles (Order of the Coif, 1993); adjunct professor, University of Southern California Master of Business Taxation Program (1988 – ); author of numerous articles on federal taxation; member of the American Bar Association, State Bar of California, American Institute of Certified Public Accountants, California Society of CPAs; Partner — Holthouse Carlin & Van Trigt LLP (CPAs); Partner — Sherry, Coleman & Holthouse LLP (Attorneys at Law).
Real Estate Leases (Portfolio 593) Benjamin Homo
Benjamin Homo is a Partner in the Paris office of Mayer Brown. He advises a large number of French and foreign private equity clients and corporate groups on their acquisitions, financing, and real estate transactions. He has developed a strong experience of all aspects of multi-country transactions, from tax due diligence to structuring work, including financing issues, and has been involved in most of the larger deals (above €1 billion) carried out on the French market over the past years. In his work on such transactions, Benjamin analyzes, develops, and manages complex financial models which allow him to translate multi-jurisdiction tax advice into cash flow simulations, helping his clients understand and analyze with their own tools and language the consequences of cross-border taxes on the economics of the transaction. Benjamin also advises French private equity clients with respect to their own fund structure, and he has provided structuring advice for the creation of several real estate or private equity funds. In addition, Benjamin assists corporate clients in their day-to-day tax management (tax audit/litigation, reporting tools) and in the reduction of their global effective tax rate (French and international tax planning, transfer pricing, and similar concerns). Before he joined Mayer Brown in 2004, Benjamin was a member of a major financial consulting firm’s Paris office. He is fluent in both French and English.
H. Carter Hood, Esq.
H. Carter Hood, A.B., Economics, Harvard College, 1991, magna cum laude; Master of Taxation, George Washington University School of Business and Public Management, 1995, summa cum laude; J.D., Harvard Law School, 1998, cum laude; Partner, Estate Planning and General Taxation, Ivins, Phillips & Barker, Chartered, Washington, D.C.; member Virginia Bar, District of Columbia Bar, ABA; Adjunct Professor, Georgetown University Law Center Graduate Tax Program; speaker on estate planning and taxation at ABA Annual Meeting of Section of Taxation and at Annual Real Property, Trust & Estate Law Symposia.
L. Paul Hood, Jr. Esq.L. Paul Hood, Jr., B.S., Louisiana State University (1982); J.D., Louisiana State University (1986); M.L.T., Georgetown University Law Center (1988); member, American and Louisiana State Bar Associations; fellow, American College of Trust and Estate Counsel; contributor, Loyola (N.O.) Law Review, ACTEC Probate Journal, Estate Planning, Journal of Practical Estate Planning, Probate Law Reporter, Charitable Gift Planning News, Tax Management Estates, Gifts and Trusts Journal, Leimberg Information Services, Inc., Louisiana Bar Journal; Editor, The Louisiana Estate Planner; co-author, Louisiana Wills & Trusts.
Valuation: General and Real Estate (Portfolio 830) Andrew H. Hook, Esq.Andrew H. Hook, CELA, CFP®, J.D., (1975), University of Virginia School of Law. Andrew H. Hook is a Partner in the law firm of Oast & Hook. He practices in the areas of estate planning, elder law, estate and trust administration, Medicaid asset protection planning, and special needs trusts. Mr. Hook is certified as an Elder Law Attorney by the National Elder Law Foundation. He is a Fellow of the American College of Trust and Estate Counsel and a Fellow of the National Academy of Elder Law Attorneys. Additionally, Mr. Hook is the co-author of Representing the Elderly or Disabled Client, published by RIA. He is President of the Board of Directors of the Special Needs Alliance, an organization of attorneys serving the needs of persons with disabilities. Mr. Hook is also a Certified Financial Planner™ professional.
Durable Powers of Attorney (Portfolio 859) Edward B. Horahan IIIEd Horahan currently acts as of counsel to the Groom Law Group, Chartered, in Washington, D.C. A 1976 graduate of Yale Law School, he formerly served on the staff of the Securities and Exchange Commission and litigated ERISA cases while with the Solicitor's Office of the Department of Labor. In the private sector, he was a partner in the Washington offices of New York City law firms and the proprietor of his own law practice.
ERISA — Fiduciary Responsibility and Prohibited Transactions (Portfolio 365) Richard M. Horwood, Esq.Mr. Horwood is with the law firm of Horwood Marcus & Berk Chtd. He has written extensively in legal journals and other trade publications, and has lectured throughout the United States on various business, estate, and tax-related issues. Mr. Horwood is a Fellow of the American College of Trust and Estate Counsel (ACTEC) and is associated with numerous professional organizations, including the advisory boards of Tax Management, The Journal of Corporate Taxation, The Journal of Taxation of Investments, Personal Financial Planning, and the Chicago Estate Planning Council. He is a graduate of Colgate University and the University of Pennsylvania Law School. He also holds an M.B.A. degree in Financial Management from American University and an LL.M. in Taxation from George Washington University. Mr. Horwood was formerly with the National Office of the Internal Revenue Service in Washington, D.C.
Managing Litigation Risks of Fiduciaries (Portfolio 857)Estate Planning for the Unmarried Adult (Portfolio 813) Kendall HoughtonMs. Houghton was a partner with the state and local tax practice group of Alston & Bird, LLP, when this Portfolio was originally written. From September 1993 through December 1997, she served as General Counsel to the Committee On State Taxation (“COST”), a nonprofit trade association that promotes the equitable and nondiscriminatory state and local taxation of multijurisdictional business entities through judicial and legislative advocacy, educational efforts, and policy development. Prior to joining COST, Ms. Houghton served as an associate in the Atlanta, Georgia law firm of Alston & Bird, where her practice focused on state and local tax planning and controversy. Ms Houghton has published numerous articles on state tax and related issues and is a frequent public speaker at conferences hosted by such groups as COST, the Tax Executives' Institute, the Federation of Tax Administrators, the American Bar Association, and the National Association of State Bar Tax Sections. She is a member of the Advisory Board of the State Income Tax Alert and is the Managing and Chief Production Editor of the ABA Section of Taxation's State and Local Tax Lawyer journal. Ms. Houghton received her A.B. degree (cum laude) from Harvard University, her J.D. degree from the New York University School of Law, and her LL.M. in taxation from Emory University School of Law. She is admitted to practice in Georgia.
Unclaimed Property (Portfolio 1600) Harry HoweHarry Howe, B.A., Brown University; MBA (Accounting), Graduate Management Institute, Union College; Ph.D., Union College. Associate Professor and Coordinator of Accounting Program, State University of New York (SUNY), College at Geneseo. Member, New York State Society of CPAs; Rochester chapter of the IMA; Rochester chapter of the FEI; and American Accounting Association. Published work has appeared in The Review of Business Information Systems; The CPA Journal; Journal of Business Valuation and Economic Loss Analysis; Decision Sciences Journal of Innovative Education; Strategy and Games; Strategic Finance; International Quarterly Journal of Marketing; The International Journal of Management; and the Journal of Accounting, Taxation and Finance for Business. Prior to completing doctoral studies and joining the accounting faculty at Geneseo, Dr. Howe managed a NYC-based construction company and practiced as a commercial real estate broker in the Hudson Valley.
Accounts Receivable: Financial Accounting and Auditing (Portfolio 5110)Accounts Receivable: Management and Analysis (Portfolio 5111) Paul HowellPaul M. Howell, MPA, CPA, tax partner with Grant Thornton, LLP (national FAS 109 champion); B.B.A., Management/Marketing, Stephen F. Austin State University (1982); M.P.A., University of Texas at Arlington (1985); Certified Public Accountant, Texas; former Director of Taxes for Furmanite Corporation (formerly known as Xanser Corporation); over 20 years of experience in public accounting.
Accounting for Income Taxes: Fundamental Principles and Special Topics (Portfolio 5001) Helen M. Hubbard, Esq.Helen M. Hubbard, Esq., B.B.A., Texas Tech University (1975); J.D., Southern Methodist University School of Law (1987, magna cum laude); Law Clerk to the Honorable Irving L. Goldberg, U.S. Court of Appeals for the Fifth Circuit (1987-88); Tax Legislative Counsel, United States Department of the Treasury (2002-05); Partner, Baker & McKenzie LLP; member, State Bar of Texas, District of Columbia Bar, American Bar Association Section of Taxation (Council, 2006-present; Chair, Simplification Committee, 2007-present; Assistant Secretary, 2004-05; Chair, Tax Accounting Committee, 1996-98); Adjunct Professor of Law at Southern Methodist University Dedman School of Law (2006) and Georgetown University Law Center (1996-2001); Fellow, American College of Tax Counsel; Certified Public Accountant.
Federal Taxation of Software and E-Commerce (Portfolio 555) Joe Huddleston
Joe Huddleston; University of South Carolina; Nashville School of Law (J.D.); served as commissioner of the Tennessee Department of Revenue (1987-1995); was president of both the Federation of Tax Administrators and the Southeast Association of Tax Administrators; was chief financial officer for the Metropolitan Government of Nashville and Davidson County; was an Internal Revenue Service revenue officer, in private practice; worked at the District Attorney General's office in Cookeville, TN (1984-1987); serves on numerous state tax related boards, is a founding trustee of the Paul Hartman Tax Forum at Vanderbilt University Law School; member of the Tennessee and American Bar Associations; is the Executive Director of the Multistate Tax Commission.
Robert F. Hudson, Jr. Esq.
Robert F. Hudson, LL.M. (Taxation), New York University (1972); J.D., University of Florida (1971); B.S.B.A., Economics, University of Florida (1968); member, Florida and New York Bars; Chairman, S.E. Region, U.S.A. Branch of International Fiscal Assoc. (1984); Chairman, Foreign Tax Advisory Committee of Florida Bar, Tax Section (1983–1985); project chairman and a principal author of the Florida Bar's “Proposed Revisions of Pending FIRPTA Withholding Tax Bill (Feb. 10, 1984)” which was essential basis of Code Section 1445 enacted as part of the Deficit Reduction Act of 1984; Contributor to: Tax Management International Journal, Tax Management Real Estate Journal, Tax Planning International Review, Lawyer of Americas, American Bar Journal, Florida Bar Journal, Florida Bar International Law Quarterly; Speaker, World Trade Institute, International Fiscal Association — U.S.A. Branch, International Tax Planning Association, Florida Bar, Florida Institute of CPAs, Quebec Bar Assoc., University of Florida, University of Miami, Universite Laval, University of Netherlands Antilles, and University of Barbados.
Martha L. Hutzelman, Esq.Martha L. Hutzelman, Ohio Northern University (B.A. 1979), University of Arizona (J.D. 1982); formerly, Senior Attorney, Office of Associate Chief Counsel (Employee Benefits and Exempt Organizations), Internal Revenue Service; Member of the Oklahoma, Virginia, United States Tax Court, and United States Supreme Court Bars; Chair-Elect of the American Bar Association, Tort and Insurance Practice Section, Committee on Employee Benefits; Member of American Bar Association Joint Committee on Employee Benefits; and Member of the American Bar Association Section of Taxation, Committee on Employee Benefits.
Employee Benefits for Small and Mid-Sized Employers (Portfolio 353)Qualified Plans — Taxation of Distributions (Portfolio 370)
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Karen Irby, Managing Editor, State Tax and Accounting
Karen Irby, Managing Editor-State Tax and Accounting, has 20 years experience with BNA Tax & Accounting, 16 of those years specializing in state and local tax matters. She assumed management of BNA’s SALT products in 1997, products which now include the BNA Portfolios, Weekly State Tax Report, the State Tax Digest, and the Green Incentives Navigator. In 2006, she added managing editor responsibilities for the Accounting Policy and Practice Series Portfolios. She received her undergraduate degree from the University of Southern Mississippi and a Juris Doctor from Loyola University New Orleans.
Kathy Davidson Ireland, Esq.Kathy Davidson Ireland, B.S., Lebanon Valley College (1977); J.D., Order of the Coif, Marshall-Wythe School of Law, College of William & Mary; Executive Editor for Student Contributions, William & Mary Law Review (1980), LL.M., Labor Law, The National Law Center, George Washington University (1982); member: District of Columbia Bar, Maryland Bar.
Qualified Plans — IRS Determination Letter Procedures (Portfolio 360)
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C. Leonard Jacobs, Jr.C. Leonard Jacobs is a project manager, Tax Operations, with Intuit Corp., in Reno, Nev. Previously he has held payroll-related positions with McDonnel Douglas and Boeing, and more recently with Sage Software and the former FLS, Inc. He is a past chair of the Communications Subcommittee of the IRS Information Reporting Program Advisory Committee.
Payroll Library Henry Jaenicke
Henry R. Jaenicke, A.B., Dartmouth College, 1956; M.B.A., The Wharton School, 1958; Ph.D., University of Pennsylvania, 1963; C.P.A., District of Columbia (inactive); C. D. Clarkson Emeritus Professor of Accounting, Drexel University, Philadelphia; co-author of the Tenth, Eleventh, and Twelfth Editions of Montgomery’s Auditing; author, articles on accounting and auditing; co-author, chapter on revenue and receivables in several editions of the Accountants’ Handbook; consultant and expert witness on accounting and auditing issues.
Craig L. Janes, CPACraig L. Janes, Principal, National Director of Estate, Gift and Trust Services, Deloitte & Touche. B.S., Accounting, Utah State University (summa cum laude, valedictorian) (1985); M.P.A., University of Texas at Austin (1988). Certified Public Accountant, Texas. Member, AICPA. Editorial Board, Estate Planning (WG&L). Frequent writer and speaker on estate and post mortem planning and estate administration topics.
Estate, Gift, and Generation-Skipping Tax Returns and Audits (Portfolio 822) Patricia Januszewski
Ernst & Young LLP's Business Tax Compliance division
Phillip JelsmaMr. Jelsma received a B.S. degree from the University of Southern California in 1979 and a J.D. from Stanford Law School in 1986. After clerking for Judge Howard Turrentine, he became associated with the law firm of Luce, Forward, Hamilton & Scripps in San Diego, California. Mr. Jelsma joined the partnership of Luce, Forward in 1995. Mr. Jelsma is also a public accountant, certified in the state of California. Mr. Jelsma is a member of the Executive Committee of the Tax Section of the California Bar and the former Chair of the Real Estate and Passthroughs Committee. He is an adjunct professor of law at the University of San Diego where he teaches courses in the taxation of real property and limited liability companies. Mr. Jelsma also served as a Tax Section Liaison to the California Limited Liability Drafting Committee and assisted in drafting two technical clean–up bills. Mr. Jelsma has lectured extensively on the subject of limited liability companies for organizations such as the California Bar, the California Society of CPAs, and CLE International. He is the author of a column on state taxation of pass–through entities that appears regularly in The California Tax Lawyer. Mr. Jelsma is also the author of a chapter discussing the tax treatment of LLCs in the book Forming and Operating California Limited Liability Companies.
State Taxation of Limited Liability Companies and Partnerships (Portfolio 1560) Carl M. Jenks, Esq.Carl M. Jenks, J. D. Harvard Law School (1980); Ph.D. Duke University (1979), M.A. Duke University (1973); B.A. Carleton College (1967).
Corporate Bankruptcy (Portfolio 790) Anna Johansson
Christian Johnson, CPA, Esq.Christian A. Johnson, J.D., CPA, formerly with Price Waterhouse (now PriceWaterhouseCoopers) is a Professor of Law, at Loyola University Chicago School of Law. He teaches and has published extensively on derivatives, repos, and banking, authoring four books and over 35 articles on the different subjects. Professor Johnson received his law degree from Columbia Law School where he was executive editor of the Columbia Law Review. He received his Masters and Bachelor's Degree in Accounting from the University of Utah.
Accounting and Disclosure for Derivative Instruments (Portfolio 5112) J. Walker Johnson, Esq.
J. Walker Johnson; Georgetown University Law Center, LL.M., Taxation, 1984; The University of Kansas School of Law, J.D., 1978, William L. Burdick Prize, Senior Articles Editor, Kansas Law Review, Order of the Coif ; Cornell University, B.A., 1975. Since 1987, Mr. Johnson has served as an Adjunct Professor of Law in the Graduate Tax Program at the Georgetown University Law Center and teaches a course entitled Taxation of Financial Institutions and Products, which covers the taxation of life insurance companies, property/casualty insurance companies, banks and thrifts, RICs, REITs, REMICs, captive insurance, and financial products; is currently a partner in the Washington office of Steptoe & Johnson LLP, where he is a member of the Business Solutions Department. Johnson’s practice focuses on tax controversies and tax litigation, and tax planning.
Susan JonesMs. Jones, formerly Vice President – Client Resource Group for DuCharme, McMillen & Associates Inc., is a state tax consultant practicing in Naples, Florida. She also previously served as Director of State & Local Taxes for PepsiCo Inc. While at PepsiCo, Susan was responsible for all state and local tax matters for this Fortune 15 company. She received her B.A. in Environmental Science from the University of Virginia and her Masters in Taxation from Virginia Commonwealth University (Dean's Scholar). Susan has served on the Executive Committee of COST and the state tax committee of Tax Executives Institute. Currently, she serves on the Finance and Tax Committee of the Florida Chamber of Commerce, and is Chair of the State Tax Committee of the FICPA. She also is a consulting editor for Interstate Tax Insights. She has been a frequent lecturer at national tax symposiums and has published several articles on various state tax issues.
Sales and Use Taxes: Retail Sales Issues (Portfolio 1360) Warren Joseph, Esq., Federal Tax Law Editor
Warren M. Joseph, Esq. is a Federal Tax Law Editor at BNA Tax & Accounting where he specializes in energy and natural resources tax issues. Warren came to BNA in 2005 after retiring from the IRS Office of Chief Counsel. He has an A.B. from Colgate University, a J.D. from Georgetown University Law Center, and is a member of the Maryland bar. He is a contributing editor for the Weekly Report.
Geraldine Josephina, Esq.Geraldine C. Josephina, graduated in Dutch tax law from the University of Leiden, The Netherlands (1990); senior tax law practitioner, Loyens & Loeff, Curaçao, rendering advice on Netherlands Antilles and Aruba tax matters.
Business Operations The Netherlands Antilles (Portfolio 974)
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Gerald A. Kafka, Esq.Gerald A. Kafka, B.S., Wheeling Jesuit University, 1972, J.D., University of Cincinnati College of Law, 1975, LL.M (Taxation), Georgetown University Law Center, 1979; Partner, Latham & Watkins LLP, Washington, DC; member of District of Columbia Bar; author of treatise (Litigation of Federal Civil Tax Controversies) and multiple articles and monographs on tax controversy topics; regular speaker on tax controversy topics, including ALI-ABA programs and as adjunct professor at Georgetown University Law Center.
Reasonable Compensation (Portfolio 390) Atsuko Kamen
Atsuko Kamen, Ph.D., is a member of KPMG LLP's global transfer pricing services practice and is a managing director in the New York office.
Gil Won Kang
Gil Won Kang is a director with Deloitte Anjin global transfer pricing group specializing in APA and competent authority negotiation matters.
Jared Kaplan, Esq.Jared Kaplan, University of California at Los Angeles (A.B. 1960), Harvard University (LL.B. 1963); member, Illinois Bar. Past Chairman, Legislative and Regulatory Advisory Committee, The ESOP Association.
ESOPs (Portfolio 354) Richard L. Kaplan
Professor Richard Kaplan, the Peer and Sarah Pedersen Professor of Law, graduated from Indiana University with highest honors and earned his law degree from Yale University. He practiced law in Houston with Baker & Botts, specializing in U.S. tax consequences of international transactions, before joining the faculty in 1979. An internationally recognized expert on U.S. taxation and tax policy, he has lectured in these areas on three continents, testified before the U.S. Congress on several occasions, and written innovative course books on income taxation and international taxation. Professor Kaplan is a Fellow of the Employee Benefits Research Institute and a member of the National Academy of Social Insurance. He served on a 12-member panel on The Future of the Health Care Labor Force in a Graying Society, chaired by former U.S. Secretary of Labor Lynn Martin. In 2002, he was a delegate to the National Summit on Retirement Savings organized by the U.S. Department of Labor.
Madhvi Kapur
PricewaterhouseCoopers, San Francisco
Deborah Karet
Deborah Karet is a senior manager in KPMG's Washington National Tax's Excise Tax Practice and a former senior attorney in the Excise Tax Branch in the IRS Office of Associate Chief Counsel (Passthroughs and Special Industries).
Lawrence P. Katzenstein, Esq.
