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International Tax Issues 2013 (Chicago)

 
Author(s): Lowell D. Yoder
Practice Area: International Law, Tax
Published: Sep 2013
PLI Item #: 48547
CHB Spine #: D388

Mr. Halpern's practice focuses on the U.S. federal income taxation of international

transactions. He has broad experience advising U.S.- and foreign-based clients on the taxation of cross-border operations, acquisitions, dispositions, and restructurings.

He has successfully represented clients in federal tax controversies at all levels, including a number of cases before the United States Tax Court, and has substantial experience managing complex tax controversies with the Internal Revenue Service.

Mr. Halpern is a frequent chairman and speaker at conferences on U.S. corporate and international income taxation, having spoken before the Tax Executives Institute, the NYU Institute on Federal Taxation, and the Council for International Tax Education, among others. He is an adjunct professor at Golden Gate University's Masters in Taxation program, teaching classes in U.S. international income tax.

He has written on a wide range of U.S. international tax rules and developments. His recent articles include:

  • Some Further Thoughts on Covered Asset Acquisitions: Can the IRS Save Us (and Itself) from Code Sec. 901(m)?, International Tax Journal (May – Jun. 2011)
  • Branch Rule Update: Two IRS Private Letter Rulings Offer Guidance on the Effective Rate of Tax Test, International Tax Journal (Jan. – Feb. 2010)
  • Section 905(c) Temporary Regulations: New Adjustment and Notification Requirements in the Case of Foreign Tax Redeterminations, Journal of Taxation (Aug. 2008)

SERVICES

Practices
Tax

EDUCATION & BAR MEMBERSHIP

J.D., Hastings College of the Law
summa cum laude

A.B., Philosophy
Princeton University

Member of the State Bar of California

Member of the American Bar Association Section of Taxation


Damon M. Lyon is a partner in the law firm of McDermott Will & Emery LLP and is based in the Firm’s Chicago office. Damon focuses his practice on international planning for multinational companies.

He advises clients on a broad range of cross-border tax issues, including foreign tax credits, subpart F and other anti-deferral rules, as well as cross-border acquisitions, dispositions, mergers, reorganizations, joint ventures and financings. He also provides advice concerning multi-jurisdictional business structures, such as centralized holding company and finance company structures.

Education

University of Michigan Law School, J.D., (cum laude) , 2000
Michigan State University, B.A.

Related Services

International Tax
Tax
U.S. and International Tax


David Waimon is a member of Ernst & Young LLP's International Tax Services practice and is based in Chicago. David's practice focuses on transactional and international tax planning.

Dave serves as the firm's Associate Director of ITS Transaction Services, and is responsible for coordinating the cross-border transaction practice.

An attorney and CPA, Dave joined Ernst & Young as a partner in 2001. He has been identified as one of the leading U.S. tax practitioners by the International Tax Review.  Prior to joining the firm, Dave was a partner at the law firm of Baker & McKenzie where he specialized in international taxation.

Dave is an adjunct professor at Northwestern University School of Law where he teaches Taxation of International Transactions. He serves on the Planning Committee for the University of Chicago Federal Tax Conference and on the Advisory Board for the Journal of Taxation of Global Transactions. He is a member of the American Bar Association Section on Taxation, the Illinois State Bar Association, and The Chicago Bar Association.

He is a frequent speaker for the World Trade Institute, the Tax Executives Institute, ATLAS, Council for International Tax Education, and Practicing Law Institute, and the author of numerous articles regarding international taxation (see attached Exhibit).

Dave is a graduate of Illinois State University (B.S, high honors, 1980) and the University of Illinois School of Law (J.D., magna cum laude, 1984). He earned his CPA certificate in 1980. He was admitted to the District of Columbia Bar in 1984 and the Illinois Bar in 1985.


Eric Solomon is the Co-Director of Ernst & Young LLP’s National Tax Department in Washington, DC.  Eric advises clients on a wide range of transactional and tax policy issues.  He has more than 35 years of tax experience in private practice and government service.

Eric served as Assistant Secretary for Tax Policy at the U.S. Treasury Department from December 2006 to January 2009.  As Assistant Secretary, he headed the Office of Tax Policy, which serves as the primary advisor to the Treasury Secretary on legal and economic matters relating to domestic and international taxation.

Eric joined the Office of Tax Policy in 1999.  He served in both the Clinton and George W. Bush Administrations. He was Senior Advisor for Policy, Deputy Assistant Secretary (Tax Policy) and Deputy Assistant Secretary (Regulatory Affairs) prior to his 2006 confirmation as Assistant Secretary.

In recognition of his accomplishments at the Treasury Department, Eric received the Alexander Hamilton Award, which is the highest award for Treasury service, and the Distinguished Presidential Rank Award. The Tax Council Policy Institute presented Eric its first Pillar of Excellence Award for his contributions in the field of tax law and policy. The Tax Foundation and the Tax Executives Institute presented him their Distinguished Service Awards. The Taxation Section of the Federal Bar Association presented Eric the Kenneth H. Liles Award for Distinguished Service. He also received an outstanding achievement award from the Taxation Section of the State Bar of Texas and the first Distinguished Service Award presented by the Taxation Section of the State Bar of California.

From 1996 to 1999, Eric was a principal in Ernst & Young LLP’s National Tax Mergers and Acquisitions group in Washington, DC. Previously, he was Assistant Chief Counsel (Corporate) at the Internal Revenue Service, heading the IRS legal division responsible for all corporate tax issues. He began his career with law firms in New York City and was a partner at Drinker Biddle & Reath in Philadelphia.

Eric received his A.B. from Princeton University (Phi Beta Kappa), his J.D. from the University of Virginia and his LL.M. in taxation from New York University. He is a member of the Executive Committee of the Tax Section of the New York State Bar Association. He was Vice Chair for Government Relations for the American Bar Association Section of Taxation and is currently Vice Chair of the ABA Corporate Tax Committee. He is co-chair of the Practising Law Institute conference on Tax Strategies for Corporate Acquisitions and Dispositions.

Eric is an adjunct professor of law at Georgetown University Law Center, where he teaches a course in corporate taxation. He received the 2012-2013 Charles Fahy Distinguished Adjunct Professor Award for Georgetown University’s graduate law programs.


JIM FULLER is a partner in the Tax Group at Fenwick & West LLP in Mountain View, California.  He is one of the world’s top 25 tax advisers, according to Euromoney. 

Fuller is described as one of the three “most highly regarded” U.S. tax practitioners in Law and Business Research’s Who’s Who Legal (2015), and is the only U.S. tax adviser to receive a coveted Chambers star performer rating (higher than first tier) in Chambers USA (2015).

Fuller authored or coauthored several NYS and ABA Bar Association Tax Section reports (creditability, 367(b), cost sharing, foreign currency, entity characterization, etc.).  Five of these reports were published in NYU’s Tax Law Review or the ABA’s Tax Lawyer.

Nine Fenwick tax partners have appeared in Euromoney’s World’s Leading Tax Advisors, seven appear in ITR’s World’s Tax Controversy Leaders and five have appeared in Euromoney’s World’s Leading Transfer Pricing Advisors.

Fenwick & West LLP has represented 6 of the Fortune Top 10 companies, over 50 of the Fortune 100 companies, and over 100 of the Fortune 500 companies in federal tax matters.  Fenwick is first tier in Tax Planning, Tax Transactional, and Transfer Pricing, according to International Tax Review.

Fuller and his firm have served as counsel in over 150 large-corporate IRS Appeals proceedings and over 70 federal tax court cases. 

Fenwick & West was named San Francisco Tax Firm of the Year six times by International Tax Review.  Fenwick also was named ITR’s U.S. Tax Litigation Firm of the Year three times, and has received multiple ITR M&A tax awards including Americas M&A Tax Firm of the Year.  These awards were given at ITR’s annual and well-attended Americas Awards Dinners in New York City.


Domestic and international acquisitions and reorganizations, foreign currency issues, subpart F and foreign tax credit provisions. Mr. McDonald has also been involved in a number of federal tax controversies, including AMP, Inc. v. United States, Laidlaw v. Commissioner, and Square D v. Commissioner. Mr. McDonald has also been involved in a number of Illinois state tax controversies.