Lawrence P. Katzenstein, Harvard Law School (J.D., 1972), Washington University (A.B., 1969); adjunct professor at the Washington University School of Law for both estate and gift taxation and fiduciary income taxation; member of Missouri Bar, American Bar Association Section of Taxation, Bar Association of Metropolitan St. Louis and American College of Trust and Estate Counsel; former chair of the American Bar Association Tax Section Fiduciary Income Tax Committee, current chair of several Tax Section charitable planning subcommittees, fellow of the American College of Trust and Estate Counsel; listed in Best Lawyers in America in the trusts and estates category; currently with Thompson Coburn, LLP.
Ira Kawaller
Ira G. Kawaller, Ph.D., the Kawaller Fund and Kawaller and Co. Before founding these organizations, Dr. Kawaller held positions with the Chicago Mercantile Exchange, J. Aron & Company, AT&T, and the Board of Governors of the Federal Reserve System. He received a Ph.D. in economics from Purdue University and has held adjunct professorships at Columbia University and Polytechnic University. He serves on the Governmental Accounting Standards Board's Task Force on Derivatives and Hedging.
Akemi Kawano, Esq.Akemi Kawano, B.M., The Julliard School (1989), M.M., The Julliard School (1991), D.M.A., Manhattan School of Music (1999), J.D., with Honors, George Washington University Law School (2002); associate in the Washington, D.C. office of Alston & Bird LLP; serves as general counsel of the Japan America Society of Washington, D.C.
Income Tax Treaties — Administrative and Competent Authority Aspects (Portfolio 940) Marianne R. Kayan
Marianne Kayan served as an associate attorney with two Maryland law firms where she concentrated on estate planning, estate administration and tax. Marianne excels and enjoys working with a diverse group of clients, including non-US citizens, couples with young children, families with complex dynamics, nontraditional families, retirees, entrepreneurs and established business owners. Marianne is affiliated with Real Property, Trust and Estate Law Section; Publications Committee 2009-2010; Fellow to the Section 2007-2009; Fiduciary Income Tax Group’s International Tax Planning Committee; Tax Section; Young Lawyers Section, American Bar Association, Estates, Trusts and Probate Section, District of Columbia Bar; Estate and Trust Law Section, Maryland Bar Association; Estate and Trust Law Section, Montgomery County Bar Association, Society of Financial Services Professionals. Ms. Kayan is currently with Buchanan Ingersoll & Rooney PC, Washington, D.C.
Yoram Keinan, Esq.Yoram Keinan, B.A., LL.B., Tel Aviv University; LL.M. (Taxation), Hebrew University; M.B.A., Bar Ilan University; M.P.A., LL.M. (International Taxation), Harvard University; LL.M. (Taxation), J.S.D., University of Michigan. As Counsel with Greenberg Traurig, Mr. Keinan specializes in United States taxation of financial products and institutions and represents major investment banks and financial institutions in the United States. Prior to joining Greenberg Traurig, Mr. Keinan was with Ernst & Young's National Tax Department in Washington, D.C. Before that, Mr. Keinan practiced with Shearman & Sterling and with Ernst & Young's tax department in Israel. He has authored numerous articles and has taught Harvard's International Tax Program, Kennedy School of Government, and School of Arts and Sciences (Department of Economics).
Accounting for Debt Instruments (Liabilities) (Portfolio 5105)The Economic Substance Doctrine (Portfolio 508) Deborah Keisner
Deborah Keisner, Ph.D. economist, is a manager in DeLoitte Tax LLP's New York office.
Gail S. Keller
Gail S. Keller reported on state and local tax issues in Prince William County, Va., for more than a decade, ultimately publishing and managing her own newspaper, which grew to a weekly circulation of almost 40,000. She also has worked for Rep. Jack Brooks (D-Texas) and Rep. Silvio Conte (R-Mass.) covering federal legislation, and joined BNA in 1999 as a copy editor on the Daily Tax Report staff.
Larry R. Kemm, Esq.Larry R. Kemm, B.S. (1984), University of Missouri – Kansas City; J.D. (1992, summa cum laude), Indiana University School of Law; Associate Editor, Indiana Law Review; Certified Public Accountant (Texas); Board Certified, Tax Law, Texas Board of Legal Specialization (1997–2002); past Chair, Controlled Group Subcommittee, ABA Tax Section, Affiliated and Related Corporations Committee; frequent speaker on international tax subjects at various institutes and seminars; Treasurer and member of Steering Committee, Midwest Region, International Fiscal Association; admitted to practice, Texas, Illinois, U.S. Tax Court, and U.S. District Court for the Northern District of Texas.
CFCs — Sections 959-965 and 1248 (Portfolio 930) David I. Kempler, Esq.David I. Kempler, J.D., 1966, University of Connecticut; LL.M., 1967, The George Washington University Law School, taxation; B.S., 1963University of Pennsylvania. Mr. Kempler is admitted to Connecticut, District of Columbia and the United States Supreme Court. He focuses his practice on corporate tax, business planning and not-for-profit (especially in the health care area) tax matters. He advises clients on a broad range of tax issues involving mergers and acquisitions, closely held entities, joint ventures and planning for health care entities. David is editor of the Corporate Tax and Business Planning Review and has written many articles in the tax area. He is a frequent speaker at tax conferences and is a member of the Corporate Relationships and Exempt Organizations Committee of the American Bar Association Section of Taxation. In 2006, he was selected by his peers for inclusion in The Best Lawyers in America. He is affiliated with the District of Columbia Bar, Federal Bar Association and the American Bar Association.
Boot Distributions and Assumption of Liabilities (Portfolio 782) Jennifer D. Kennedy, CPAJennifer D. Kennedy, B.S., Washington and Lee University; M.S.T., American University; member, American Institute of Certified Public Accountants; member, Virginia Society of Certified Public Accountants.
Accounting Methods — Adoption and Changes (Portfolio 572) Kathryn J. KennedyKathryn J. Kennedy; Drake University (B.S., with honors, 1974); Fellow of the Society of Actuaries (F.S.A., 1976); Northwestern University School of Law (summa cum laude, Order of the Coif, Article Editor for the Northwestern University Law Review, 1980); Professor of Law and Director of the Center for Tax Law and Employee Benefits, John Marshall Law School; member of the ABA Section of Taxation; former chair of the ISBA Employee Benefits Section Council; chair of the CBA Employee Benefits Committee.
IRAs (Portfolio 367)SEPs and SIMPLEs (Portfolio 368) J. Edward KetzJ. Edward Ketz, Ph.D., a member of the Penn State faculty since 1981, has authored and edited 17 books, including Hidden Financial Risk (Wiley, 2003) and Accounting Ethics (Routledge, 2006). Professor Ketz has been cited frequently in the popular and business press, including The Wall Street Journal, The New York Times, The Washington Post, Business Week, Fortune, USA Today, and Chicago Tribune, on topics such as accounting for stock compensation, business combination accounting, accounting for derivatives, and evaluations of specific corporate accounting practices at Enron, Tyco, Rite Aid, HealthSouth, AIG, CVS, Starbucks, Krispy Kreme, and others. He also has appeared as an accounting commentator on CNBC, CNNfn, and National Public Radio. Dr. Ketz writes a column about financial reporting issues, “Accounting Cycle: Wash, Rinse, and Spin,” which appears on SmartPros.com.
Fair Value Measurements: Valuation Principles and Auditing Techniques (Portfolio 5127) Lee Khvat, Esq.Lee Khvat is an associate in the law firm of McDermott Will & Emery UK LLP, based in its London office. He is a member of the Tax Department, where his practice focuses on a range of corporate tax matters.
Business Operations the United Kingdom (Portfolio 989) Tae-Hyung Kim
Tae-Hyung Kim, a senior transfer pricing partner and Ph.D. economist with Deloitte Anjin in Seoul, is the firm's national leader in its global transfer pricing group.
Woo Taik Kim, Esq.Woo Taik Kim, Seoul National University (B.A., 1970); Columbia University (M.B.A., 1972); tax partner, Kim & Chang, Seoul; Member, Korean Institute of Tax Attorneys, Korean Institute of Certified Public Accountants, New York State Society of Certified Public Accountants, International Fiscal Association.
Transfer Pricing: Foreign Rules and Practice Outside of Europe, Part 2 (Portfolio 898)Business Operations the Republic of Korea (Portfolio 970) Barbara L. Kirschten, Esq.Barbara L. Kirschten, B.A., University of Pennsylvania (summa cum laude); Honours B.A., Cambridge University; Ph.D., M.A., Harvard University; J.D., Northwestern University; member, New York and District of Columbia Bars; former member, Steering Committee District of Columbia Bar Association Taxation Section and former Chair, Exempt Organizations Committee; Co-Chair, Subcommittee on Museums of Other Cultural Organizations, Exempt Organizations Committee, ABA Section of Taxation; author, The Nonprofit Corporation Forms Handbook; co-author, Federal and State Taxation of Exempt Organizations.
Charitable Contributions: Income Tax Aspects (Portfolio 521)Charitable Contributions: Income Tax Aspects (Portfolio 863) Joe Kirwin
Joe Kirwin is the Brussels Staff Correspondent at BNA Tax and Accounting's Accounting Policy & Practice Report.
Martha A. Klasing, CPAMartha A. Klasing, B.S., Southern Illinois University — Carbondale; Master of Accounting (Taxation), University of Missouri – St. Louis; Partner, KPMG LLP; Certified Public Accountant; member, American Institute of Certified Public Accountants; contributor: Tax Management International Journal; International HR Journal; Tax Management Compensation Planning Journal; frequent speaker on international tax issues and developments.
Section 911 and Other International Tax Rules Relating to U.S. Citizens and Residents (Portfolio 918) James KleierMr. Kleier is a graduate of Thomas More College (B.A. 1976) and the University of Kentucky College of Law (J.D. 1979). He was Survey and Comments Editor of the Kentucky Law Journal and a member of the Order of the Coif.Mr. Kleier is active in local and national bar activities. He was previously the American Bar Association Section of Taxation's Chair of the Special Project Task Force of the Administrative Practice Committee and is also past Chair of the San Francisco Bar Association's Barristers Club Tax Section. He has taught California State Taxation at Golden Gate University and is a regular lecturer on criminal tax at the University of California's Hasting College of the Law. He has written and lectured extensively on state and local taxation and on federal tax controversies, including “Sales and Use Tax Consequences of Mergers and Acquisitions” for the center for State and Local Taxation at the University of California (Davis). “Prospectivity of Decisions Invalidating State Tax Laws” for the Federation of Tax Administrators, “State Tax Procedural Tips and Traps” for the Committee On State Taxation, “Current State Tax Issues” for the Continental Association of Certified Public Accountants, and “Sales and Use Tax Exemptions” (with James B. Ellis) for the Matthew Bender treatise California Taxation. He has also written articles on tax indemnity clauses and purchase price allocations for Taxation for Lawyers, and has written articles on various aspects of state taxation for Interstate Tax Insights and International Tax Review.Mr. Kleier specializes in tax litigation and the administrative resolution of tax controversies in the United States Supreme Court, the United States Tax Court, and other federal and California courts, as well as handling controversies at the administrative level before the Internal Revenue Service, in California, and in nearly a dozen others states. He represented Colgate–Palmolive Co. in its constitutional challenge to worldwide combined reporting in the United States Supreme Court.
Mergers and Acquisitions: Sales and Use Tax Consequences (Portfolio 1530) James P. Klein, Esq.James P. Klein, J.D., Columbia University Law School (1972), LL.M. in taxation, New York University Law School (1979), B.A., Fordham University (1968); member, New York State Bar; member, past chair, Employee Benefits Committee, Section of Taxation, American Bar Association; member, past chair, Employee Benefits Committee, Tort and Insurance Section, American Bar Association; member, Tax Management Advisory Board; founding member and past chair, International Pension and Employee Benefits Lawyers Association (IPEBLA).
International Pension Planning (Portfolio 320) Michael J. Kliegman, Esq.Michael J. Kliegman, A.B., University of Pennsylvania; J.D., Boston University School of Law, LL.M. (Taxation), Georgetown University Law Center; member: American Bar Association, Tax Section (Corporate Tax Committee; Task Force on Acquisitions Involving S Corporations); New York State Bar Association, Tax Section (Committee on Reorganizations); formerly, Internal Revenue Service, Office of Chief Counsel, Reorganization Branch (1981–85), Group Chief (1984–85).
Single Entity Reorganizations: Recapitalizations and F Reorganizations (Portfolio 774) Steven E. KligSteven E. Klig, B.A. (cum laude), C.U.N.Y., Queens College; J.D. (cum laude), Fordham University School of Law; LL.M. (Taxation), New York University School of Law; member, American Bar Association and the New York State Bar Association and their respective Tax Sections; admitted to practice in New York, Colorado, Connecticut, and the District of Columbia; speaker, various conferences including the American Bar Association and the Bank Tax Institute; author, various articles in NYU Institute of Taxation, Tax Management Memorandum, and Tax Planning for Domestic & Foreign Partnerships, LLCs, Joint Ventures, & Other Strategic Alliances (Practising Law Institute).
Partnerships — Taxable Income; Allocation of Distributive Shares; Capital Accounts (Portfolio 712) Daniel C. Knickerbocker, Jr.Daniel C. Knickerbocker, Jr., A.B., Syracuse University (1940); J.D., Cornell University (1950); Advanced Management Program, Harvard University Graduate School of Business Administration (1969). Member of the New York and Massachusetts Bars. Member, American Bar Association; Association of the Bar of the City of New York; American Law Institute; Association of Life Insurance Counsel; Society of American Law Teachers.
Subchapter J — Throwback Rules (Portfolio 856) Michael Knight
Michael Knight; Fairfield University, 1973, degree in marketing; University of Bridgeport, MBA. Mr. Knight is a frequent speaker at small business planning forums and has appeared before the U.S. Congress and the Internal Revenue Service (IRS) on small business issues such as Sec. 83 and 2036 repeal, the unavailability of capital, and independent contractor hearings. He most recently (1997) chaired the New York State Society of CPA's Task Force on the Commission for Restructuring the IRS and testified in Washington before the national commission. He has appeared on CNBC, MSNBC, and WBIZ and is regularly interviewed by business publications including the Wall Street Journal, Inc. Magazine, Money magazine, Accounting Today, Business Week, USA Today, Journal of Taxation, and the Tax Adviser. Mr. Knight is a member of The American Institute of Certified Public Accountants, the Connecticut Society of Certified Public Accountants, the New York State Society of Certified Public Accountants, the Association of Certified Fraud Examiners, and the National Association of Certified Valuation Analysts. Currently serves as Principal, Michael J. Knight & Company, CPAs.
Neal Kochman, Esq.
Neal M. Kochman, Esq. is with Caplin & Drysdale, Chartered in Washington, D.C. and is a frequent contributor to BNA's International Journal.
Mark KohlbeckMark A. Kohlbeck, Ph.D., The University of Texas at Austin; M.B.A., Southern Methodist University; B.B.A. (Accounting), The University of Wisconsin - Whitewater. Dr. Kohlbeck is a former auditor and management consultant for Deloitte & Touche. His practice experience includes restructuring troubled financial institutions, mergers and acquisitions, and litigation support. Dr. Kohlbeck has written for numerous journals including Contemporary Accounting Research; Journal of Accounting, Auditing, and Finance; and Issues in Accounting Education. Dr. Kohlbeck is an assistant professor with the School of Accounting at Florida Atlantic University in Boca Raton, Florida, where he teaches financial accounting. He has taught financial accounting courses at the University of Wisconsin—Madison, Southern Methodist University, and The University of Texas at Austin. Dr. Kohlbeck is a member of Beta Alpha Psi, Beta Gamma Sigma, the AICPA, and the American Accounting Association.
Accounting for Investments Debt Securities (Portfolio 5106) Adil K. KotwalAdil K. Kotwal, B.Com, F.C.A., Bachelor of Commerce, University of Bombay (1978), Fellow of the Institute of Chartered Accountants of India. He joined the firm in 1978 and is currently the Managing Partner and partner responsible for the firm's international and corporate finance practice. He has served as visiting faculty with the University of Bombay teaching Accountancy and Taxation.
Business Operations India (Portfolio 966) George C. Koutouras, Esq.George C. Koutouras, LL.M. (Taxation), Georgetown University Law Center; J.D., University of Detroit School of Law; B.S.A., University of Michigan; bar membership, Michigan and Illinois; formerly Attorney/Advisor to Special Trial Judge Stanley J. Goldberg, United States Tax Court; Co-Author, 767-2nd T.M., Redemptions and 564 T.M., Related Party Transactions; Adjunct Professor, University of Illinois Urbana-Champaign Master of Tax Program.
Related Party Transactions (Portfolio 564)Redemptions (Portfolio 767)Stock Sales Subject to Section 304 (Portfolio 768)Boot Distributions and Assumption of Liabilities (Portfolio 782) James KratochvillMr. Kratochvill received his B.A. degree from the University of Pittsburgh in 1969 and his J.D. degree from the Case Western Reserve School of Law in 1972, where he was an editor of the CWRU Law Review and Order of the Coif. Mr. Kratochvill is General Attorney for AT&T Corp. responsible for all state and local tax legal advice and assistance, and has been state and local tax counsel for AT&T since 1975. He is Chair of the Sales & Use Tax Subcommittee, Committee On State Taxation and a former Subcommittee Chair of the American Bar Association Committee on State and Local Taxes. He has served frequently as an instructor at the annual Tax Executive Institute State and Local Tax Course and has participated in several tax institutes and seminars. Mr. Kratochvill is a member of the Ohio and New Jersey Bars.
Sales and Use Taxes: Communications Services and Electronic Commerce (Portfolio 1350) Gregory KrockGregory J. Krock is a shareholder with Buchanan Ingersoll PC and a member of its Commercial Litigation Group. Mr. Krock's practice involves a wide range of commercial matters, including trade secret and covenant not to compete litigation, securities fraud and shareholder suits, and professional/accounting liability actions. Mr. Krock has written on the use of protective orders for the firm's national White Paper Series. Mr. Krock received a B.S. in Business Administration from the University of North Carolina at Chapel Hill and a J.D. from the University of Pittsburgh.
Preparing for and Defending Accounting Liability Litigation (Portfolio 5500) Keith KrugerKeith H. Kruger, CPA, is a Senior Manager at KPMG LLP in Stamford, Connecticut. Mr. Kruger is also a member of the firm's state and local tax practice. A graduate of the University of Connecticut, Mr. Kruger is a member of the American Institute of Certified Public Accountants and the Connecticut Society of Certified Public Accountants.
Connecticut Corporate Business Tax (Portfolio 1960) Kenneth J. Krupsky, Esq.Kenneth J. Krupsky, Tax Partner, Jones Day (Washington, DC); Columbia LawSchool (J.D. 1972; Harlan Fiske Stone Scholar; International Fellow;Columbia Law Review; Comments and Case Notes Editor, Columbia Journal ofTransnational Law); Columbia College (B.A. in Philosophy 1969; NationalMerit Scholar). Served as Deputy Assistant Secretary of the Treasury forTax Policy, U.S. Treasury Department in President Clinton's second term,Chair of the International Tax Committee of the District of Columbia BarAssociation, and Adjunct Professor at Georgetown University Law Center.Member of Tax Management International Journal's "Panel of LeadingPractitioners" and regularly contributes to that journal. Otherpublications include: Joint Ventures with International Partners (coauthor, Butterworth 1994); and International Joint Ventures coauthor, Federal Publications 1986; 2d ed. 1988). Regularlylisted as a leading tax lawyer in Chambers USA, Euromoney's InternationalTax Review (one of the "world's leading tax advisers" and "world's leadingtransfer pricing advisers"), and Super Lawyers.
Transfer Pricing: Alternative Practical Strategies (Portfolio 890) Laura KulwickiLaura A. Kulwicki was special counsel to Jones, Day, Reavis & Pogue in Cleveland, Ohio when this Portfolio was originally written. Ms. Kulwicki received her B.A. degree from The Ohio State University in 1984 and her J.D., with honors, from The Ohio State University in 1987. A member of the American Bar Association, Ohio State Bar Association, and Cleveland Bar Association, Ms. Kulwicki has published numerous articles on state taxation which have appeared in such publications as State Tax Notes, CCH State Tax Review, and Banks Baldwin Ohio Tax Service. She also has lectured for the Council On State Taxation and other local tax organizations.