Publications, presentations and articles

Mr. McDonald has written/co-authored a number of publications, including but not limited to:

  • International Aspects of Section 304 Transactions, Tax Strategies for Corporate Acquisitions, Dispositions, Spin-Offs, Joint Ventures, Financings, Reorganizations and Restructurings published by Public Law Institute (2004);
  • James M. O’Brien, et. al., U.S. Corporations Doing Business Abroad (ed. 1998, 2002, 2004, 2006, 2008, 2010 & 2013);
  • Mr. McDonald co-authors a bi-monthly column entitled, “International Tax Watch” for TAXES magazine.

Awards and rankings

Mr. McDonald has been named one of the top tax advisors by Chambers USA (2011, 2012, 2013 and 2014), and as one of the top ten international tax advisers in the Midwest region by Euromoney’s International Tax Review (2003). He was also mentioned in World Tax 2007 as an attorney in Chicago known for cross border M&A transactions.

Government service

Mr. McDonald served from September 1, 2005 to September 31, 2006, as the legal advisor to Dr. Anwar ul-haq Ahady, Minister of Finance for the Islamic Republic of Afghanistan. During this time, Mr. McDonald: assisted in the development of the income tax regulations and insurance regulations for Afghanistan; assisted with negotiations at the “Paris Club” and the drafting and execution of bilateral agreements between the United States, Germany and Russia confirming debt relief for Afghanistan; and participated in a number of other projects on behalf of the Islamic Republic of Afghanistan.

Education and admission

Education:

  • Northwestern University School of Law (J.D., magna cum laude)
  • Certified Public Accountant
  • Marquette University, (B.A., Accounting, summa cum laude)

Admissions:

  • Illinois
  • Northern District of Illinois
  • Federal Circuit Court of Appeals
  • U.S. Tax Court


Lowell D. Yoder is a partner in the law firm of McDermott Will & Emery’s Chicago office, and is head of the U.S. & International Tax Practice Group.  He focuses his practice on cross-border mergers and acquisitions, global tax planning and international tax controversies, representing high-tech, pharmaceutical, ecommerce, financial, consumer and industrial companies.  He advises on tax efficient structuring of cross-border acquisitions, dispositions, financings, internal reorganizations and joint ventures, as well as tax beneficial planning for intangible holding companies, global supply chains, and multi-jurisdictional services arrangements.  Lowell also represents clients before the Internal Revenue Service handling audits and obtaining tax rulings.  He works with an extensive network of lawyers worldwide developing tax favorable transactional and operational cross-border structures.

Lowell has spoken on a variety of international topics before numerous professional organizations.  He is the editor-in-chief of CCH’s International Tax Journal, and has authored and published numerous articles and treatises on international topics. Lowell was an adjunct professor at the Northwestern University School of Law, where he taught advanced international taxation.

Lowell is an active member of International Committees and Advisory Boards. He chairs Practising Law Institute’s International Tax Issues.  He is a fellow of the American College of Tax Counsel and is USA Branch Counsel of the International Fiscal Association.  He is a member of the Planning Committees for the University of Chicago Law School’s Annual Federal Tax Conference and the GWU/IRS Annual Institute on International Taxation, and on the Advisory Board of the Tax Management International Journal.


Manal Corwin is KPMG LLP’s National Service Line Leader for International Corporate Services as well as Principal-in-Charge of Washington National Tax—International Tax Policy.  She recently rejoined the firm following completion of her tenure as Deputy Assistant Secretary of Tax Policy for International Affairs in the Treasury Department.

Professional and Industry Experience

During her tenure at the U.S. Treasury Department, Manal helped shape the Administration’s views and policies in all areas of international taxation and worked closely with the IRS, members of Congress, and key tax regulators globally. Importantly, Manal was responsible for leading the development of the intergovernmental approach by which the U.S. government is implementing the Foreign Account Tax Compliance Act (FATCA) and worked to forge an implementation framework that meets the needs of governments, financial institutions, and other stakeholders.  Manal also served as head of the delegations responsible for negotiating income tax treaties with Japan, Spain, Chile, and the United Kingdom and as the U.S. delegate and Vice Chair to the OECD’s committee on fiscal affairs as well as the U.S. delegate to the Global Forum on Tax and Transparency.

Prior to Joining the Treasury Department (first as International Tax Counsel in the Office of Tax Policy and then as Deputy Assistant Secretary for International Tax Affairs), Manal was a principal in KPMG’s Washington National Tax practice from 2001 to 2009, where she advised multinational corporations on U.S. international tax aspects of their operations and transactions and represented clients in tax controversies before the IRS.