Limitations on States' Jurisdiction to Impose Sales and Use Taxes (Portfolio 1420)Recovery of Attorney's Fees State Tax Controversies (Portfolio 1590) Michael G. Kushner, Esq.Michael G. Kushner, B.A., George Washington University (1974); J.D., University of Virginia School of Law (1977); LL.M. (Taxation), George Washington University (1982). Co-author, The Employee Benefits Desk Encyclopedia (BNA Books, 1995); Retirement & Welfare Benefit Plans (BNA Books, 1989); co-editor, ERISA, The Law and the Code (BNA Books); co-editor, ERISA Regulations (BNA Books). Member, District of Columbia, Maryland and Virginia Bars. Adjunct faculty member, Georgetown University Certified Employee Benefits Specialist Program (1982-88); adjunct faculty member, The Dickinson College School of Law (1989-91).
Multiemployer Plans — Special Rules (Portfolio 359)Reporting and Disclosure Under ERISA (Portfolio 361) Kalle KylakallioKalle Kyläkallio, LL.B., 1993 (University of Lapland), Varatuomari, 1995 (“lawyer trained in the court”),Address: Susiluoto Attorneys-at-Law Ltd, Uudenmaankatu 16 B, 00120 Helsinki, Finland, Tel:+358 9 6869 110, Fax: +358 9 6869 1169
Business Operations Finland (Portfolio 960)
L
Steven Lainoff
Steven R. Lainoff is with KPMG LLP in Washington, DC and is a frequent contributor to BNA's International Journal.
Ron M. Landsman, Esq.Ron M. Landsman, University of Michigan (B.A. 1970), University of Michigan Law School (J.D., magna cum laude, 1974); admitted to practice in Maryland, District of Columbia, and before U.S. Supreme Court; Fellow and founding member of American Academy of Elder Law Attorneys; Chairman, Maryland State Bar Association Elder Law Section (1997–98); regularly writes for The Elder Law Report and the Journal of Asset Protection.
Planning for Disability (Portfolio 816) Andrea M. Lane, Esq.Andrea M. Lane; B.S. Acc., University of Florida; J.D., The George Washington University Law School; LL.M., New York University School of Law; Associate, Alston & Bird LLP (2001-present); Member, American Bar Association (Section of Taxation); Co-author of articles appearing in the Journal of Taxation, the Journal of Financial Instruments and the International Tax Review; Admitted to the bars of Virginia and the District of Columbia; Licensed as a certified public accountant in Virginia.
Sarbanes-Oxley: Auditor Independence (Portfolio 5502) Brian J. LaneBrian J. Lane is a partner in the Washington, D.C. office of Gibson, Dunn & Crutcher. Mr. Lane focuses on securities regulation and disclosure issues and sophisticated capital markets counseling. He represents U.S. and foreign clients in proxy contests, complex mergers and acquisitions, public and private offerings and corporate governance matters. Mr. Lane received his law degree in 1983 from the American University, Washington College of Law. He has served as an adjunct professor of law at Georgetown University Law Center. Before joining Gibson, Dunn & Crutcher, Mr. Lane served at the Securities and Exchange Commission (SEC) for 16 years, where he held a variety of positions. Mr. Lane served as Director of the Division of Corporation Finance, Counsel to Chairman Arthur Levitt, Counsel to Commissioner Richard Roberts, and staff attorney with the Corporation Finance and Market Regulation Divisions.
Management's Discussion and Analysis (Portfolio 5107) Daniel S. LangeDaniel S. Lange, B.B.A., 1981, M.S., taxation, 1983, University of Wisconsin; managing partner, U.S. International Tax practice, Deloitte Tax LLP, 2002–present; tax partner, International Tax Specialty Team, Arthur Andersen, Milwaukee, Wisconsin, 1992-2002, manager, 1986-1991, staff, 1983-1985; member AICPA, WICPA; speaker, international tax issues; author, numerous articles on international tax issues.
The Allocation and Apportionment of Deductions (Portfolio 906)Foreign Corporation Earnings and Profits (Portfolio 932) Franklin C. Latcham, Esq.Frank Latcham is a graduate of the University of Washington (1943) and received his legal education at the University of Washington (LL.B. 1944) and Yale University (J.S.D. 1951). He taught at Case–Western Reserve University Law School from 1948 to 1954. He became an associate of the firm of Morrison & Foerster in 1954, a partner in 1961, and Senior of Counsel in 1986. Mr. Latcham is a past chairman of the Committee on State and Local Taxes of the ABA Section of Taxation and of the Committee on Standards of Tax Practice. He has written extensively in the field of state and local taxation and co–authored (with Prentiss Willson, Jr.) “Franchise and Corporation Income Taxes,” in California Taxes (California Continuing Education of the Bar, 1987). He lectures regularly and has spoken at the University of Southern California Tax Institute, the Georgetown University Institute on State and Local Taxation, and the New York University Institute on State and Local Taxation. He is Chairman of the Advisory Board for the Tax Management Multistate Tax Portfolio Series and is Adjunct Director, Institute of Governmental Affairs, University of California, Davis, California. Mr. Latcham has also been in charge of state and local tax cases in all California administrative agencies and in all California courts, federal courts, administrative agencies, courts in other states, and before the United States Supreme Court.
Income Taxes: Definition of a Unitary Business (Portfolio 1110) Matthew Lay
Matthew Lay is a Director at Deloitte Tax LLP and a contributor to BNA Tax & Accounting's Real Estate Journal.
Werner LedererWerner Lederer, University of Zürich (lic. iur., 1988); Swiss Certified Tax Consultant; member, Swiss Institute of Certified Accountants and Tax Consultants, International Fiscal Association, International Bar Association.
Business Operations Switzerland (Portfolio 986) Cecilia Lee
Cecilia Lee is a transfer pricing partner in PricewaterhouseCoopers' China transfer pricing network.
Gary R. LeeGary R. Lee, B.A., cum laude, University of Connecticut; J.D., McGeorge School of Law, University of the Pacific; L.L.M. in taxation, Boston University School of Law; Member California State Bar; Member Massachusetts State Bar; Certified Public Accountant (CPA); Certified Financial Planner (CFP); field experience as an Advanced Sales Attorney advising on life insurance purchases; Author/Co-author of various life insurance articles in tax publications; Speaker at various life insurance forums. Currently in practice with Sterling Resources, Ltd., of Hingham, Massachusetts.
Life Insurance — A Practical Guide for Evaluating Policies (Portfolio 827) William S. Lee
William S. Lee; 1979 - L.L.M., Taxation, New York University School of Law1975 - LL.B., University of Texas School of Law; 1972 - B.B.A., Accounting and Finance, University of Texas. Mr. Lee’s 30 years of tax controversy experience includes the representation of individuals, trusts, estates, partnerships, corporations, and other entities in IRS examinations, Appeals Office proceedings, and in litigation. Bill strives to resolve tax controversies successfully as efficiently as possible for the client (i.e., at the lowest level possible), but has also litigated cases in U.S. Tax Court, the Court of Federal Claims, and U.S. District Courts around the country.Bill began his professional career in the Tax Department of a “Big Eight” accounting firm and is a certified public accountant. Bill has been a partner in the Tax Department of Fulbright & Jaworski L.L.P. since 1985.Fulbright & Jaworski LLP
Mark Leeds
Mark Leeds; LL.M., New York University School of Law, 1990; J.D., magna cum laude, Boston University School of Law, 1984; B.A., cum laude, Binghamton University State University of New York, 1981. Mark Leeds' professional practice focuses on the United States tax aspects of financial instruments and strategies. Mark is also the editor-in-chief of Derivatives: Financial Products Report, a Thomson/RIA monthly publication. Areas of concentration include structured finance, OTC and market-traded derivatives, financial products, mortgage-backed securities, asset-backed securities, structured products, REITs, RICs and REMICs. Currently with Greenberg Traurig LLC, New York.
Corey Lehr, CPPCorey Lehr, CPP, director of payroll compliance and administration for the University of Cincinnati, is also a past president of the American Payroll Association. He has served previously as an APA Director and Vice President. In 1991, Corey was honored as the first recipient of the Ohio Outstanding Payroll Professional of the Year Award.
Payroll Library Patrick Leslie, Esq.
Patrick S. Leslie, Esq. is an International Tax Editor for BNA Tax & Accounting, and is a contributing editor for the Weekly Report.
Howard J. Levine, Esq.Howard J. Levine, B.A., Hunter College (1969); J.D., State University of New York at Buffalo (cum laude, 1972); LL.M. (Taxation), Georgetown University Law Center (1976); attorney and assistant branch chief, Office of Chief Counsel, Internal Revenue Service (1972-1976); adjunct lecturer in Real Estate Taxation, American University Law School (1980-1982); adjunct professor, The George Washington University Law School and Georgetown University Law Center LL.M. Tax Programs (1982-1993); contributing editor, The Journal of Real Estate Taxation; Tax Management Distinguished Author (2000); member, Advisory Board, Tax Management International Journal; member, Advisory Board, CCH Journal of Taxation of Global Transactions; author, 936 T.M., U.S. Income Tax Treaties — The Limitation on Benefits Article; partner, Roberts & Holland LLP, Washington, D.C. and New York, N.Y.; member, American Bar Association (Chairman, Committee on Sales, Exchanges and Basis, and Subcommittee Chairman, Like Kind Exchanges, Tax Section 1990-1994), New York Bar, District of Columbia Bar, International Fiscal Association.
U.S. Income Tax Treaties — The Limitation on Benefits Article (Portfolio 936) Jay Levine
Ernst & Young LLP's Business Tax Compliance division
Richard A. Levine, Esq.Richard A. Levine, B.S., Economics, University of Pennsylvania (1964); J.D., Harvard Law School (1967); L.L.M., New York University (1968); member, New York, U.S. Tax Court, Court of Federal Claims, U.S. Supreme Court, U.S. Court of Appeals (Second Circuit), U.S. District Court, and Southern and Eastern Districts of New York Bars; editor, Harvard Law Review, 1965-1967; editor-in-chief, Roberts & Holland, Annotated Tax Forms — Practice and Procedure (3d ed.); co-author, “Tax Court's Revised and Expanded Partnership Rules Leave Questions Open,” 69 Journal of Taxation 164 (Sept. 1988); member, The Association of the Bar of the City of New York, New York State and American Bar Associations (Sections on Taxation; Litigation); contributor, Journal of Taxation and other tax periodicals.
Tax Court Litigation (Portfolio 630) Jack B. Levy, Esq.Jack B. Levy, Partner, Balch and Bingham LLP, Birmingham, AL; New York University School of Law, LL.M., in Taxation, 1977; Emory Law School, J.D., 1976; Emory University, B.A., 1973. He is admitted to Alabama and Georgia. Mr. Levy concentrates his practice in the areas of employer resources, employee benefits and executive compensation, corporate and business, health care, taxation and estate and trust planning. He represents numerous closely held businesses, professionals and professional corporations and negotiates and closes sales of professional practices and closely held business practices. He also lectures on issues relating to pension and welfare benefits as well as health care matters. He is listed in The Best Lawyers in America, 1995 Edition - Present (Employee Benefits Law); 2007 Edition (Corporate Law); 2008 Edition (Healthcare Law), and is a member of the American Health Lawyers Association; Southern Employee Benefit Conference; American Bar Association, Tax Section; Alabama State Bar, Tax Section; Alabama Profit Sharing Council; Alabama Super Lawyers, 2009.
Employee Benefits for Small and Mid-Sized Employers (Portfolio 353) Stuart M. Lewis, Esq.
Stuart M. Lewis is on the board of directors of Buchanan Ingersoll & Rooney PC and is head of the firm's Employee Benefits Practice Group. Prior to being elected to the board of directors, Mr. Lewis was the managing shareholder of the Washington, D.C. office of Buchanan Ingersoll & Rooney.Mr. Lewis specializes in employee benefits, including qualified retirement plans, 403(b) plans, nonqualified plans, individual retirement accounts, stock options, employment contracts, mergers & acquisitions and compensation & benefit matters generally. His practice also includes representation as employee benefit expert in litigation and legislative work.Mr. Lewis is a past president of the American Bar Retirement Association. He is also an adjunct professor at the Georgetown University Law Center and is a former chair of the ABA Tax Section's Employee Benefits Committee. In addition, Mr. Lewis is the author of numerous articles and has been interviewed for and quoted in many publications, including The Wall Street Journal, The New York Times, The Washingtonian and The Practical Accountant. Mr. Lewis regularly chairs, moderates and speaks at benefits-related conferences.
Edward H. Lieberman, Esq.Edward H. Lieberman, B.A., C.C.N.Y.; J.D., Brooklyn Law School; LL.M., London School of Economics; member, The District of Columbia and New York Bars and the American and International Bar Associations; formerly, Tax Law Specialist, IRS Corporation Tax Branch; author: “The Foreign Sales Corporation Issues and Answers Under the Temporary Regulations,” Tax Mgmt. Intl. J., March, 1985; “Analysis of the Foreign Sales Corporation — Temporary Regulations,” Tax Mgmt. Memo., February, 1986; “Foreign Sales Corporations — The Shape of Regs. to Come,” Tax Mgmt. Intl. J., January, 1987; and “Foreign Sales Transactions: A Prognosis for 1987,” Tax Mgmt. Memo., February, 1987. Member, IRS Commissioner's Advisory Group 1995–1996.
Foreign Sales Corporations (Portfolio 934) Howard M. Liebman, Esq.Howard M. Liebman, A.B. (summa cum laude), Colgate University (1974); A.M. (with distinction), Colgate University (1975); J.D. (cum laude) Harvard Law School (1977); Member, District of Columbia Bar and “B” List of the French-speaking Brussels Bar; Belgian Member, Tax Management International Forum; Contributing Editor, European Taxation; Editorial Advisory Board, Practical European Tax Strategies; Chairman, Legal & Taxation Committee, American Chamber of Commerce in Belgium.
Business Operations the European Union (Portfolio 999) Pernille Lindholm
Pernille Lindholm is a consultant with Deloitte in Copenhagen.
Michael LippmanMichael H. Lippman is a managing director with Alvarez & Marsal Taxand, LLC, providing planning, consulting, and controversy services to many of the country's largest corporations. Prior to joining A&M, Mr. Lippman was the National Partner in Charge of State and Local Tax Services for KPMG LLP. Mr. Lippman sits on a number of boards, including the State and Local Taxation Committee of the American Institute of Certified Public Accountants, the Georgetown Institute Advisory Board, the Advisory Board to the Vanderbilt School of Law Paul J. Hartman State and Local Forum, the New York University's State and Local Taxation Advisory Board. He received his B.S. in accounting from the University of North Carolina and an M.S. (Taxation) from Georgetown University, graduating both as valedictorian.
Income Taxes: State Treatment of Net Operating Losses (Portfolio 1200) Margo Lipscomb, Esq.
Margo J. Lipscomb, Esq. is a BNA Tax & Accounting Editor for Foreign Income Tax, the Financial Planning Journal, the International Journal and the Washington Tax Review.
Henry J. Lischer, Jr.Henry J. Lischer, Jr., University of Iowa (B.B.A., 1967; J.D., 1970); New York University (LL.M. in Taxation, 1974); Judge Advocate, U.S. Marine Corps, 1970–73; Associate, Lillick, McHose & Charles, Los Angeles, California, 1974–75; Professor of Law, University of Alabama, 1975–78; Professor of Law, Southern Methodist University, 1978–present; Counsel, Malouf Lynch Jackson & Swinson, Dallas, Texas, 1982–84, 1985–present; Professor-in-Residence, Office of Chief Counsel, Internal Revenue Service, Washington, D.C., 1984–85; Fellow, American College of Tax Counsel; Academic Fellow, American College of Trust and Estate Counsel.
Incomplete Lifetime Transfers: Retained Powers Under Sections 2036(a)(2) and 2038 (Portfolio 50)Incomplete Lifetime Transfers: Retained Beneficial Interests Under Sections 2036(a)(1) and 2037 (Portfolio 52)Gifts (Portfolio 845)Gifts to Minors (Portfolio 846) Josephine S. Lo, Esq.
Josephine Lo, J.D., cum laude, Georgetown University, 1988; M.Ed. and M.A., counseling psychology, Columbia University, 1981 and 1982; B.A., sociology, magna cum laude, Mississippi University for Women, 1979; tax partner, Pillsbury Winthrop Shaw Pittman LLP; member, DC Bar, Maryland Bar, ABA; speaker on low-income housing tax credit, historic rehabilitation tax credit, and new markets tax credit.
Christian Looks
Christian Looks is a member of KPMG's global transfer pricing services practice. Looks is a partner with KPMG AG in Frankfurt, Germany.
Simon LorneSimon M. Lorne, B.A., Occidental College (1967, cum laude; Phi Beta Kappa); J.D., University of Michigan Law School (1970, magna cum laude; Order of the Coif); partner, Munger, Tolles & Olson, LLP (1970-1993; 1999-2004); managing director, Salomon Brothers Inc., responsible for global internal audit (1996-1999); general counsel, Securities and Exchange Commission (1993-1996); has taught at the University of Pennsylvania, USC and NYU law schools; serves as co-director of the Directors' College, Stanford Law School; has lectured at Stanford University, University of Michigan, Cornell University and UCLA and frequently speaks on securities law and corporate governance matters; author, Acquisitions and Mergers: Negotiated and Contested Transactions (multi-volume treatise, West Securities Law Series), A Director's Handbook of Cases (CCH), and numerous articles in professional journals; currently Vice Chairman and Chief Legal Officer, Millennium Partners, L.P., a multi-strategy hedge fund.
Internal Controls: Sarbanes-Oxley Act �404 and Beyond (Portfolio 5402) Peter A. Lowy, Esq.Peter A. Lowy, J.D. (cum laude and member of law review), Tulane Law School; L.L.M. (taxation), New York University School of Law; member: New York and Texas bars; currently: Senior Tax Counsel, Shell Oil Company; formerly: Senior Tax Attorney, Exxon Mobil Corporation; attorney-advisor, the Honorable Maurice Foley, United States Tax Court; judicial clerk, the Honorable Nauman Scott, U.S. District Court; adjunct professor in Legal Research & Writing, University of Houston Law.
U.S. Federal Tax Research (Portfolio 100) Gregory P. Lubkin, Esq.Gregory P. Lubkin, University of Edinburgh (U.K.) (M.A. 1975); University of California, Berkeley (Ph.D. 1982); Harvard University (J.D. 1996); member, District of Columbia Bar and Section of Taxation of American and District of Columbia Bar Associations; contributor: Tax Management International Journal.
Source of Income Rules (Portfolio 905) Denise Lugo
Denise Lugo is the New York Staff Correspondent at BNA Tax and Accounting's Accounting Policy & Practice Report.
Mary Lundstedt, Esq.
Mary F. Lundstedt, Esq. is an Editor at BNA Tax & Accounting, and a contributing editor for the Weekly Report.
David Luntz
David Luntz, Esq. is president of International Corporate Consultants, Inc. in New York City, and a contributor to BNA Tax & Accounting's Real Estate Journal.
M
David Machemer
David Machemer is a graduate of the John Marshall Law School and a practicing attorney in Chicago, IL, and a contributor to BNA Tax & Accounting's Real Estate Journal.
Scott MacKayScott W. MacKay, B.S. (Engineering), United States Military Academy; J.D., Boston University School of Law. Mr. MacKay began working at Lockheed Martin in 1995, and was responsible for managing and conducting corporate litigation, including criminal and civil fraud matters, coordinating the Corporation's response to government investigations and requests for information, conducting internal investigations, and other compliance issues. From 1988 to 1995, he was a Senior Trial Attorney in the U.S. Department of Justice Criminal Division's Fraud Section where he investigated and prosecuted procurement fraud cases as well as cases involving violations of the Foreign Corrupt Practices Act, perjury before a grand jury, telemarketing fraud, public corruption, and fraud relating to classified contracts. Before joining the Fraud Section, Mr. MacKay served in the Army's Judge Advocate General's Corps in a variety of criminal justice assignments and as a legal advisor in the Office of the Secretary of the Army.
Responding to Department of Justice Investigations (Portfolio 5515) Elisabeth O. Madden
Elisabeth O. Madden is an attorney with Milbank, Tweed, Hadley & McCloy. LLP, in New York City.
Tammara Madison
Tammara Madison is Editor of BNA Tax and Accounting's IRS Practice Adviser and Weekly Report.
Ewing W. Madole, Esq.Ewing W. Madole, B.A., M.B.A. Mississippi State University (1973, 1975); J.D., Columbia University School of Law (1985); LL.M. in Taxation, New York University (1990); Member of the New York Bar; Certified Public Accountant, Tennessee (1977).
Controlled Foreign Corporations — Section 956 (Portfolio 929) J. Russell Madray
J. Russell Madray, CPA, Master of Professional Accountancy, Clemson University (1988); B.S. in Accounting, Clemson University (1986). President of The Madray Group Inc., which helps businesses, accounting firms, and other organizations understand and implement technical accounting and auditing issues; senior lecturer at Clemson University's School of Accountancy and Legal Studies; former member, AICPA Accounting and Review Services Committee; former member, Board of Directors, South Carolina Association of CPAs. Author of Attestation and Other Special Engagements (CCH), Compilations and Reviews (CCH), OCBOA Guide (CCH), and the AICPA's annual Compilation and Review Alert.
Stephen P. Magowan, Esq.Stephen P. Magowan, Honors Tutorial College at Ohio University (B.A. 1985, with Highest Honors), Washington University School of Law in St. Louis (1988, Order of the Coif). Faculty Member, 1998-2000, University of Vermont Income Tax School. Author, “Roth IRA's: Estate and Income Tax Planning Tool for the 21st Century,” Probate & Property, July/August 1998; “Doing Right by Doing Good: Giving IRA's to Charity,” Probate & Property 17, September/October 1997; “Overview of Significant Changes of Pension Laws in SBJPA 1996,” 23 Vermont Bar Journal 17, 1997. Contributing Author, The Lawyer's Guide to Retirement 3d ed., published by the American Bar Association. Member, American, Vermont and New York Bar Associations.
Probate and Administration of Decedents' Estates (Portfolio 804) Kirk F. Maldonado, Esq.Kirk F. Maldonado, B.A., University of Nebraska at Omaha (1975); J.D., Creighton University (1978); M.L.T., Georgetown University (1981); member, California Bar; Attorney, Employee Plans and Exempt Organizations Division, Office of Chief Counsel, Internal Revenue Service (1978-1981).
Securities Law Aspects of Employee Benefit Plans (Portfolio 362) Jacques Malherbe, Esq.Jacques Malherbe, JD, University of Louvain (1962); LL.M., Harvard University (1964); Professor, University of Louvain; Visiting Professor, Universities of Paris II, Paris XII, Dijon, Vienna, Hamburg.
Business Operations Belgium (Portfolio 953) J. Randolph MallekJ. Randolph Mallek, CPA, Ph.D. (Accounting), The University of Texas at Austin; MPA (Master in Professional Accounting), The University of Texas at Austin; MS (Information Systems), American University; MS (Administration), University of California at Irvine. Licensed as a CPA in the state of Texas, Dr. Mallek has taught undergraduate and graduate financial, managerial, and accounting information courses at the Leventhal School of Accounting at the University of Southern California and was an Associate Professor of Accounting at Al Akhawayn University in Morocco and an Assistant Professor of Accounting at American University in Washington, D.C. Dr. Mallek works as an Accounting Consultant in the Washington, D.C. office of Buchanan Ingersoll & Rooney, PC.
Revenue Recognition: Fundamental Principles (Portfolio 5100)Revenue Recognition: Product Sales and Service (Portfolio 5101) Mary Ann Mancini, Esq.
Mary Ann Mancini, Esq. is with Bryan Cave LLP in Washington, DC and is a frequent contributor to BNA Tax & Accounting's Financial Planning Journal.
Vivek MandeVivek Mande, Ph.D, is a Professor of Accounting and the Director for the Center for Corporate Reporting and Governance at California State University, Fullerton. Dr. Mande teaches and researches in the areas of corporate governance, financial accounting, and auditing. He was the Academic Accounting Fellow at the Securities and Exchange Commission's Office of Economic Analysis in Washington, D.C. from 2001–2002. Professor Mande holds a Ph.D. in Accounting from the Anderson Graduate School of Management, U.C.L.A. Dr. Mande is an Associate Member of Institute of Chartered Accountants. His research findings have been published in Contemporary Accounting Research, Auditing: A Journal of Practice and Theory, Journal of Accounting and Public Policy, International Journal of Accounting, ABACUS, Accounting and Business Research, and a number of other journals.
Accounting for Share-Based Compensation (Portfolio 5109) Petri ManninenPetri Manninen, LL.B., 1993 (University of Helsinki), Varatuomari, 1995 (“lawyer trained in the court”), LL.M. in European Community Law (University of Leiden), 1996.
Business Operations Finland (Portfolio 960) Peter J. Marathas, Jr. Esq.Peter J. Marathas, Jr., B.A. (1981), cum laude, M.A. (1986), summa cum laude, Bradley University; J.D., magna cum laude, University of Illinois, Harno Fellow (1994); Employment and Labor Section, American Bar Association; Boston Bar Association; Massachusetts Bar (1997), Illinois Bar (1994), Florida Bar (2005).
ERISA — Litigation, Procedure, Preemption and Other Title I Issues (Portfolio 374) Steven Marcy
Steven Marcy is the Staff Editor of BNA Tax and Accounting's Accounting Policy & Practice Report.
Patrick MarleyPatrick Marley, B.Comm., Queen's University; LL.B., University of Western Ontario; LL.M., New York University; Barrister and Solicitor of the Bars of Ontario and New York; Tax Partner, Osler, Hoskin & Harcourt LLP.
Business Operations Canada (Portfolio 955) Howard MarmorsteinHoward Marmorstein is an Associate Professor of Marketing at the University of Miami where he teaches Marketing Management and Consumer Behavior. Professor Marmorstein received both a B.S. in Economics and an M.B.A. from the Wharton School of the University of Pennsylvania. He received his Ph.D. from the University of Florida. He has served as an Investment Adviser for more than 10 years. Professor Marmorstein won the University of Miami Professor of the Year Award in 2003. His research on consumer decision making has won two national awards and has been published in numerous academic journals. Professor Marmorstein has also served as an expert witness and business consultant for both firms and municipalities in the areas of business valuation, eminent domain, trademark infringement, and deceptive advertising.
Accounting Principles and Financial Statements (Portfolio 5116) Richard Marshall, Esq.
Richard S. Marshall; LL.M. / J.D., 1984, 1981; The George Washington University, B.A., 1975; Tufts University, political science. Mr. Marshall is a Senior Attorney with Buchanan Ingersoll Rooney PC, and focuses his practice on corporate, partnership and general business tax planning matters at the federal and state levels. In addition, he advises clients on the formation and operation of tax-exempt organizations and represents clients in civil and criminal tax matters before the Internal Revenue Service. He is affiliated with the Taxation Division, District of Columbia Bar and the Fairfax Bar Association. Richard is a frequent contributor to and assists in editing various publications for BNA Tax & Accounting. He is the author of several chapters of the "Tax Practice Series" and is the co-coordinator of the "Washington Items" feature of the Tax Management Memorandum.
Mauricio Martínez, Esq.
Mauricio Martínez, Esq. is with Deloitte Touche Tohmatsu in Mexico City, Mexico and is a frequent contributor to BNA's International Journal.
Elena Marty-NelsonElena Marty-Nelson, B.A., University of Miami (1980); J.D., Georgetown University Law Center (1983); LL.M. (Tax), Georgetown University Law Center (1986); Institute Fellow, Harrison Institute for Public Law Georgetown University Law Center (1990-1991).
Testamentary Capacity and Validity of Wills (Portfolio 824) Nadia Masri, Esq.
Nadia Masri, Esq. is Compensation Planning Editor at BNA Tax & Accounting, and a contributing editor for the Weekly Report.
Nicholas Mastracchio, Jr.Nicholas J. Mastracchio, Jr., BBA in Accounting, Siena College (1964); Masters in Accounting, University at Albany (1977); Ph.D., Union College (dissertation: Valuation of Closely Held Businesses) (1993). Dr. Mastracchio practices in Marco Island, Florida and Adirondack, New York and limits his practice to valuations and related areas. He is a member of the American Institute of Certified Public Accountants and The New York State Society of CPAs; author of How Much Is It Worth? Valuing a Profession or Closely Held Business (AICPA 1995) and Mergers and Acquisitions of CPA Firms: A Guide to Practice Valuations (AICPA 1998); author of chapters on Mergers and Acquisitions in Management of an Accounting Practice (AICPA 2001); reviewer of several books on valuation; and frequent contributor to Journal of Accountancy, CPA Journal, The Practicing CPA, Family Law Review, Journal of Small Business Management, ABA Banking Journal, The Trusted Professional, Trial Lawyer and The Practical Accountant. Dr. Mastracchio is a member of the Auditing Standards Board and the National Association of State Boards of Accountancy. (NASBA)
Closely Held Business Valuation (Portfolio 5147) Steven R. Mather, Esq.Steven R. Mather, University of Iowa (B.B.A. with highest distinction 1978; J.D., with distinction 1982); Member, California and Iowa Bars; Certified Public Accountant, Iowa, 1979; Senior Attorney, District Counsel, Internal Revenue Service, Los Angeles 1983–87; Co–Director, Tax Court Pro Se Program (Los Angeles/Beverly Hills) 1988–Present; Lecturer, Federal Tax Procedure, Golden Gate University Masters in Taxation Program; Member, Section of Taxation of California, Los Angeles County and Beverly Hills Bar Associations; Contributor, The Tax Lawyer; Co–author: 638-2nd T.M., Federal Tax Collection Procedure.
Audit Procedures for Pass-Through Entities (Portfolio 624)Federal Tax Collection Procedure — Liens, Levies, Suits and Third Party Liability (Portfolio 637)Federal Tax Collection Procedure — Defensive Measures (Portfolio 638) Thomas J. Matragrano, CPAThomas J. Matragrano, J.D., Hofstra University School of Law; B.A., State University of New York at Stony Brook; member, New York State Bar and Tax Section, New York State Bar Association; formerly Attorney/Advisor, Office of Chief Counsel, Internal Revenue Service.
Redemptions (Portfolio 767) James E. MauleJames Edward Maule, B.S., University of Pennsylvania (1973); J.D., Villanova University (1976); LL.M. (Taxation), George Washington University (1979); lecturer, Villanova University Graduate Tax Program and Tax Forum CLE Programs; lecturer, Philadelphia Bar Association Tax Section; member, Advisory Board on U.S. Income, Tax Management Inc.; former attorney-advisor, United States Tax Court, Judge Herbert L. Chabot; former attorney-advisor, Chief Counsel to the Internal Revenue Service; former Editorial Advisory Board member and Columnist, Journal of Limited Liability Companies; former lecturer, ALI-ABA; former lecturer, Tax Management Inc. & Continuing Legal Education Satellite Network; former lecturer, Pennsylvania Bar Institute; former lecturer, Georgetown University Law Center Institute on State and Local Taxation; former lecturer, The Dickinson School of Law CLE Programs; member, American Bar Association, Section of Taxation, Committee on S Corporations (Consultant and former Chair, Subcommittee on Subchapter S and State Law; former Chair, Subcommittee on Comparison of Partnerships and S Corporations).
Gross Income: Overview and Conceptual Aspects (Portfolio 501)Gross Income: Tax Benefit, Claim of Right and Assignment of Income (Portfolio 502)Deductions: Overview and Conceptual Aspects (Portfolio 503)Deduction Limitations: General (Portfolio 504)Trade or Business Expenses and For-Profit Activity Deductions (Portfolio 505)Tax Credits: Concepts and Calculation (Portfolio 506)Income Tax Liability: Concepts and Calculation (Portfolio 507)State, Local, and Federal Taxes (Portfolio 525)Depreciation: MACRS and ACRS (Portfolio 531)Income Tax Basis: Overview and Conceptual Aspects (Portfolio 560)Tax Incentives for Economically Distressed Areas (Portfolio 597)State Taxation of S Corporations (Portfolio 1510) Todd F. Maynes, Esq.Todd F. Maynes, B.A., magna cum laude, Brigham Young University (1984); J.D., magna cum laude, Brigham Young University (1987); law clerk to Judge Kenneth Ripple, United States Court of Appeals for the Seventh Circuit (1987–1988); partner, Kirkland & Ellis LLP, Chicago, Illinois, since 1988; adjunct professor, Chicago-Kent College of Law, Graduate Tax Program, since 1993; chair, Planning Committee of the Chicago-Kent College of Law, Federal Tax Institute.
Start-Up Expenditures (Portfolio 534) Cheri MazzaDr. Cheri R. Mazza is an Associate Professor of Accounting at Fordham University where she teaches graduate and undergraduate financial accounting courses. Dr. Mazza received a Ph.D. in Accounting from the University of North Texas in 1994, an M.S. in Accounting from Illinois State University in 1983, and a B.S. in Business Education from Indiana University of Pennsylvania in 1979. She is a Certified Public Accountant and a Certified Management Accountant. Prior to joining Fordham, Dr. Mazza was a project manager at the Financial Accounting Standards Board (FASB). Dr. Mazza's research encompasses issues in contemporary financial reporting, standard setting, and quality of earnings. She has published numerous articles in academic and professional journals.
Segment Reporting (Portfolio 5119)Asset Retirement Obligations (Portfolio 5143) Todd Y. McArthur, Esq.Todd Y. McArthur, B.S., University of Virginia, McIntire School of Commerce (1985), Beta Alpha Psi; J.D., University of Virginia, School of Law (1990). Author, Selected Federal Income Tax Issues Arising in Technology Ventures and Business Transactions Involving Technology or Facilitated by the Internet — A Transactional Perspective; with Steven R. Lainoff, “The Final Functional Currency Regime for U.S. Taxpayers Operating in Hyperinflationary Environments: Mandatory DASTM”, 12 Tax Management Int'l J. 583 (1994). Member, Virginia State Bar, District of Columbia Bar, United States Tax Court, and American Bar Association.
Partnership Transactions — Section 751 Property (Portfolio 720) Paul B. McCawley, Esq.Paul B. McCawley, shareholder, Greenberg Traurig, P.A.; B.S.B.A., University of Florida (with High Honors); J.D., University of Florida College of Law (with Honors); LL.M. in Taxation, New York University School of Law; member, The Florida Bar (Real Property, Probate and Trust Law Section and Tax Section).
Estate Tax Payments and Liabilities (Portfolio 832) Ellen E. McCleskey
Ellen E. McCleskey returned to BNA in 2007 as a copy editor for Daily Tax Report after seven years at Deloitte Washington National Tax, where she worked primarily with Tax Policy group. From 1990-1997, she was a reporter for various BNA publications, including Health Care Policy and Medicare Report, World Food Regulation Review, and Product Safety and Liability Report. She was a copy editor on Tax Management’s Financial Products Report from 1997-2000. She holds a B.A. from Belhaven College, Jackson, Miss.
John C. McCoy, Esq.John C. McCoy, B.B.A., University of Notre Dame (1969); J. D., high honors, George Washington University (1976); Arent Fox, LLP since 1976, member since 1984; member, District of Columbia, Virginia, Maryland and American Bar Associations.
Loss Deductions (Portfolio 527)Bad Debts (Portfolio 538) Rebecca Pearl McCracken
Rebecca Pearl McCracken has been managing editor of Daily Tax Report since 1988. She joined BNA in 1977 and became chief tax reporter in 1980. She holds a B.S. in Journalism from Suffolk University, Boston, and an M.S. from the University of Maryland College of Journalism, College Park. She served for 10 years as BNA’s representative on the Executive Committee of Periodical Correspondents in Congress and was its chairwoman from 1985-1986.
David McDonald
David McDonald is a Director in PricewaterhouseCoopers' specialist financial services transfer pricing network in Greater China.
Joel M. McDonaldJoel M. McDonald, B.S., summa cum laude, University of Alabama (1984); J.D., University of Virginia (1987); Advisor to the Russian Government on Tax Reform (1994-1997).
Business Operations Russia (Portfolio 981) Kathleen McEligotKathleen McEligot, CPA; B.S., University of California, Berkeley. Ms. McEligot is a tax partner at Deloitte Tax LLP, with over 29 years of professional experience. She specializes in corporate taxation, with extensive experience in the financial services, distribution and retail industries. As a firm designated specialist in Accounting for Income Taxes (FAS 109), she consults on income tax accounting issues for all types of companies. Ms. McEligot is a frequent lecturer, speaking before groups such as the Tax Executives Institute (TEI). She is a member of the American Institute of Certified Public Accountants and the California Society of Certified Public Accountants; and a Finance Committee Member, Metropolitan Club.
Accounting for Income Taxes: Uncertain Tax Positions (FIN 48) (Portfolio 5002)Accounting for Income Taxes: Uncertain Tax Positions � Selected Topics (Portfolio 5003) Ruth McEwenRuth Ann McEwen, CPA; Ph.D., Industrial Management, with a concentration in Accounting, Georgia Institute of Technology; Masters, Industrial Management, Georgia Institute of Technology; and B.S., Alabama A&M University. Dean McEwen serves as the Associate Dean of Accreditation and Administration and Professor of Accounting at Suffolk University's Sawyer Business School. She has taught Financial Accounting at the Intermediate and Doctoral levels for more than 20 years. Author and co-author of numerous articles dealing with ethics and the usefulness of accounting information to the investment community, Dean McEwen has published in premier journals including The Accounting Review, Decision Sciences, Accounting Horizons, The CPA Journal, The International Journal of Accounting, and the Journal of Business Ethics. Dean McEwen has presented practical applications of her research to numerous academic and practitioner groups. She also has presented to the FASB and the GASB a series of papers focusing on financial reporting and the usefulness of GAAP accounting information. Dean McEwen has also composed and assessed questions for the Uniform CPA Examination. Serving as a consultant to the FASB, Dean McEwen has been deeply involved with its project to codify Generally Accepted Accounting Principles. A member of Beta Gamma Sigma, she has received such honors as the 2001 Dean's Recognition Award for Research and the 2002 Graduate Student Association's Professor of the Year. She is a certified Medical Technologist, ASCP, and is licensed as a Certified Public Accountant in Georgia.
Earnings Per Share (Portfolio 5137)Asset Retirement Obligations (Portfolio 5143) Diane M. McGowanDiane M. McGowan, Senior Manager, Executive Compensation Tax Services, Deloitte & Touche LLP; B.A., B.S. Summa Cum Laude, and MPrA, University of Utah.
Golden Parachutes (Portfolio 396) Richard P. McHugh, Esq.Richard P. McHugh, B.A., Georgetown University (1977); J.D., Georgetown University Law Center (1980); member, American Bar Association Section of Taxation (Employee Benefits Committee), District of Columbia Bar Section of Taxation (Employee Benefits Committee), State Bar of Ohio, Southern Employee Benefits Conference (President, 2001).
Qualified Plans — Treatment Mergers, Acquisitions and Other Corporate Transactions (Portfolio 364) Patrick McKenna, CPAPatrick McKenna, CPA, is Director, Corporate Tax, for Prudential Financial, in Newark, N.J. He is Prudential's primary advisor on federal, state, and local employment tax laws and regulations. Patrick, a 2003 American Payroll Association Meritorious Service Award recipient, is active on several APA task forces and also is a perennial presenter at the APA Congress.
Payroll Library Erin McManus, State Tax Law Editor
Erin McManus is a graduate of Colorado State University with a B.A. in Economics and Political Science and a graduate of Northwestern University School of Law. Prior to attending law school, Erin was a state legislative analyst with MultiState Associates in Alexandria, Virginia. She has practiced law in Colorado with a focus on real estate and business transactions. Erin joined BNA in 2009, and works primarily in the area of credits and incentives.
Gillian McPheeGillian McPhee is an associate in Gibson, Dunn & Crutcher's Washington, D.C. office. She currently practices in the firm's Corporations Department where she focuses her practice on securities regulatory issues and corporate governance matters. Ms. McPhee has co-authored a variety of articles and other publications on securities law and corporate governance issues, including “Liability of Officers and Directors; Statutory Limitations, Indemnification and D&O Insurance,” in Corporate Governance: Law and Practice, LexisNexis/Matthew Bender (2005); “The Business Roundtable's 2002 Principles of Corporate Governance,” The Corporate Governance Advisor, September/October 2002; “The Investment Company Act of 1940: Why the Time Has Come to Revive Section 3(b)(1),” in Villanova Journal of Law and Investment Management, Spring 2001. Prior to joining Gibson, Dunn & Crutcher in 1999, Ms. McPhee was an associate in the Washington, D.C. office of Fulbright & Jaworski LLP. Ms. McPhee received her J.D., with Honors, from the University of Texas in 1997. She received her Bachelor of Arts magna cum laude from Yale University in 1993.
Management's Discussion and Analysis (Portfolio 5107) Rita McWilliams
Rita McWilliams is the Managing Editor of BNA Tax and Accounting's Transfer Pricing Report.
Thomas Meyer
Thomas E. Meyer, CFA, is a managing director of Horst Frisch Inc., a Washington, D.C.-based economic consulting firm that specializes in transfer pricing issues.