Earlier in her career, Manal served as the Deputy and then Acting International Tax Counsel in the Office of Tax Policy at the U.S. Treasury Department. Prior to that, Manal practiced as an attorney specializing in international taxation at the law firm of Covington & Burling in Washington, D.C.  Manal also served as a judicial clerk for then Chief Judge Levin Campbell on the U.S. Court of Appeals for the First Circuit.

Other Activities

Manal served as Editor-in-Chief of the Boston University Law Review 1990-1991; Ordronaux Prize, 1991; Edward Hennessey Distinguished Scholar, 1990-1991; Paul J. Liacos Scholar, 1989-90; G. Joseph Tauro Distinguished Scholar, 1988-89.

She formally served as a member of the American Bar Association, the boards of the National Foreign Trade Council and the National Foreign Trade Council Foundation, and the Advisory Board for the GW-IRS Annual Institute on Current Issues in International Taxation.

Function and Specialization

Manal S. Corwin advises multinational corporations on U.S. international tax aspects of their structures, operations and transactions.  She specializes in consulting and advising on issues relating to expense allocation, the source of income rules, foreign tax credits, subpart F, U.S. taxation of international transportation income and certain special tax benefit provisions.

Professional Associations

Member of the Massachusetts Bar Association
Member of the District of Columbia Bar Association

Languages

Fluent in Arabic
Conversant in French

Education, Licenses & Certifications

J.D. magna cum laude, from the Boston University, School of Law, May 1991
A.B. in Psychology, cum laude, from Harvard University, June 1986

 


Michael A. DiFronzo serves as a Principal in the Washington National Tax Office of PricewaterhouseCoopers LLP.  In that role, Mr. DiFronzo serves as a global resource for the firm’s international tax practice.  His practice includes all aspects of international taxation, with a particular focus on international mergers, acquisitions and restructurings and the U.S. anti-deferral rules.  He also works closely with U.S. and non-U.S. based multinationals on cross-border financing, cash repatriation and other planning issues. 

Before joining PricewaterhouseCoopers, Mr. DiFronzo was a senior executive in the U.S. Treasury Department.  He worked for the Office of Chief Counsel, Internal Revenue Service as the Deputy Associate Chief Counsel (International – Technical).  In that capacity, he had primary responsibility for the oversight of published guidance related to the taxation of cross-border investment and related issues.  Mr. DiFronzo served in that role from 2006 - 2010.

Prior to joining the Office of Chief Counsel, Internal Revenue Service, Mr. DiFronzo served as a partner in the Tax Department of McDermott Will & Emery LLP in Chicago, Illinois.  There he served as an international tax attorney for large U.S. and non-U.S. multinational corporations.  Mr. DiFronzo’s work experience also includes the National Tax Office of Deloitte & Touche LLP and the Washington, DC office of Weil Gotshal & Manges LLP.

Mr. DiFronzo received an LL.M. in taxation from New York University School of Law, a J.D. from University of Montana School of Law, and a B.S. in Accounting from Montana State University.  Mr. DiFronzo served on the Board of International Tax Advisors and as a guest lecturer for New York University School of Law’s graduate tax program from 1999 - 2010.   Mr. DiFronzo also served on the Board of Visitors for the University of Montana School of Law from 2006 - 2011.

Mr. DiFronzo’s professional affiliations include the tax sections of the American Bar Association and the DC Bar Association, as well as the International Fiscal Association.  He is the author of numerous articles on cross-border tax issues and a frequent speaker.  Mr. DiFronzo is currently a member of the District of Columbia, Illinois, Montana and Nevada bar associations and is admitted to practice before the United States Tax Court.  He is also licensed as a CPA.


Nicholas J. DeNovio is a partner in the Washington, D.C. office of Latham & Watkins and is Global Chair of the firm's International Tax Practice. He is also a member of the Firm's Audit Committee. Throughout his career, Mr. DeNovio has represented large US and non-US based multinational corporations on complex cross-border transactions involving mergers and acquisitions, spin-offs, financings and group structuring.

He is also a well-known speaker and writer for organizations such as the Tax Executive Institute, Practicing Law Institute, International Fiscal Association, National Foreign Trade Council and various bar associations.