Louis A. Mezzullo, Esq.Louis A. Mezzullo, University of Maryland (B.A. 1967, M.A. 1976), University of Richmond (J.D. 1976); Partner, Luce, Forward, Hamilton & Scripps LLP, 2006 to present; Partner, McGuireWoods LLP, Richmond, Virginia, 2003 to 2006; Member, Mezzullo & Guare, PLC, Richmond, Virginia, 2000 to 2003; Founding Member, Mezzullo & McCandlish, Richmond, Virginia, 1982 to 2000; Adjunct Professor, University of Miami School of Law, University of Richmond Law School.Fellow and Chair, American College of Tax Counsel; Fellow and former Regent, American College of Trust and Estate Counsel; Charter Fellow, American College of Employee Benefits Counsel; Past Chair, ABA Section of Real Property, Probate and Trust Law (2000-01); former Member of Council, and Current Chair of the Business Planning Subcommittee of the Estate and Gift Taxes Committee of the ABA Section of Taxation; and Academician and Vice President, International Academy of Trust and Estate Law.Author, An Estate Planner's Guide to Buy-Sell Agreements; An Estate Planner's Guide to Life Insurance; An Estate Planner's Guide to Qualified Retirement Plan Benefits; An Estate Planner's Guide to Family Business Entities; and Valuation Rules Under Chapter 14, all published by the American Bar Association, and Limited Liability Companies in Virginia, published by the Virginia Law Foundation; Co-author, Advising the Elderly Client, published by Clark, Boardman, Callaghan.
The Migrant Client: Tax, Community Property, and Other Considerations (Portfolio 803)Estate Planning for Owners of Closely Held Business Interests (Portfolio 809)Family Limited Partnerships and Limited Liability Companies (Portfolio 812)Estate and Gift Tax Issues for Employee Benefit Plans (Portfolio 814)Valuation of Corporate Stock (Portfolio 831)Transfers of Interests Family Entities Under Chapter 14: Sections 2701, 2703 and 2704 (Portfolio 835)Estate and Gift Tax Issues for Employee Benefit Plans (Portfolio 378)Family Limited Partnerships and Limited Liability Companies (Portfolio 722) Michael Midzio
Michael A. Midzio is a tax assistant with KPMG Meijburg & Co. in Amstelveen, Netherlands.
Forrest David Milder, Esq.Forrest David Milder, S.B., Massachusetts Institute of Technology (1973) (Phi Beta Kappa); S.M., Massachusetts Institute of Technology (1974); J.D., Harvard Law School (1977); LL.M. (Taxation), Boston University (1983); admitted to bar, Massachusetts; member, Tax Section, American Bar Association, Boston Bar Association (Chairman, Internet and Computer Assisted Tax Practice Committee, former Chairman, Section of Law Office Management and Professionalism); member, National Association of Bond Lawyers; Boston University School of Law, Instructor of Legal Research and Writing; Lecturer, Federal Tax Institute, Massachusetts Continuing Legal Education, Massachusetts Association of Public Accountants, Northwest Center for Professional Education; Contributor on tax matters to The Wall Street Journal, Boston Globe, Massachusetts Banker and Tradesman, The Matrimonial Strategist, Massachusetts Lawyer's Weekly, and Writer's Digest; author of “Disposition of Personal Residence” (The Best of MCLE, August 1991). Contributed Chapter “Federal Income Taxation of Asset Securitization Transactions” to Securitization: Asset–Backed and Mortgage–Backed Securities (Michie 1994).
Rehabilitation Tax Credit and Low-Income Housing Tax Credit (Portfolio 584) Joel E. Miller, Esq.Joel E. Miller, A.B., Columbia College (1954); J.D., Columbia University School of Law (1956); LL.M. in Taxation, New York University Graduate School of Law (1964); Law Secretary to Honorable Harold R. Medina, Judge, U.S. Court of Appeals for the Second Circuit, 1956–1957; associated with Paul, Weiss, Rifkind, Wharton & Garrison, New York, N.Y., 1957–1960; associated with and member of Demov, Morris, Levin & Shein, New York, N.Y., 1961–1969; member of adjunct and full-time faculty, St. John's University School of Law between 1976 and 1989; Chair, Subcommittee on Condominiums and Cooperatives, Committee on Real Estate Tax Problems, Section of Taxation, American Bar Association; Chair, Subcommittee on Liens, Cooperatives and Condominiums Committee, Real Property Law Section. New York State Bar Association, Tax Section; co-author, Modern Trust Forms and Checklists (Warren, Gorham & Lamont, Inc. 1980); author, Federal Taxation of Trusts (Prentice-Hall, Inc., 1968); contributor to Tax Law Review, Journal of Real Estate Taxation, Journal of Taxation and other legal publications on matters involving federal taxation and property law; editor, Real Estate Tax Ideas 1979–1983; member, several advisory boards; and lecturer at various tax institutes. Note: Portions of this portfolio are taken from articles written by Mr. Miller and originally published in the Journal of Real Estate Taxation (Warren, Gorham & Lamont, Inc.).
Cooperative and Condominium Apartments (Portfolio 596) Michael J. Miller, Esq.Michael J. Miller is a partner in the New York office of Roberts & Holland LLP. He counsels foreign-and-U.S. based multinationals regarding a wide range of tax issues pertaining to their cross-border activities. Michael co-authored 945 T.M., U.S. Taxation of International Shipping and Air Transport Activities, and has written numerous articles on international tax issues for the Tax Management International Journal, CCH Journal of Taxation of Global Transactions, and the Canadian Tax Journal. Michael is an active member of the U.S. Activities of Foreign Taxpayers and Tax Treaties Committee of the American Bar Association Tax Section. He received his B.A. cum laude from Columbia College in 1988 and his J.D. from New York University in 1991. He clerked on the U.S. Tax Court for the Honorable James S. Halpern from 1991-1993.
U.S. Income Tax Treaties — The Limitation on Benefits Article (Portfolio 936)U.S. Taxation of International Shipping and Air Transport Activities (Portfolio 945) Robert H. "Buff" Miller, Esq.Robert H. (“Buff”) Miller, Williams College (B.A. magna cum laude and Phi Beta Kappa, 1970); Stanford University Law School (J.D. 1974); Stanford University Business School (M.B.A. 1974); former Deputy Tax Legislative Counsel for Regulatory Affairs, U.S. Department of Treasury (1995-1999); member, California and New York Bars; partner, Cooley Godward Kronish LLP.
Statutory Stock Options (Portfolio 381) Peter Mills, Esq.
Peter D. Mills, Esq. is a US Income Editor at BNA Tax & Accounting, and a contributing editor for the Weekly Report.
Peter D. Mills, Federal Tax Law Editor
Peter has been with BNA Tax & Accounting since 2008, and is a member of the U.S. Income Group. In this position, Peter focuses mainly on issues relating to individual and family income taxation, including deductions, credits, non-corporate AMT, trade or business income, and real estate. Peter is admitted to the bar in multiple jurisdictions. He is a member of the Taxation Section of the American Bar Association, and is a member of the committee on Individual and Family Taxation within the Taxation Section. Peter received a B.S. from Boise State University, and a J.D. and an LL.M. (in Taxation) from the Thomas M. Cooley Law School.
Luis Fernando MirandaLuis Fernando Miranda, Universidad Central de Venezuela (Public Accounting, 1986); Columbia University (Professional Extension Program); Professor, Universidad Central de Venezuela; member, Tax Committee of Venamcham; former member, Committee of Coindustria.
Business Operations Venezuela (Portfolio 993) Jerrie V. Mirga Jerrie Varrone Mirga, College of William & Mary, B.A. (1979); George Washington University, MBA (1985) and post-MBA Certificate (2001); Vice President, Economic Consulting Services, LLC. Ms. Mirga advises clients on transfer pricing issues involving tangible and intangible property for planning, documentation and audit purposes.
Transfer Pricing: Economic, Managerial, and Accounting Principles (Portfolio 889) Rick Mitchell
Rick Mitchell is a special correspondent for BNA.
Mark MitschowMark C. Mitschow, Ph.D. (Accounting), University of Maryland at College Park. Associate Professor of Accounting, State University of New York (SUNY) at Geneseo, teaching primarily financial accounting courses. His research interests include business ethics, the financial services industry, and the accounting profession. Dr. Mitschow has authored 15 peer-reviewed articles (in journals including Research on Professional Responsibility and Ethics in Accounting, The CPA Journal, and the Journal of Business Ethics) and 24 conference presentations.
Accounts Receivable: Financial Accounting and Auditing (Portfolio 5110)Accounts Receivable: Management and Analysis (Portfolio 5111) Michael C. Moetell, Esq.Michael C. Moetell, B.S. (cum laude), Villanova University (1982); J.D. (cum laude), Harvard Law School (1985); member, International Fiscal Association, American Bar Association's Section of Taxation, D.C. Bar Association's Tax Section.
Indirect Foreign Tax Credits (Portfolio 902) Charles Moll, IIICharles Moll, III, A.B. degree from Cornell University in 1976, J.D. from George Washington University in 1979. He served as an Attorney Advisor to Chief Judge C. Moxley Featherston of the United States Tax Court from 1979 through 1981. Thereafter, he joined the Tax Department of Morrison & Foerster in San Francisco and became a partner of the firm on January 1, 1989. Mr. Moll's practice primarily involves the resolution of tax controversies through litigation and negotiation. He practices extensively in state and local tax matters before all levels of California's courts, taxing authorities, and a wide variety of county assessment appeals boards. His practice also covers federal tax matters, including the representation of clients in federal courts and at appellate hearings before the Internal Revenue Service. Mr. Moll has lectured and written on a variety of federal and state tax issues, including teaching in the Golden Gate University graduate tax program and speaking at the Southern California Annual Tax Institute.
Property Taxes: California's Property Tax Regime (Portfolio 1630)State Environmental Taxes (Portfolio 1690) Keith A. Mong, Esq.
Keith A. Mong, B.A., University of Maryland (1984); J.D., The Catholic University of America Columbus School of Law (1987); LL.M., Georgetown University Law Center (1990); Shareholder, Buchanan Ingersoll & Rooney PC, Washington, DC; member District of Columbia Bar; Maryland State Bar Association; American Bar Association (Chair, Subcommittee on Employee Benefits Legislation); Chair, Compensation Planning Journal, Board for Compensation Planning, Tax Management, Inc.; regular speaker at seminars and contributor to various journals, including but not limited to, author “A Road Map for Complying with the Final Regulations under Code §409A,” Part I (Tax Mgmt. Comp. Planning J. Aug 3, 2007) and Part II (Tax Mgmt. Comp. Planning J. Sep. 7, 2007), author, “Tax Treatment of Supplemental Retirement Plans, Host Country Response: United States” in Tax Mgmt Int’l. Forum No 4, Sep. 2006
Gianmarco MonsellatoGianmarco Monsellato; graduate of the HEC Group, International Management School France; recognized as “Lead Tax Adviser” and “Lead Transfer Pricing Advisor” in all Euromoney Legal Media Group Surveys. Co-founder of the Transfer Pricing worldwide Deloitte team, his service line has been quoted n°1 Transfer Pricing Team in France, by the International Tax Review; co-author of the first French book on transfer pricing: Les prix de Transfert; wrote the French chapter in Transfer Pricing – an International Guide; author of numerous articles on international tax and transfer pricing in French and international reviews; is a member of the global transfer pricing task force of the International Chamber of Commerce; member of the IFA; member of the French-US Chamber of Commerce; has substantial experience in strategic tax planning, tax controversies, Advance Transfer Pricing Agreements and Competent Authority Procedures; is currently the Managing Partner (CEO) of Taj, an international tax and law firm in France, member of Deloitte Touche Tohmatsu and advises leading European, Japanese, Korean and US multinational companies in transfer pricing and international tax strategies.
U.S. Income Tax Treaties — Competent Authority Functions and Procedures of Selected Countries (Portfolio 941) Carmela T. Montesano, Esq.
Carmela T. Montesano, Georgetown University Law Center, 1983, J.D.; Fairfield University, 1980, B.A.; Of Counsel at Meyer, Suozzi, English & Klein, P.C. in Garden City, New York; member of New York State Bar Association, Suffolk County Bar Association and Columbian Lawyers Association; author of several publications on Federal estate, gift and income tax issues, including contributions to the American Bar Association regarding “qualified personal residence trusts” and lifetime gifts to minors.
Kevin J. MoodyKevin J. Moody is with the Harrisburg office of Wolf, Block, Schorr and Solis–Cohen LLP where he concentrates in state taxation. Mr. Moody spent seven years as a member of the Pennsylvania Department of Revenue's Board of Appeals and 10 years in the Law Bureau of the Pennsylvania Public Utility Commission. Mr. Moody received his law degree from the Dickinson School of Law in 1981 and received his B.A. in political science from the University of Pittsburgh in 1977.
Pennsylvania Corporate Taxes (Portfolio 2300) Cynthia A. Moore, Esq.Cynthia A. Moore, B.A., Alma College (1978); M.S.L., Western Michigan University (1979); J.D., University of Texas at Austin (1986); member of the Michigan Bar; American Bar Association, Taxation and Business Law Sections; and Oakland County Bar Association.
Employee Fringe Benefits (Portfolio 394) Ralph J. Moore, Jr. Esq.Ralph J. Moore, Jr., Yale College (B.A. 1954), School of Law, University of California at Berkeley (LL.B. 1959); Law Clerk to Chief Justice of the United States (1959–1960); Senior Counsel, Morgan, Lewis & Bockius LLP, Washington, D.C.; admitted to practice in District of Columbia, Maryland, and California; member of American Bar Association, Real Property, Probate & Trust Law Section, District of Columbia Bar, Estates, Trusts & Probate Law Section, Maryland State Bar Association, Estate & Trust Law Section, State Bar of California, Estate Planning, Trust & Probate Law Section; Fellow, American College of Trusts and Estates Counsel and American Academy of Elder Law Attorneys; author of Estate Planning for Families of Persons with Disabilities in Maryland, D.C., and Virginia (1989) and chapters on estate planning in Woodbine House series on disabilities.
Planning for Disability (Portfolio 816) Anne E. Moran, Esq.Anne E. Moran, Partner, Steptoe & Johnson, LLP; B.A., Wellesley College; J.D., Harvard Law School; formerly Tax Counsel, United States Senate Committee on Finance; former member of the ERISA Advisory Council for the United States Department of Labor; member, American Bar Association, Section of Taxation; member, American Bar Association, Joint Committee on Employee Benefits (former chair); member, District of Columbia Bar, Tax Section, Committee on Employee Benefits (former chair) and Steering Committee (former member); member, American College of Employee Benefits Counsel (former board member).
Reasonable Compensation (Portfolio 390) Robert C. Morris
Robert C. Morris; Brigham Young University, J.D., cum laude, 2004; Georgetown University Law Center, LL.M., Taxation, with distinction, 2006; Brigham Young University (B.S., Accounting, 2002; Master of Accountancy, 2004). Mr. Morris practices in the following areas of law: Taxation; Federal Tax Controversies; Tax Audits; Tax Litigation. Admitted: 2004, Texas; 2006, U.S. District Court, Southern District of Texas, U.S. Tax Court and U.S. Court of Federal ClaimsMorris is a member of the Houston, American and Federal Bar Associations and Houston Young Lawyers Association. Currently practices with the law firm of Fulbright & Jaworski L.L.P.
Helen J. Morrison, Esq.Helen H. Morrison, Trinity College (B.A.1979), IIT/Chicago—Kent College of Law (J.D. cum laude 1985); member, Illinois Bar. Past Chairman, Legislative and Regulatory Advisory Committee, The ESOP Association.
ESOPs (Portfolio 354) Philip D. Morrison, Esq.
Philip D. Morrison; Princeton University (high honors graduate); Harvard Law School (honors graduate); served as the U.S. Treasury's International Tax Counsel (1989 – 1992), the U.S. government's chief legal advisor on international tax matters (including international tax legislation and regulations), chief negotiator of tax treaties and director of the Office of International Tax Counsel; represented the U.S. at the OECD and at other multilateral tax for a; served as Counsel to the U.S. Senate Finance Committee (1981 – 1983); member of the Committee on U.S. Activities of Foreigners and Tax Treaties of the American Bar Association’s Tax Section, the tax committee of the National Foreign Trade Council, the International Fiscal Association, and two Washington-based international tax study groups; has regularly been selected as a leading tax advisor and a leading transfer pricing advisor for the International Tax Review/Legal Media Group’s expert guides; spoken and published widely on various international tax subjects and is a regular contributor to the Tax Management International Journal’s “Leading Practitioner Commentary”; is a Principal at Deloitte Tax LLP, in Washington, D.C.
Paul MortensonPaul D. Mortenson, B.S., Merrimack College (1989); J.D., Suffolk University Law School (1992); Certified Public Accountant (Illinois, 1993); Member: Chicago Bar Association, State and Local Tax Committee, American Bar Association.
Sales and Use Taxes: Services (Portfolio 1310) Molly Moses
Molly Moses is a Staff Writer/Editor at BNA Tax and Accountings Transfer Pricing Report.
Clifford E. Muller, Esq.Clifford E. Muller, B.S., B.A., Bucknell University (magna cum laude 1978), Delta Mu Delta; J.D., George Washington University (with high honors 1981), Order of the Coif; Professional Lecturer in Law, George Washington University Law School, 1987–1990. Member, District of Columbia Bar Association; member, American Bar Association, Section of Taxation; Chairman, Subcommittee on International Financial Transactions; member, Committee on Foreign Activities of U.S. Taxpayers, Foreign Currency Subcommittee. Lecturer: World Trade Institute, New York, “Taxation of Foreign Currency” and “Foreign Currency Exposure Management.”
Tax Aspects of Foreign Currency (Portfolio 921) Johann Muller
Johann Müller is an international tax manager at the A.P. Møller Mærsk Group in Denmark. Johann is a member of the tax department of the A.P. Moller Maersk group, where he is heading its tax risk management team. He has been working at A.P. Moller Maersk A/S since September 2006. Prior to that, he ran his own practice after having worked in the international tax practice for various Dutch law firms in Holland, the UK and the US. Johann is the author of numerous articles on international taxation and EU law on direct taxation. He is a member of the International Fiscal Association, the Tax Executives Institute (chairperson for the European Direct Tax Committee) and the European American Tax Institute.
Michael Mulroney, Esq.Michael Mulroney, B.S.C., University of Iowa (1954); J.D., Harvard Law School (1959); Order of Coif; Professor of Law, Director, Graduate Tax Program, Villanova School of Law (1988-present); Adjunct Professor, Georgetown University Graduate Tax Program (1986-present); Partner, Lee, Toomey & Kent, Washington, D.C. (1969-1988) (Associate 1965-1969); Appellate Attorney, Tax Division, U.S. Department of Justice, Washington, D.C. (1961-1965); Attorney Advisor, U.S. Tax Court (1959-1961). Teacher: Federal taxation; professional responsibility; faculty advisor, Villanova Law School Tax Clinic. Admitted to practice: District of Columbia; Iowa; U.S. Supreme Court; Iowa Supreme Court; U.S. Circuit Courts of Appeal for the Second, Third, Fourth, Fifth, Sixth, Seventh, Eighth, Ninth and Tenth Circuits; U.S. Tax Court; U.S. District Court for the District of Columbia; District of Columbia Court of Appeals. Professional organizations: District of Columbia Bar; Iowa State Bar Association; Federal Bar Association; American Bar Association, Section of Taxation (Tax Lawyer Committee, former Managing Editor, The Tax Lawyer, Chair Annual Reports Subcommittee; Court Procedure Committee; Standards of Practice Committee; Teaching Taxation Committee; Committee on Government Submissions), Section of Legal Education and Admissions to the Bar; District of Columbia Bar (Tax Section); Federal Bar Association (Tax Section); Iowa Bar Association (Tax Section); Fellow, American College Tax Counsel; J. Edgar Murdock American Inn of Court (Founding Master); American Association of Law Schools (Tax Section); International Fiscal Association (U.S.A. Director); Washington Tax Lawyers' Study Group; Philadelphia Tax Conference (Director, Executive Committee); Reporter, Invitational Conference on Professionalism in Tax Practice (1993); Commentator, Statute of the Bar of the Republic of Belarus (CEELI); author of various books and tax articles. Competition license holder, Sports Car Club of America.
Tax Aspects of Foreign Currency (Portfolio 921) Jonathan Brett MuroffMr. Muroff is a manager at PricewaterhouseCoopers in Boston. Mr. Muroff is part of the firm's state tax consulting practice with an emphasis in mergers and acquisitions and corporate tax planning. He has authored and co-authored a number of articles on various state tax issues and has lectured on the subject at firm training seminars and at the Tax Executives Institute. Mr. Muroff received a B.A. from Clark University (1992), a J.D. from Case Western Reserve University (1995), and a LL.M. from the Georgetown University Law Center (1996). He is a member of the bar in Massachusetts and New York.
Massachusetts Corporate Taxes (Portfolio 2140) Sharon MurphySharon A. Murphy, B.A., Mercyhurst College (1985); M.S.T., Robert Morris College (1992); Member: American Institute of Certified Public Accountants, Pennsylvania Institute of Certified Public Accountants.
Sales and Use Taxes: Services (Portfolio 1310) Fred F. Murray
Fred F. Murray; B.A., Rice University; J.D. University of Texas at Austin. Fred Murray is an attorney (District of Columbia, Maryland, New York, and Texas (Board Certified in Tax Law, Texas Board of Legal Specialization), and various federal courts) and C.P.A (Maryland and Texas). His experience includes public law and accounting practice, government service as Deputy Assistant Attorney General in the Tax Division at the Department of Justice and as Special Counsel at the Internal Revenue Service, as well as service as Vice President for Tax Policy at the National Foreign Trade Council and General Counsel and Director of Tax Affairs at the Tax Executives Institute.Mr. Murray serves as an adjunct member of the faculty at Georgetown University Law Center where he teaches courses on international taxation and accounting for income taxes, Sarbanes Oxley Act of 2002, and other issues for corporate tax advisors. He also lectures at the New York University School of Law. Previously, Fred Murray was also an adjunct professor at the University of Texas School of Law, Rice University Jesse H. Jones Graduate School of Management, and the University of Houston Law Center. Grant Thornton LLP, Washington, D.C. Murry is currently Executive Director of Tax Practice Policy and Quality Grant Thornton LLP, U.S. member of Grant Thornton International.
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Walter NagelMr. Nagel has an LL.M. in taxation from the Georgetown University Law Center and a J.D., an M.B.A. and a B.A. from Rutgers University. He is a member of the bars of the District of Columbia and the U.S. Supreme Court. Mr. Nagel is the author of Leading U.S. Supreme Court State Tax Cases, a book discussing U.S. Supreme decisions involving state taxation. He also writes the U.S. Supreme Court Update column that appears bi–monthly in the Journal of Multistate Taxation. He is a frequent contributor to professional journals and is a member of the Advisory Board of the Georgetown University Law Center State and Local Tax Institute and the Tax Management Multistate Tax Portfolio Series. He is a frequent speaker at professional association meetings. From 1990–1994 he was a lecturer on sales taxes at New York University. He has also chaired various subcommittees of the American Bar Association, Tax Section since 1987. Mr. Nagel is Vice President–Taxes for MCI Communications Corp. where he has oversight responsibility for consumption taxes, property taxes, and tax systems, including nationwide responsibility for trial and appellate advocacy in these tax areas. He has also held management positions with AT&T Corp. and TWA. The opinions expressed herein are solely the authors' and not those of the entities with which they are or have been associated.
Sales and Use Taxes: General Principles (Portfolio 1300) Prija Nair
Prija D. Nair is a State Tax Law Editor at BNA Tax and Accounting.
Andrew W. Needham, Esq.Andrew W. Needham, J.D., Georgetown University Law Center; LL.M. (Taxation), Georgetown University Law Center; M.B.A., The Wharton School; B.A., University of Arizona; Member, Executive Committee, Tax Section of New York State Bar Association, American Bar Association, United States Tax Court.
Private Equity Funds (Portfolio 735)Hedge Funds (Portfolio 736) Joseph W. Neff, Esq.Joseph W. Neff, B.A., Brigham Young University; J.D., Southwestern University; Vice–Chair, American Bar Association (state and local section for environmental taxes); Associate Editor, ABA State Tax Journal; frequent author and lecturer on state and local tax matters. Previous Adjunct Professor, Master in Taxation, Golden Gate University, state and local taxation; member, California Bar Association, Idaho State Bar Association.
Income Taxes: Computation of State Taxable Income (Alabama Through Michigan) (Portfolio 1090)Income Taxes: Computation of State Taxable Income (Minnesota Through Wyoming) (Portfolio 1100) Annette NellenAnnette Nellen (B.S., CSU, Northridge; MBA, Pepperdine University; J.D. Loyola Law School) is a Professor of Accounting & Taxation in the College of Business at San José State University, and a Fellow with the New America Foundation.
Amortization of Intangibles (Portfolio 533) Richard Nenno, Esq.
Richard W. Nenno, Esq. is with Wilmington Trust Company in Wilmington, Delaware and is a contributor to BNA Tax & Accounting's Tax Management Memorandum.
Andrew C. Newman, CPAAndrew C. Newman, B.B.A., University of Wisconsin, 1980; tax partner, International Tax Service Line, Deloitte Tax LLP, Chicago, Illinois, 2002-present; Arthur Andersen, 1980-2002; member, AICPA, Illinois CPA Society, International Fiscal Association, Chicago Counsel on Foreign Relations; author, numerous articles on international tax matters; frequent speaker at seminars on international tax issues.
The Allocation and Apportionment of Deductions (Portfolio 906) Glenn NewmanGlenn Newman, until his appointment as President of the New York City Tax Commission, was a partner in Roberts & Holland LLP, where he handled tax planning and controversy matters involving state and local taxes. Prior to joining Roberts & Holland, he was Deputy Commissioner for Audit & Enforcement at the New York City Department of Finance, and before that chief of the Tax and Bankruptcy Division in the Office of the Corporation Counsel of the City of New York. He was a member of the Commissioner's Advisory Panel for both the New York State and City tax departments and was chair of the State and Local Tax Committee of the Association of the Bar of the City of New York (1999-2001) and wrote a regular column on New York tax appeals for the New York Law Journal.
New York Sales and Use Taxes (Portfolio 2220) Caroline H. Ngo, Esq.Caroline H. Ngo, B.S., University of Virginia (2002); J.D., Cornell Law School (2005); Associate, McDermott Will & Emery LLP (2005-present); member, New York and District of Columbia Bars.
Accumulated Earnings Tax (Portfolio 796) Thanh Vinh NguyenThanh Vinh Nguyen holds his Bachelor of Arts Degree in English from the University of Ho Chi Minh City and his LL.B. from the College of Law of Ho Chi Minh City. Mr. Nguyen worked for two international accounting firms for eight years before joining the Ho Chi Minh City office of Baker & McKenzie in 2004. His principal practice areas are tax advice and planning, finance and banking, and general corporate matters. He is fluent in English as well as his native Vietnamese.
Business Operations Vietnam (Portfolio 994) Peter M. W. Nias, Esq.Peter Nias is a partner in the law firm of McDermott Will & Emery UK LLP, based in its London office. He is Head of the London office Tax Department, where his practice focuses on direct and indirect tax advice on a broad range of corporate and commercial business activities, including acquisitions and disposals, and corporate structures for UK and international business investments. Peter also advises on general corporate commercial tax matters for companies and advises individuals on wealth preservation techniques.
Business Operations the United Kingdom (Portfolio 989) Linda NicholsLinda Nichols, Ph.D., Louisiana State University (Accounting). Dr. Nichols worked for an international accounting firm in Houston as part of the oil and gas industry audit division and later joined Columbia Gas Development, an exploration and production company. She is heavily involved with the oil industry through consulting and training for oil companies worldwide. She has led industry training in Angola, Nigeria, Cameroon, Ecuador, Malaysia, Indonesia, China, Thailand, Hungary, the United Kingdom, Australia, and the United States, and has spoken at several national conferences including the North American Petroleum Accounting Conference and the AICPA Oil and Gas Industry Conference. Dr. Nichols is currently Professor and Director of Accounting Programs at Texas Tech University. She also is Associate Editor of Oil, Gas and Energy Quarterly and on the Editorial Board of Petroleum Accounting and Financial Management Journal, and she has published numerous articles dealing with accounting issues in the oil industry. Dr. Nichols also received the 2007 Texas Society of CPAs' Outstanding Accounting Educator Award, was named Outstanding Educator of the Year by the American Woman's Society of CPAs, served as President of the South Plains Chapter of the Texas Society of Certified Public Accountants (TSCPA), and serves as a trustee of the Educational Foundation of the TSCPA. Dr. Nichols is a licensed Certified Public Accountant in Texas.
Oil and Gas Accounting: Upstream Operations (Portfolio 5206) Peter Nichols
Peter Nichols is an associate principal with the London office of the Ballentine Barbera Group, a CRA International company.
Alina NiculitaAlina V. Niculita, CFA, MBA, B.S. in Economics, Academy of Economic Studies, Bucharest, Romania; MBA in Finance, University of Pittsburgh and from the Czech Management Center, Czech Republic. Ms. Niculita is the president and chief operating officer of Shannon Pratt Valuations. She is a chartered financial analyst and a candidate for the American Society of Appraisers designation in business valuation. She is also a member of the Chartered Financial Analyst Institute, the American Society of Appraisers, and the Licensing Executives Society; co-author of Valuing a Business, 5th edition; Business Valuation Body of Knowledge Workbook, 2nd Edition and the Cost of Capital Workbook. She is the former managing editor of Shannon Pratt's Business Valuation Update©, BVLibrary™ and the Economic Outlook Update.™
Closely Held Business Valuation (Portfolio 5147) Lionel B. NobreLionel Bonner Nobre, Director of BDO Seidman LLP's Brazilian Consulting Services in Miami; Pontifical University of São Paulo, Brazil (LLB, 1992 and LLM, 2000); Member, Brazilian Bar, Brazilian Institute of Certified Financial Planners (“Instituto Brasiliro de Certificação de Planejadores Financeiros – IBCPF”), Brazilian Association of Tax Consultants (“Associação Brasileira de Consultores Tributários – ABCT”), Academy of Brazilian Tax Law (Academia Brasileira de Direito Tributário – ABDT”), and the Brazilian Tax Planning Institute (“Instituto Brasileiro de Planejamento Fiscal – IBPT”).
Transfer Pricing: Foreign Rules and Practice Outside of Europe, Part 2 (Portfolio 898) Sharon Nowakowski, Esq.Sharon Nowakowski, J.D., Loyola University Chicago; BA, University of Illinois. Nowakowski practices law with Bryan Cave LLP, and was previously with ABN AMRO Bank. The opinions of authors expressed herein do not necessarily reflect those of Bryan Cave LLP or ABN AMRO Bank N.V.
Mortgage Banking Activities and Mortgage-Backed Securities (Portfolio 5208) Hugo NurnbergHugo Nurnberg, Ph.D., Columbia University; M.B.A., Baruch College; B.S., Queens College. Licensed as a Certified Public Accountant (New York), Dr. Nurnberg frequently serves as an expert witness and manages continuing education programs for practicing accountants and nonfinancial executives. Dr. Nurnberg has authored numerous articles in leading journals, including Accounting Forum, Accounting Horizons, The Accounting Review, Journal of Accountancy, Journal of Accounting Research, Journal of Financial Statement Analysis, Journal of Business Finance and Accounting, The CPA Journal, and Issues in Accounting Education. A Professor of Accountancy at Baruch College of the City University of New York, Dr. Nurnberg has been a Visiting Professor at the University of Pennsylvania, Columbia University, the University of Chicago, Rutgers University, and St. John's University, and a Professor of Accounting at Michigan State University.
The Cash Flow Statement (Portfolio 5121)
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Christopher Ocasal, Esq.Christopher (Chris) Ocasal is an international tax partner with Sutherland, Asbill & Brennan. Mr. Ocasal has extensive experience in advising clients with regard to their international tax issues and has substantial expertise in international insurance tax issues. Mr. Ocasal has worked with major U.S. multinationals with significant international operations and major foreign multinationals with significant U.S. operations. He advises on structuring joint ventures, domestic and international reorganizations, mergers and acquisitions, financial products, foreign currency transactions, anti-deferral regimes, withholding tax issues, foreign tax credit planning, and U.S. tax treaties. Prior to joining Sutherland, Mr. Ocasal was a principal in the PricewaterhouseCoopers LLP Washington National Tax Services office for nearly a decade. Additionally, prior to joining PricewaterhouseCoopers, Mr. Ocasal was a member of the Washington, D.C. office of Baker & McKenzie. Chris Ocasal received a J.D. from George Washington University Law School and an LL.M. from Georgetown University. He is a member of the New York and Virginia bar. Mr. Ocasal is also the co-author of a new BNA tax management portfolio, to be published, on Financial Instruments in which he reviews the taxation of notional principal contracts.
State Tax Appeal Systems (Portfolio 1700)U.S. Income Taxation of International Insurance Activities(Portfolio 931) Margaret Peg O'Connor, Esq.Margaret O’Connor, A.B. Bryn Mawr College; J.D. University of Maryland; M.L.T. from Georgetown University; International Tax Services Principal, Ernst & Young LLP, Washington, DC; member District of Columbia Bar, Maryland Bar, ABA; speaker on international tax issues; author of numerous articles relating to international tax.
Reporting Requirements Under the Code for International Transactions (Portfolio 947) Thomas A. O'Donnell, Esq.Thomas A. O'Donnell, Esq., B.A., Swarthmore College (1969); Ph.D., Rutgers University (1979); J.D., University of Cincinnati College of Law (1983); member, American Bar Association, District of Columbia Bar Association.
PFICs (Portfolio 923) Michael A. Olesnicky, Esq.Michael Olesnicky holds a BA and LLB from Adelaide University in Australia. He also holds an LLM from Columbia University in New York. He practiced from 1979–82 with Baker & McKenzie's office in Sydney. In 1988, he rejoined Baker & McKenzie's office in Hong Kong, and became a partner in 1989 in the International Tax Group. His chief specialty is Hong Kong and regional tax advisory work as well as estate duty planning. He is the Chairman of the Joint Liaison Committee on Taxation, which is a quasi-governmental committee that interfaces between tax practitioners and the Inland Revenue Department. He is a past chairman of the tax committee of the Australian Chamber of Commerce. He was a member of the Inland Revenue Board of Review (the lowest-level tax court in Hong Kong) between 1985 and 1994. He was Chief Editor of the Hong Kong Law Journal for five years. He writes and speaks frequently on Hong Kong tax matters.
Business Operations Hong Kong (Portfolio 964) Florence Olsen
Florence Olsen is a BNA staff correspondent for the Weekly Report.
Eric Oman, CPA
Eric Oman, C.P.A., is with Ernst & Young LLP's International Tax Services division in Washington, D.C. and is a frequent contributor to BNA's International Journal.
Paul W. Oosterhuis, Esq.Paul W. Oosterhuis, B.A., Brown University (1969); J.D., Harvard University (1973); member, Tax Management U.S. Income Advisory Board; member, International Fiscal Association; member, Special Committee on International Tax Policy, U.S. Chamber of Commerce; member, American Bar Association, Section on Taxation, Committee on Foreign Activities of U.S. Taxpayers; Adjunct Professor, Georgetown University Law Center (1977-1983); Legislation Attorney (1973-1977) and Legislation Counsel (1977-1978), Joint Committee on Taxation, U.S. Congress; member, District of Columbia Bar Association.
Research and Development Expenditures (Portfolio 556) Bruce OreckBruce J. Oreck is a senior partner with the law firm Oreck, Bradley, Crighton, Adams & Chase in New Orleans, Louisiana, and Boulder, Colorado. He received his B.A. degree from John Hopkins University, his J.D. degree from Louisiana State University School of Law, and his LL.M. in taxation from New York University. Mr. Oreck is a member of the taxation sections of the Louisiana, Colorado, and American Bar Associations and is an affiliate member of the Institute of Professionals in Taxation (IPT). He is a frequent speaker for many national tax organizations including COST, the American Petroleum Institute, and IPT. In addition, Mr. Oreck has authored and co–authored numerous articles on state taxation.
Managing State Tax Audits (Portfolio 1730) Robert Orlowsky, Content Development Specialist
Robert Orlowsky is a content development specialist with BNA Product Research and Planning. Bob joined BNA in 2008 after more than a decade as a Judicial Law Clerk with the United States District Court for the Northern District of California. Before working for the court, Bob was in private practice, specializing in securities litigation. Bob received a B.A. in Economics from Northwestern University and a J.D. from the University of California, Davis.
Ricardo Gonzales OrtaRicardo Gonzalez Orta; graduate of the Universidad Iberoamericano; has significant experience in transfer pricing matters and coordinates the Deloitte Mexico and Latin America region Transfer Pricing practices; spent eight years in a number of top executive posts with the Ministry of Finance (Secretaría de Hacienda y Crédito Público -SHCP-) and the Tax Administration Service (Servicio de Administración Tributaria -SAT-), most recently as Director General of Tax Policy and, as Director General of International Fiscal Affairs, in these positions he was in charge of Mexico's tax and customs policy and the negotiation of double taxation treaties; is a frequent speaker in different domestic and international forums; writes periodically on Mexican tax and transfer pricing issues in the Tax Management International Journal; is currently a partner at Galaz, Yamazaki, Ruiz Urquiza SC, Deloitte Touche Tohmatsu´s Mexico affiliate, where he advises multinational companies on tax-related matters, including structuring new businesses, acquisitions, reorganizations, joint ventures, double taxation issues, and transfer pricing.
U.S. Income Tax Treaties — Competent Authority Functions and Procedures of Selected Countries (Portfolio 941) Lee Oster
Lee Oster, Tax Effective Supply Chain Management leader at Ernst & Young LLP.
Jeffrey Owens
Jeffrey Owens, a public finance expert, completed his doctoral work at Cambridge University in the United Kingdom in 1973. In addition to his economic degrees, he is trained as an accountant. He is currently an international civil servant at the Organization of Economic Co-operation and Development in Paris, where he has focused his activities on the tax implications of the globalization of national economies, the broader policy issues that arise in the areas of cross-border direct and portfolio investment and tax administration. He has made numerous contributions to professional journals, has published a number of books ("The Growth of the Euro-Dollar market", “Local Government Finance: an international perspective”: “A Comparison of Tax Systems in North Africa and Europe") and has been the author of many OECD publications on taxation. Dr. Owens' position as Director of the Centre for Tax Policy and Administration at the OECD, his frequent participation in international conferences and business seminars and his high level contacts with representatives from governments and the business community have provided him with a unique international perspective on economic and tax policy issues.
Austin Ozawa, Esq.
Austin Ozawa, Esq. is an Associate in the Benefits Group in the New York office of Latham & Watkins.
Omer Ozusta, Legal Editor
Omer Y. Ozusta, Esq., is a Legal Editor at BNA Tax & Accounting. As legal editor for the Accounting Group, his responsibilities include editing BNA’s Accounting Policy and Practice Portfolios Series, as well as the Accounting Policy and Practice Report. Prior to joining BNA, Mr. Ozusta was in private practice, handling corporate, litigation, and immigration matters. He received a B.A. from the College of William and Mary and J.D. from the Catholic University of America.
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Kari Pahlman
Kari Pahlman is a partner with KPMG's global transfer pricing services practice in Hong Kong.
Ganesh PanditGanesh M. Pandit, CPA, CMA, DBA, Louisiana Tech University; MBA, University of Louisiana at Monroe. Mr. Pandit has a Post Graduate Diploma in Systems Management and a Bachelor of Commerce from the University of Bombay. Ganesh Pandit has previous experience in both public accounting at a chartered accountants firm and in industry. With more than 15 years of experience in teaching financial and managerial accounting at both undergraduate and graduate levels, Pandit currently is a faculty member at Adelphi University in Long Island, NY. He has authored and co-authored several articles on accounting and related topics that have appeared in both academic and practitioner journals. These articles include: “Auditor Compensation Pattern of S & P 500 Corporations Before and After the Passage of Sarbanes-Oxley Act,” in Journal of Applied Business Research, Summer 2007; “Are the Audit Committee Reports Disclosing Enough after the Sarbanes-Oxley Act? A study of NYSE Companies,” in Managerial Auditing Journal, Vol. 21, No. 1,( 2006), [selected as a Highly Commended Paper at the Emerald Literati Network Awards for Excellence 2007]; and “Audit Committee Reports Before and After the Sarbanes-Oxley Act: A Study of Companies Listed on the NYSE,” in The CPA Journal, October 2005 [solicited for a proposed book on Audit Committees by the ICFAI University, an academic institution in India]. Ganesh Pandit is a non-practicing C.P.A. from Louisiana.
Accounting by Partnerships (Portfolio 5209) Jeffrey H. Paravano, Esq.Jeffrey H. Paravano, B.S.B.A., cum laude, John Carroll University; J.D., magna cum laude, Georgetown University Law Center; LL.M. in Taxation, with distinction, Georgetown University Law Center; Firmwide Chair of Baker & Hostetler LLP's Tax, Personal Planning and Employee Benefits Group; formerly, Senior Advisor to the Assistant Secretary, Tax Policy, Department of Treasury; adjunct professor of law (LL.M. program), Case Western Reserve University School of Law and Georgetown University Law Center; member, American Bar Association, Section of Business Law and Section of Taxation; soon-to-be Chair, ABA Tax Section's Affiliated and Related Corporations Committee; former member, Editorial Advisory Boards of Corporate Business Taxation Monthly and The Tax Adviser; Chair, Cleveland International Tax Forum; Editor in Chief, The Tax Lawyer; President, Tax Club; frequent author and speaker on tax topics. Admitted to practice in New York, Connecticut, Ohio, Colorado, Maryland, and Washington, D.C.
Tax Shelters (Portfolio 798) Michael F. Patton, Esq.Michael F. Patton; University of Maryland (B.A. and J.D. with honors, Order of the Coif), Georgetown University Law Center (LL.M., Taxation); was editor and a major contributor to the Treasury/IRS Transfer Pricing White Paper; was a member of the Treasury/IRS study group to revise the competent authority function; worked extensively on the OECD Multilateral Treaty on Mutual Administrative Assistance in Tax Matters and the U.S.-Bermuda Tax Convention; was the lead U.S. Treasury negotiator in many negotiations with foreign governemnts for tax information exchange agreements under the Caribbean Basin Initiative; named one of the Best of the Best U S transfer pricing advisors as well as one of the leading Asia Pacific tax advisors by Euro Money and the International Tax Review; has been named as a “Highly Recommended” tax advisor by the International Tax Review; member, Editorial Advisory Board of Tax Management, Inc; contributor to the Tax Management International Tax Journal, the Transfer Pricing Reporter, and other publications; is a Principal with Ernst & Young, a member of the International Tax Services Group in the National Tax Department.
Transfer Pricing: Alternative Practical Strategies (Portfolio 890) Jack PaulJack W. Paul, B.A. (Economics), Cornell University, MBA, Ph.D., Lehigh University. Dr. Paul is a licensed CPA in the State of Florida. He is a professor of accounting at Lehigh University and has taught financial and intermediate accounting, auditing, advanced auditing, information systems, CPA review, and managerial and cost accounting. He is former director of the MS in Accounting program at Lehigh University and teaches the capstone course in that program. He has obtained several grants for conducting accounting research and has published in a number of academic and practitioner journals.
Related Party Transactions (Portfolio 5148) Laura H. Peebles, CPA/PFSLaura H. Peebles, Director, Deloitte & Touche. B.S., Accounting, University of New Orleans (summa cum laude) (1987); Certified Public Accountant, District of Columbia and Louisiana (Elijah Watts Sells Award 1988); Personal Financial Specialist. Member, AICPA and State Society of Louisiana CPAs. Editorial Board, Planned Giving Design Center. Frequent writer and speaker on estate planning and charitable planning topics.
Estate Tax Credits and Computations (Portfolio 844)Estate, Gift, and Generation-Skipping Tax Returns and Audits (Portfolio 822) Gordon O. Pehrson, Jr. Esq.Gordon Pehrson, a partner in the Washington office of Hopkins & Sutter, is a nationally recognized expert on the taxation of insurance companies and their products. Mr. Pehrson is a graduate of the College of William & Mary (A.B. 1964) and the University of Michigan School of Law (J.D. cum laude 1967), where he was elected to the Order of the Coif. From 1977 through 1981, Gordon was an adjunct professor of law in the graduate tax program at Georgetown University. In 1990, he was elected as a member of the American Law Institute.
Annuities, Life Insurance, and Long-Term Care Insurance Products (Portfolio 546) Josephine Y. K. Peng Josephine Y. K. Peng, Member of Taiwan CPA Association and Taipei Certified Public Accountant Association (since 1985); CPA, New Jersey, USA (since 1982); Senior CPA and Senior Counselor, Lee and Li, Attorneys-at-Law, Taipei (2000–present); Managing Partner, Intellects & Co., CPAs, Taipei (1989–2000); Columbia University, USA (Accounting Doctoral Program, 1981); Central State University of Oklahoma, USA (MBA, 1980); National Chung Hsing University, Taipei (B.B.A., 1977). Named by International Tax Review in 2006 as the most sought after tax adviser in Taiwan; and by The Tax Directors Handbook 2009 as one of the three best tax advisers in Taiwan; leads the Tax Practice Group of Lee and Li, Attorneys-at-Law, which was voted by International Tax Review in 2006 and 2007 as Taiwan Tax Firm of the Year; an active member on the tax committees of the American Chamber of Commerce in Taipei and the European Chamber of Commerce in Taipei; and a regular contributor of articles on various tax issues.
Business Operations in the Republic of China (Taiwan) (Portfolio 958) Jeffrey N. PennellJeffrey N. Pennell; B.S., Northwestern University (1971); J.D., Northwestern University (1975); Order of the Coif; Executive Editor, Northwestern University Law Review, 1974-75; Attorney, The Northern Trust Company, Chicago, Illinois, 1975-78; Assistant Professor of Law, University of Oklahoma, 1978-81; Visiting Assistant Professor of Law, Southern Methodist University, 1980; Associate Professor of Law, University of Oklahoma, 1981-84; Visiting Adjunct Professor of Law, University of Miami, 1981-93, 1999-present; Professor of Law, University of Oklahoma, 1984-86; Visiting Professor of Law, University of Miami, 1985-86; Director, Graduate Tax Program, 1986-94
Estate Tax Marital Deduction (Portfolio 843)Transfer Tax Payment and Apportionment (Portfolio 834) Isabella Owen Perelman
Isabella Owen Perelman has been a Daily Tax Report copy editor since 2008. She has done freelance work that includes editing books, reports, and conference transcripts for the Organization of American States, the Center for Strategic and International Studies, and other organizations in the Washington, D.C., area. She also has 17 years of experience as a managing editor of several scholarly journals at the Helen Dwight Reid Educational Foundation in Washington, D.C. She has a B.A. in the Great Books program from St. John’s College, Annapolis, Md.
Dennis L. Perez, Esq.Dennis L. Perez, A.B., San Diego State University (1978); J.D., University of California at Los Angeles (1982). Trial Attorney, District Counsel, Internal Revenue Service (1982–1986). Member: American Bar Association, State Bar of California. Principal – Hochman, Salkin and DeRoy, P.C., Beverly Hills, California.
Tax Crimes (Portfolio 636) Mario Petriccione
Mario Petriccione is a Director of International Corporate Tax at KPMG LLP in London. BA (Economics, Cambridge University), ACA, ATII Mario was brought up in Italy and went to Cambridge University as an overseas student. He graduated in 1979 with a BA (Economics, Cambridge University), ACA, ATII. Since then he has been based in London. He specialises in advising large companies on cross-border acquisitions and reorganisations. His clients include some of the larger UK and foreign multi-nationals, with a special focus on emerging markets Mario is the author of numerous articles on tax in China, India and Africa, which have appeared in a wide range of tax publications. Mario is a visiting lecturer and examiner on the International Tax Law LLM course at Leiden University, the Netherlands. He also teaches at the Brazilian Tax Law Institute in São Paulo, and at Said Business School (Oxford University).
Theodore D. Peyser, Esq.Theodore D. Peyser, B.A., Princeton University (1950); LL.B., Yale Law School (1955); member, District of Columbia, Tax Court, Court of Federal Claims, Federal Circuit, and U.S. Supreme Court Bars; member, Court Procedure Committee, Tax Section, ABA; Tax Division, U.S. Department of Justice, trial attorney (1955-1973), chief, Claims Court Section (1974-1984), Special Litigation Counsel (1985-1987); author, 631-2nd T.M., Refund Litigation and 628-2nd T.M. Transferee Liability; co-author, 630-3rd T.M. Tax Court Litigation; contributor, Tax Practice Series.
Limitations Periods, Interest on Underpayments and Overpayments, and Mitigation (Portfolio 627)Transferee Liability (Portfolio 628)Refund Litigation (Portfolio 631)Tax Court Litigation (Portfolio 630) Lisa Pfenninger, Federal Tax Law Editor
Lisa M. Pfenninger began her BNA Tax & Accounting career in 1998 and is a member of the U.S. Income Group. Lisa specializes in real estate taxation and is the lead editor for the "Tax Management Real Estate Journal. Before joining BNA, she was a practicing tax attorney in Washington, DC and served as a Judicial Clerk to Judge Schwelb on the D.C. Court of Appeals. Lisa holds an LL.M. (in Taxation) from the Georgetown University Law Center, a J.D. from the Florida State University College of Law, and a B.S. in Mathematics Education from the Florida State University.
Barnet Phillips, IV Esq.Barnet Phillips, IV, Partner, Skadden, Arps, Slate, Meagher & Flom L.L.P., New York, New York; B.A., Yale University 1970; J.D., Fordham University 1973; LL.M., New York University 1977.
Structuring Corporate Acquisitions — Tax Aspects (Portfolio 770) Astrid Pieron
Astrid Pieron is a Partner in the Brussels office of Mayer Brown. She has more than 25 years of tax experience, which includes 20-plus years of focus on international taxation. Her practice covers the fiscal aspects of financial functions within multinational groups, tax optimization of mergers and acquisitions, structuring of financial products and investment funds, and general assistance to private equity deals. Astrid has had a primary geographic emphasis on Brussels and Luxembourg throughout her career, and together with Mayer Brown’s Paris office (which won the 2006 Private Equity Award) she is advising on most of the significant private equity transactions that directly or indirectly are connected to the Benelux countries. In addition to her transactional work, Astrid has substantial background in tax controversy matters, including assistance with tax litigation and negotiation of rulings with the tax authorities in Belgium and Luxembourg. Her experience in transfer pricing controversy includes examination, appeals and advance pricing agreements. She also counsels on the transactional aspects of transfer pricing, such as structuring European transfer pricing policy for US manufacturing groups operating in Europe. Astrid’s related work involves advising on the conversion to commissionaire structures as well as on the fiscal optimization of financial vehicles within multinational enterprises (such as captive insurance companies, treasury centers, and investment funds). Before joining and subsequently becoming a partner in Mayer Brown’s Brussels office in 2007, Astrid practiced in Brussels and Luxembourg with two of the world’s leading tax and accounting firms: Deloitte (2002 to 2006) and Arthur Andersen (1981 to 2002). Reflecting her multinational practice, she is fluent in French, Dutch, and English.
John T. Piper, Esq.When this portfolio was written, Mr. Piper was a partner in the Seattle, Washington, law firm of Bogle & Gates where his practice focused on tax litigation. He has argued tax cases before the United States Supreme Court, the Washington Supreme Court, the Eighth and Ninth Circuit Courts of Appeal, the United States Court of Federal Claims, and the United States Tax Court. Mr. Piper has been active on bar committees providing liaison with the Internal Revenue Service and the Washington Department of Revenue. He is a Fellow of the American College of Tax Counsel and a member of the Advisory Councils of the NYU State and Local Tax Institute and the National Institute of State and Local Taxation. Mr. Piper is a former member of the Advisory Committee of the Department of Justice, Tax Division, and is Past Chair of the ABA Tax Section, State, & Local Taxes Committee. He is Vice Chair, ABA Tax Section Court Procedure Committee; ABA Tax Section Liaison with the Multistate Tax Commission; and Chair, State Bar Liaison with the Washington Department of Revenue (includes handling joint tax programs with the Washington Department of Revenue). Before joining Bogle & Gates, Mr. Piper was tax counsel for Weyerhauser and tax trial attorney with the Department of Justice. He received his LL.M. in Taxation from New York University in 1960.
Gross Receipts Taxes: General Principles (Portfolio 1610) Charles T. Plambeck, Esq.Charles T. Plambeck, A.B. University of North Carolina (1983); J.D. University of North Carolina School of Law (1986); Office of the Associate Chief Counsel (International), Internal Revenue Service (1988-1990); Special Counsel of the Chief Counsel, Internal Revenue Service (1990-1992); Of Counsel and Partner, Caplin & Drysdale (1992-1997); Managing Director and Tax Counsel, Bankers Trust Company and Deutsche Bank (1997-2001).
U.S. Income Taxation of Foreign Corporations (Portfolio 908) Robert D Plattner, Esq.Robert D. Plattner is the Deputy Commissioner of the Office of Tax Policy Analysis for the New York State Department of Finance and Revenue. Previously he was Counsel with the Albany law firm of McNamee, Lochner, Titus & Williams, P.C. He received his B.A. degree, Phi Beta Kappa, from Cornell University and his J.D. from Stanford Law School. Prior to entering private practice, Mr. Plattner served as Counsel to the New York State Assembly Program Development Group, Counsel and subsequently Director of the New York State Legislative Tax Study Commission, and Deputy Commissioner for Policy and Research in the New York State Department of Economic Development. In addition to private practice, he teaches state and local taxation as an adjunct professor at Albany Law School.
New York Personal Income Tax (Portfolio 2210) Irving H. PlotkinIrving H. Plotkin, Wharton School, University of Pennsylvania, B.S.; Massachusetts Institute of Technology, Ph.D. in mathematical economics. Dr. Plotkin is Managing Director of the Boston Tax practice of PricewaterhouseCoopers; for many years previous, he was Vice-President for Forensic Economics at Arthur D. Little, Inc. Dr. Plotkin has designed and conducted research studies on various topics including the effects of government regulation, self-regulation, industry efficiency and risk taking. Dr. Plotkin lectures frequently on economic and regulatory issues, and based on his research work, has presented expert testimony in the Tax Claims, U.S. District, and State Courts on behalf of taxpayers and the IRS in a number of high-profile tax disputes (including Du Pont, UPS, DHL, ACM, Bausch and Lomb, The Limited, Dow, and the captive cases) and has testified before U.S. congressional committees and federal and state commissions.
Transfer Pricing: Economic, Managerial, and Accounting Principles (Portfolio 889) Dirk PohlDr. Dirk Pohl, University of Tax Administration, Northrhine-Westfalia (1987), University of Bonn (First State Law Examination 1993, Second State Law Examination 1997); Doctor of Jurisprudence (1997); member, German Bar for lawyers (Rechtsanwälte) and for tax consultants (Steuerberater); member, International Fiscal Association.
Business Operations Germany (Portfolio 962) Neil PomerantzMr. Pomerantz received his B.A., Magna Cum Laude, in 1989 from Princeton University. In 1994, he received his J.D. degree, Cum Laude, from Harvard Law School. Mr. Pomerantz is a partner with the Denver office of the firm of Silverstein & Pomerantz LLP. He has significant experience in litigating state and local tax cases and in advising clients on tax planning matters. His practice includes franchise (income), sales and property tax issues.
Sales and Use Taxes: Communications Services and Electronic Commerce (Portfolio 1350) David W. Powell, Esq.David W. Powell, B.B.A., cum laude, Southern Methodist University (1979); J.D., University of Texas School of Law (1982); member: Tax section of the American Bar Association, District of Columbia Bar, New York State Bar, State Bar of Texas, Louisiana State Bar; Certified Public Accountant, Louisiana (1983).
Church and Governmental Plans (Portfolio 372) Catherine PreeCatherine Pree, J.D. (cum laude) in 1985 from the University of Puget Sound, LL.M. in Taxation from New York University, 1987. Ms. Pree's practice primarily focused on Washington State excise tax matters. Ms. Pree was an associate with Bogle & Gates. She has served as an Administrative Law Judge for the Washington Department of Revenue and as an Attorney–Advisor to the Honorable Judge Jacobs of the United States Tax Court. Ms. Pree has also served as Vice–Chair, Newsletter Subcommittee, ABA Section of Taxation, Committee of State and Local Taxes, and is a member of the Washington State Bar Association, State and Local Tax Committee.
Gross Receipts Taxes: General Principles (Portfolio 1610) Todd Prewett
Todd Prewett is with KPMG LLP's Washington National Tax office.
John R. Price, Esq.John R. Price, B.A., University of Florida (1958); LL.B., New York University School of Law (1961); Member of the Bars of California (inactive) and Washington; Of counsel, Perkins Coie LLP, Seattle, Washington (1976-2004); McCutchen, Doyle, Brown & Enersen, San Francisco, California (1961-69); Reporter for ACTEC Commentaries on Model Rules of Professional Conduct (1993, 1995 editions); Associate Professor (1969-72), Professor (1972-1996), Dean (1982-89), University of Washington School of Law; Visiting Professor, University of Michigan School of Law (1982), University of Florida College of Law (1989); Adjunct Professor, University of Miami Graduate Program in Estate Planning (1994, 2003, 2004); Christensen Visiting Fellow, St. Catherine's College, Oxford, England (1995); Author, Contemporary Estate Planning (Little, Brown 1983), Price on Contemporary Estate Planning (Little, Brown 1992; 2d ed., Aspen Publishing 2000); Fellow and former Regent, American College of Trust and Estate Counsel; Member, American Law Institute; Life Fellow, American Bar Foundation; Emeritus Member, Advisory Committee for Philip E. Heckerling Institute on Estate Planning.
Conflicts, Confidentiality, and Other Ethical Considerations Estate Planning (Portfolio 801) G. Garner Prillaman, Jr. Esq.G. Garner Prillaman, Jr., B.S., Virginia Polytechnic Institute and State University (1975); M.B.A., Virginia Polytechnic Institute and State University (1976); J.D., Wake Forest University (1981); LL.M. in Taxation, New York University (1985). Member, District of Columbia Bar Association; member, American Bar Association, Section of Taxation; member, Committee on Foreign Activities of U.S. Taxpayers, Controlled Foreign Corporations Subcommittee; Certified Public Accountant, North Carolina; Lecturer: World Trade Institute, New York, “Foreign Currency Exposure Management.”
Tax Aspects of Foreign Currency (Portfolio 921) Carlos Probus, Esq.
Carlos R. Probus, Esq. is with Ernst & Young LLP's International Tax Services division in Washington, D.C. and is a frequent contributor to BNA's International Journal.
Timothy J. Pronley, Esq.Timothy J. Pronley, B.B.A., University of Wisconsin – Madison, 1990; J.D., University of Minnesota, 1993; Tax Senior Manager, Deloitte Tax LLP, Minneapolis, Minnesota; member Wisconsin Bar, ABA, WICPA; speaker on international tax issues; author, articles on international taxation, including contributions to Practicing Law Institute and American Bar Association publications.
Foreign Corporation Earnings and Profits (Portfolio 932) Harold Pskowski, Esq.
BNA Tax and Accounting, Managing Editor for Estates, Gifts and Trusts, Tax-Exempt Organizations, and U.S. International TaxationHarold W. Pskowski has worked in the tax and estate planning fields for more than 25 years at BNA, a law firm, and an international accounting firm. He has detailed knowledge of the federal estate, gift and generation-skipping tax system, the federal and state regulation of tax-exempt organizations, and the how the United States taxes the international transactions of individuals and business entities subject to its jurisdiction.Publications Estates, Gifts and Trusts Portfolios Foreign Income Portfolios Transfer Pricing Portfolios Estates, Gifts and Trusts Journal International Journal Tax Practice SeriesDegrees, Honors, and Other Distinctions B.A., English Literature, Boston University, Boston, MA J.D., Northeastern University, Boston, MA LL.M. (Taxation), Boston University, Boston, MA Acquisitions Editor, ABA Section of Real Property, Trust & Estate Law
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James Cantillon Ross
James Cantillon Ross has been a tax attorney for 24 years, and belongs to the Bars of California, New York and Quebec. He has a master's degree from New York University School of Law (LL.M Taxation), law degrees from McGill University (common law and civil law) and from Université de Paris II - Assas, a junior degree in French Literature from Université de Paris III - Censier, and Math credits from Concordia University. He has been quoted by the United States Supreme Court and by the Supreme Court of Canada. James worked in large law firms for 15 years, and has had a private practice since 1998. He has applied twice to reduce the sentence of ex-Enron CEO, Mr. Jeffrey Skilling. He is a competitive surfer, foreign exchange day-trader, alternative band promoter, runway model-selection commentator, and feline rescue specialist. Mr. Ross has contributed to BNA publications, particularly Tax Planning International Review, since 1987. He is a citizen of each country of which he is commentator, in the Tax Treaties Analysis.
Amnon RafaelDr. Amnon Rafael, member of the Israeli and New York Bars (Advocate); LL.M. graduate of New York University (Taxation); J.S.D. graduate of New York University (Doctoral thesis on Tax Aspects of American Investments in Israel); member of the International Fiscal Association.
Business Operations Israel (Portfolio 967) Jeanne Rauch, Esq.
Jeanne M. Rauch, Esq., is a State Tax Law Editor at BNA Tax and Accounting.
Linda J. Ravdin, Esq.Linda J. Ravdin, B.A., Ohio State University (with honors 1970); J.D., George Washington University (with honors 1974); shareholder, Pasternak & Fidis, Bethesda, Maryland; admitted to practice, Virginia, District of Columbia, and Maryland; member of family law sections, American Bar Association, District of Columbia Bar, Virginia State Bar, and Maryland State Bar Association; facilitator, District of Columbia Superior Court Family Court Alternative Dispute Resolution Program; family law mentor, District of Columbia Bar's Law Firm Pro Bono Project; fellow, American Academy of Matrimonial Lawyers; co-author, Domestic Relations Manual for the District of Columbia (2002); frequent author and lecturer on domestic relations topics.
Marital Agreements (Portfolio 849) Wayne E. Reames, Esq.Wayne E. Reames, B.A., Luther College; J.D., University of Michigan; LL.M. (Taxation), New York University; Certified Public Accountant; associate of law firm of Belin Lamson McCormick Zumbach Flynn, A Professional Corporation.
Section 2032A — Special Use Valuation (Portfolio 833) Thomas Z. Reicher, Esq.Thomas Z. Reicher, Amherst College (B.A. summa cum laude and Phi Beta Kappa, 1970); University of California at Berkeley (M.A. 1973); Stanford University Law School (J.D. 1976); member, Connecticut Bar; Director, New England Employee Benefits Council; partner, Day, Berry & Howard.
Statutory Stock Options (Portfolio 381)Reductions Force (Portfolio 398) Richard Reichler, Esq.Mr. Reichler was formerly an Attorney Advisor, Office of the Chief Counsel Internal Revenue Service in Washington, D.C. and Vice President, Tax Planning and Services and Deputy General Counsel, of the Long Island Lighting Company. He also acted as the National Director of Executive Compensation Planning while a Senior Tax Partner at Ernst & Young, P.C.'s New York office. He is currently with the law firm of Meltzer, Lippe, Goldstein & Breitstone, LLP. Mr. Reichler is a 1955 graduate of Columbia College and a 1957 graduate of Columbia University Law School. He is a member of the New York State Bar Association (Tax Section), the International Fiscal Association, and the BNA Tax Management Advisory Board. Mr. Reichler is the author of “Leveraged Buyout Financing in Business Combinations and Restructuring,” and “The Limited Partnership as an Investment Vehicle.”
State Taxation of Compensation and Benefits (Portfolio 366)State Taxation of Compensation and Benefits (Portfolio 1750) Taylor S. Reid, Esq.Taylor S. Reid, Esq., B.A., University of California at Berkeley (1986); Graduate Diploma in International Studies, University of Vienna, Austria (1990); J.D., Northwestern University School of Law (1993, cum laude); Partner, Baker & McKenzie LLP; co-author, Internet Law for the Business Lawyer (ABA: 2001); co-author, United States Taxation of Income Derived from International Electronic Commerce Transactions, Tax Management Memorandum (December 4, 2000); member, State Bar of California, Illinois State Bar Association, American Bar Association Section on Taxation.
Federal Taxation of Software and E-Commerce (Portfolio 555) Diane L. Renfroe, Esq.Diane L. Renfroe, B.A., Wellesley College, 1968; J.D., Boston College Law School, 1977; admitted to Bar, Massachusetts, District of Columbia; Adjunct Professor, LLM International Tax Program, Georgetown University Law Center, 2004–present; tax principal, Washington International Tax Group, Deloitte Tax LLP, 2002–present; tax partner, International Tax Specialty Team, Arthur Andersen, Washington, D.C., 1988-2002; manager, Arthur Andersen, 1983-1988; formerly Assistant Branch Chief/Attorney-Advisor, Legislation and Regulations Division, Office of Chief Counsel, Internal Revenue Service, 1977-1982; member, Commissioner's Advisory Group, 1990-1992; author, numerous articles on international tax issues and developments; frequent speaker at seminars on international tax issues.
The Allocation and Apportionment of Deductions (Portfolio 906) Charles P. Rettig, Esq.Charles P. Rettig, B.A., University of California at Los Angeles (1978); J.D., Pepperdine University (1981); LL.M., New York University (1982). Member: American Bar Association, State Bar of California, State Bar of Arizona. Principal – Hochman, Salkin and DeRoy, P.C., Beverly Hills, California.
Tax Crimes (Portfolio 636) Donald B. Reynolds, Jr. Esq. Donald B. Reynolds, Jr., shareholder, Buchanan Ingersoll & Rooney PC; J.D., magna cum laude, 1979, Georgetown University Law Center; senior case and note editor, Law and Policy in International Business; B.A., magna cum laude, 1976, Hamilton College. Mr. Reynolds focuses his practice on financings, acquisitions and business planning for a variety of businesses, including both closely and widely held entities. His clients include mortgage companies, real estate brokerage firms, insurance companies and real estate developers. Reynolds specializes in tax and business and international tax. He is admitted to District of Columbia. Mr. Reynolds has represented the largest privately-held real estate brokerage firm in the country in virtually all of its significant acquisitions and financings. In addition to the brokerage business, the client's subsidiaries operate mortgage, title insurance and casualty insurance businesses. Along with his transactional work, Don also specializes in tax planning for partnerships, limited liability companies and S corporations and is a frequent contributor to tax publications and tax conferences.
Tax Shelters (Portfolio 798) Zabihollah RezaeeZabihollah (Zabi) Rezaee, CPA, CFE, CMA, CIA, and CGFM, is Thompson-Hill Chair of Excellence and Professor of Accountancy at The University of Memphis. Mr. Rezaee received a B.S. (Accounting) from The Iranian Institute of Advanced Accounting; an M.B.A. from Taleton State University in Texas; and a Ph.D. from The University of Mississippi. He is a Certified Public Accountant (Texas); Certified Fraud Examiner (CFE); Certified Management Accountant (CMA); Certified Internal Auditor (CIA); Certified Government Financial Manager (CGFM); and a former Member, Standing Advisory Group, Public Company Accounting Oversight Board. Professor Rezaee has published over 150 articles in a variety of accounting and business journals and has authored three books: Financial Institutions, Valuations, Mergers and Acquisitions (John Wiley & Sons 2001); Financial Statement Fraud: Prevention and Detection (John Wiley & Sons 2002); and U. S. Master Auditing Guide (3rd ed. CCH 2004), and co-authored, with Lynn Turner and Cynthia Richson, the forthcoming book, Corporate Governance Effectiveness Post-Sarbanes-Oxley Act: Regulations, Requirements, and Integrated Processes (John Wiley & Sons 2007).
Audit Committee Oversight Effectiveness Post Sarbanes-Oxley Act (Portfolio 5401) Nathan Richards
Nathan Richards is a director with KPMG's global transfer pricing services practice in Hong Kong.
Candace A. Ridgway, Esq.Candace A. Ridgway, B.A. (cum laude), University of Connecticut; M.B.A., Arizona State University; J.D. (magna cum laude), Cornell Law School; LL.M. (Taxation, with distinction), Georgetown University Law Center; member, District of Columbia Bar; member, New York State Bar; member, American Bar Association, Tax Section, Corporate Tax Committee.
Corporate Bankruptcy (Portfolio 790)Corporate Separations (Portfolio 776)Corporate Acquisitions — D Reorganizations (Portfolio 772) Kristine Riisberg
Kristine Riisberg is a senior manager in the New York office of Deloitte Tax LLP.
Diane M. RingDiane M. Ring, A.B. Harvard College (1986); J.D. Harvard Law School (1990); Caplin & Drysdale (1991-1994); Assistant Professor of Law, Harvard Law School (1994-2004); Associate Professor of Law, University of Florida (2004-2005); U.S. National Reporter to IFA (2003-2004).
U.S. Income Taxation of Foreign Corporations (Portfolio 908) Celia Roady, Esq.Celia Roady, undergraduate degree from Duke University in 1973, law degree from Duke University in 1976 and LL.M. from
Georgetown University in 1979; partner in the Tax Practice of Morgan, Lewis & Bockius, LLP, resident in the Washington, D.C., office; published extensively in various journals on exempt organizations; chairs the annual conference on “Representing and Managing Tax-Exempt Organizations,” sponsored by the Georgetown University Law Center; frequent speaker for the American Bar Association (ABA), American Law Institute, American Society of Association Executives, and other nonprofit conferences and symposia; past chair of the Exempt Organizations Committee of the ABA's Taxation Section; served on the Council of the Section; former member of the Legal Section Council of the American Society of Association Executives and a Fellow with the American College of Tax Counsel; has served as chair of the Exempt Organizations Committee of the District of Columbia Bar Association Tax Section, chair of the D.C. Bar's Council on Sections, and as a member of the Steering Committee of the D.C. Bar Tax Section.
Intermediate Sanctions (Portfolio 884) Thomas RobinsonThomas R. (“Tom”) Robinson is Head, Educational Content in the Education Division of the CFA Institute. He leads and develops the teams responsible for producing and delivering educational content to candidates, members, and others encompassing CFA Program Content, Professional Development Content, Private Wealth, Publications, University Relations, and Conferences. Previously, Tom was an Associate Professor of Accounting and Director of the Master of Professional Accounting program at the University of Miami. He also was Managing Director of TR Robinson & Associates, LLC, a state registered Investment Advisory firm. He primarily taught financial statement analysis, personal financial planning, and valuation. He has a B.A. in Economics from the University of Pennsylvania, and a Masters and Ph.D. from Case Western Reserve University.Tom is a certified public accountant (Ohio), certified financial planner® (CFP®) certificant and chartered financial analyst® (CFA®) charterholder. Prior to joining the University of Miami, Tom practiced public accounting and financial planning for 10 years, primarily with Deloitte & Touche, and Pritchett Dlusky & Saxe in Columbus, Ohio. He has also served as a consultant to law firms, accounting firms, professional associations, and governmental agencies in the areas of financial statement analysis and valuation.
Accounting Principles and Financial Statements (Portfolio 5116) Jennifer Roeleveld, CA(SA)Professor Jennifer Roeleveld, B.Compt (Hon)(SA), B.Com (Honours) (Taxation), LLM University of Cape Town; CA(SA), member of the South African Institute of Chartered Accountants (SAICA); member of the International Fiscal Association. Executive board member of the South African Fiscal Association; member of the National Tax Committee of SAICA and Integritax; head of taxation, Faculty of Commerce, University of Cape Town and registered tax practitioner.
Business Operations South Africa (Portfolio 982) Steven Roll, Senior State Tax Law Editor
Steven Roll, senior state tax law editor, has been with BNA more than 10 years, all of them with BNA Tax & Accounting, where he has covered state tax developments for the Multistate Tax Report, Weekly State Tax Report, and Daily Tax Report. Steve received his B.A. from the State University of New York at Albany, and a law degree from the University of Baltimore. His areas of specialization are corporate taxation and green incentives. He is the immediate past president of the American Society for Business Publication Editors.
Marjorie Rollinson, Esq.
Marjorie A. Rollinson, Esq. is with Ernst & Young, LLP's International Tax Services division in Washington D.C. and is a frequent contributor to BNA's International Journal.
Ricardo J. Romulo, Esq.Ricardo J. Romulo, B.S., cum laude, Georgetown University (1955); J.D., Harvard Law School (1958); Senior Partner, specializing in foreign investments and taxation, Romulo, Mabanta, Buenaventura, Sayoc & de los Angeles; Chairman, Makati Business Club and member, Philippine-United States Business Council; member, 1986 Constitutional Commission, which drafted the present Constitution of the Philippines; former President, Philippine Bar Association.
Business Operations the Philippines (Portfolio 978) Nicholas Ronan
Nicholas Ronan is an executive director with E&Y's San Jose office.
Arthur RosenMr. Rosen is a partner in the law firm of McDermott Will & Emery, where his practice focuses on tax planning and litigation relating to state and local tax matters. He has served as the Deputy Counsel to the New York State Department of Taxation and Finance, Tax Counsel to the New York State Senate Tax Committee and Counsel to the N.Y. Governor's Temporary Sales Tax Commission. Mr. Rosen has held executive tax management positions at Xerox Corp. and AT&T. Mr. Rosen holds leadership positions in professional tax organizations including the New York State Bar Association tax section, the NYU Tax Society, and the National Association of State Bar tax sections. He is past chair of the State and Local Tax Committee of the American Bar Association tax section. Mr. Rosen is editor of the newsletter Inside New York Taxes, is co-editor of the newsletter New York Tax Highlights and of New York Tax Cases. He has written scores of articles that have appeared in numerous professional publications, has made hundreds of presentations on state and local tax matters, and founded and chairs the New York University course entitled “Introduction to State and Local Taxes.” He is a member of the American College of Tax Counsel and is listed in The Best Lawyers in America.
Jurisdictional Limitations: Attributional Nexus (Portfolio 1430)Sales and Use Taxes: Streamlined Sales Tax System (Portfolio 1270)Sales and Use Taxes: General Principles (Portfolio 1300) Howard D. Rosen, Esq.Howard D. Rosen, B.B.A., University of Miami (1969, magna cum laude); J.D., University of Miami (1973, summa cum laude); member, Editorial Board, University of Miami Law Review; Certified Public Accountant, Florida; member, Florida Bar; member, Tax and International Law Sections of the Florida Bar; Adjunct Professor of Law, University of Miami School of Law (1990- ); member, Board of Governors of the Florida Institute of Certified Public Accountants (1997-1999), member, Florida Institute of Certified Public Accountants, past president and director of the South Dade Chapter of the Florida Institute of Public Accountants.
Asset Protection Planning (Portfolio 810)U.S. Taxation of Foreign Estates, Trusts and Beneficiaries (Portfolio 854)U.S. Taxation of Foreign Estates, Trusts and Beneficiaries (Portfolio 911) Jeffrey I. Rosenberg, Esq.Jeffrey I. Rosenberg, undergraduate degree, University of Rhode Island; J.D., Western New England College School of Law; LL.M. in Taxation, Georgetown University Law Center; formerly Attorney-Advisor, Passthroughs and Special Industries Division of the Office of Chief Counsel, Internal Revenue Service; speaker and lecturer, various tax institutes; author, various articles on tax issues in partnership area.
Limited Liability Companies (Portfolio 725) Robert J. Rosepink, Esq.Robert J. Rosepink, B.A., Amherst College (magna cum laude, 1972), Phi Beta Kappa; J.D., The George Washington University (with honors, 1975); partner, Rosepink & Estes, P.L.L.C., Scottsdale, Arizona; Member: Maricopa County Bar Association, State Bar of Arizona (Chair, Section of Real Property, Probate and Trust Law, 1984), American Bar Association (Sections: Real Property, Probate and Trust Law; Taxation), Estate Planning Seminar Group, and Trusts and Estates magazine Mini-Board for Estate Planning and Taxation (1995–1999); Fellow: American College of Trust and Estate Counsel and American College of Tax Counsel; Draftsperson, Arizona versions of Revised Uniform Principal and Income Act and Uniform Trustees' Powers Act (1984); author, Arizona Probate (Bancroft-Whitney 1980) and various articles; listed in Best Lawyers in America.
Charitable Remainder Trusts and Pooled Income Funds (Portfolio 865) John S. Ross, III Esq.
John Ryan of Matheson Ormsby Prentice Solicitors is a Fellow of The Institute of Chartered Accountants in Ireland.
Heather M. Rothman
Heather M. Rothman has been a reporter with BNA since 2001, joining the Daily Tax Report staff in 2007. She covers tax legislation. She holds a B.A. in Journalism and an M.A. in Political Management from the George Washington University. Her prior experience includes nearly two years at Congressional Quarterly. She is BNA’s representative on the Executive Committee of Periodical Correspondents in Congress.
Howard J. Rothman, Esq.Howard J. Rothman, B.A., City College of New York (1967); J.D., Brooklyn Law School (1971); LL.M., New York University School of Law (1972); member, American Bar Association, Section of Taxation, Committee on Corporate Tax; member, New York State Bar Association, Section of Taxation, Committee on Corporations, Committee on Partnerships, and Committee on Income from Real Property; member, International Bar Association, Committee on Taxation; Advisory Board, Tax Management Real Estate Journal; member, New York State Bar; co-author, Tax Management Portfolios No. 561, Capital Assets and No. 759, Transfers to Controlled Corporations: Related Problems.
Capital Assets (Portfolio 561)Transfers to Controlled Corporations: General (Portfolio 758)Transfers to Controlled Corporations: Related Problems (Portfolio 759) Robert P. Rothman, Esq.Robert P. Rothman, Of Counsel, Piper Rudnick L.L.P., New York, New York; B.S., Cornell University 1978; J.D., Columbia University 1981; Formerly associated with Skadden, Arps, Slate, Meagher & Flom L.L.P., New York, New York.
Structuring Corporate Acquisitions — Tax Aspects (Portfolio 770) Gideon Rothschild, Esq.Gideon Rothschild, B.B.A., Bernard M. Baruch College of the City University of New York, 1973; J.D., New York Law School, 1980, with honors; Partner and Co-Chair, Trusts & Estates and Wealth Preservation Group, Moses & Singer LLP, New York, New York; member New York Bar, U.S. Tax Court, U.S. District Court Southern District of New York, American College of Trust and Estate Counsel, International Academy of Estate and Trust Law, New York State Bar Association, American Bar Association Real Property Trust & Estate Section, Adjunct Professor at University of Miami School of Law Graduate Program; speaker on asset protection and advanced estate planning strategies; author of articles on asset protection, trusts and estate planning, including contributions to Trusts and Estates magazine, BNA Tax Management Portfolio, and American Bar Association publications.
Asset Protection Planning (Portfolio 810) Mark RoweMark S. Rowe, MBA, University of Texas; B.S. (Accounting) (cum laude), Ohio State University. Mr. Rowe has over 15 years of experience providing financial management to high growth public and private technology companies. He began his career in public accounting as a CPA with Arthur Young & Company and later with Peat, Marwick, Mitchell and Company. Since 1997, he has been a chief financial officer with Interim Management Services, LLC, Tatum CFO LLC, and, most recently, TLMI Corporation.
Revenue Recognition: Software (Portfolio 5103) Allen RubenfieldAllen J. Rubenfield, CPA, J.D., University of Pittsburgh; M.B.A., University of Pittsburgh; B.A., Pennsylvania State University. Allen Rubenfield has authored numerous articles for both practitioner and academic journals, including The CPA Journal, The Journal of Applied Business Research, and the New Accountant. He is currently a Lecturer of Accounting at the Stetson School of Business and Economics, Mercer University in Atlanta, GA. He is a licensed Certified Public Accountant in Maryland and a licensed attorney in both Pennsylvania and the District of Columbia.
Accounting by Partnerships (Portfolio 5209) Charles D. Rubin, Esq.
Charles D. Rubin, Esq., University of Florida (1983); B.A. (Political Science), Northwestern University (1980); member, Florida Bar; Vice–chairman, Foreign Tax Advisory Committee of Florida Bar, Tax Section (1988); Author, “The FIRPTA Manual — Compliance and Planning Guide to the Foreign Investment in Real Property Tax Act” (Maxwell McMillan); Author, “Florida Sales and Use Taxes on Boats — Compliance and Planning Manual” (Florida Tax Publications); Contributor to: University of Florida Law Review, Journal of Bank Taxation, Marine Business Journal, Tax Ideas, Tax Management Estates, Gifts and Trusts Journal, Tax Notes, Journal of Taxation, Callaghan & Co. publications, Bureau of National Affairs publications; Adjunct Professor, University of Miami School of Law, Graduate Program in Taxation and Graduate Program in Estate Planning (1991–present).
Eric Rubin, Esq.
Eric B. Rubin, Esq. is with Dechert LLP in Philadelphia, PA and is a frequent contributor to BNA Tax & Accounting's Financial Planning Journal.
William RulandWilliam Ruland, Ph.D., SUNY at Buffalo, New York (1976), MBA, SUNY at Buffalo, BS, Pennsylvania State University Industrial Engineering. Areas of expertise include financial accounting and financial statement analysis. Author of numerous publications in journals of accounting and finance. Editorial Board, Journal of Accounting and Public Policy, 1982-present.
Management's Discussion and Analysis (Portfolio 5107) Denise Ryan, State Tax Law Editor
Denise Ryan, who joined BNA in 2005, covers state tax credits and incentives issues for the Multistate Tax Report, Weekly State Tax Report, and Daily Tax Report. She previously worked at Lexis/Nexis as a state code editor, at Legal Times covering local court decisions, and at the American Health Lawyers Association. She is a graduate of Catholic University and Catholic University Law School.
Risto Rytohonka, Esq.
Risto Rytöhonka, LL.B., 1978 (University of Helsin