From 2003-2005, Mr. DeNovio served as Deputy Chief Counsel (Technical) at the Internal Revenue Service Office of Chief Counsel. In his position, Mr. DeNovio directly supervised the IRS Regulatory guidance program carried out by more than 600 Chief Counsel attorneys working with the Treasury Department's Office of Tax Policy. One of his accomplishments was leading the Regulatory guidance required quickly after the enactment of the American Jobs Creation Act of 2004, including guidance under sections 965 (temporary rate reduction for repatriated foreign earnings) and 199 (manufacturing deduction).


Mr. Oosterhuis is a senior international tax partner in the Washington, D.C. office of Skadden, Arps, Slate, Meagher & Flom.  Mr. Oosterhuis has had extensive experience in international acquisition and disposition transactions, financing arrangements and tax planning for U.S. and foreign-based multinational corporations.  He frequently represents clients on controversy matters, as well as regulations and rulings proceedings, with the Internal Revenue Service.  In addition, he represents clients in intercompany pricing matters, including docketed Tax Court cases and Advance Pricing Agreement negotiations.

He received his B.A. from Brown University and his J.D. Degree from Harvard Law School.  After law school he became a Legislation Attorney for the Joint Committee on Taxation, U.S. Congress, and later served as the Committee's Legislation Counsel.  He has served as an Adjunct Professor at Georgetown University Law Center, where he taught International Taxation in the Master of Taxation graduate law program.

He has lectured at various professional seminars and institutes, has written on a variety of subjects relating to tax matters, and has testified before Congressional tax writing committees on various tax legislative issues.  He is a member of the bar of the District of Columbia and is admitted to practice in the U.S. Tax Court.


Bob Stack is the Deputy Assistant Secretary for International Tax Affairs in the Office of Tax Policy at the US Department of the Treasury. In this capacity, he is responsible, on behalf of the Assistant Secretary, for the conduct of legal and economic aspects of tax policy relative to the representation of the United States in bilateral and multilateral relations with other countries, as well as advising the legal and economic staffs within the Office of Tax Policy, other offices of the Treasury Department and other government agencies as to policy analysis and interpretation for domestic legislation and administrative guidance in all matters involving cross border taxation. Mr. Stack serves as the U.S. delegate to the Committee on Fiscal Affairs (CFA) in the Organization for Economic Cooperation and Development (the OECD). In addition, Mr. Stack oversees the Office of Tax Policy’s participation in the various working bodies of the CFA and sits on the CFA Bureau (the CFA’s governing body). Mr. Stack also serves as the U.S. delegate to the Global Forum on Transparency.

Prior to joining Treasury, Mr. Stack served as head of the international tax practice group at the law firm of Ivins, Phillips & Barker. In the private sector, he has over 26 years of experience in international tax matters, representing both corporations and individuals. His work for corporations has included structuring both inbound and outbound ventures, the establishment of efficient cross border structures, the formation of joint ventures and private equity funds and all aspects of international mergers and acquisitions.

He is a member of the American Bar Association Tax Section, New York State Bar Association Tax Section, and International Fiscal Association. Mr. Stack has participated in numerous panels on international tax issues at the meetings of the American Bar Association Tax Section as well as the Federal Bar Association. He graduated from Georgetown University Law Center in 1984, where he was editor-in-chief of the Georgetown Law Journal. After graduating, he clerked for Judge Thomas A. Flannery of the United States District Court for the District of Columbia and Justice Potter Stewart (Ret.) of the United States Supreme Court.


Rocco V. Femia is a member of Miller & Chevalier Chartered.  Mr. Femia’s practice focuses on international tax planning for domestic and foreign-based enterprises, and on assisting such enterprises in avoiding or resolving controversies involving U.S. international tax rules, transfer pricing, and U.S. tax treaties.  Mr. Femia routinely advises businesses on Advance Pricing Agreements and mutual agreements under tax treaties.

Mr. Femia is a former Associate International Tax Counsel at the U.S. Department of the Treasury, Office of Tax Policy.  While at the Treasury, Mr. Femia had responsibility for a broad spectrum of U.S. tax treaty and international tax regulatory and legislative matters. 

Mr. Femia writes and speaks regularly on a variety of international tax and transfer pricing issues, and is a former Adjunct Professor at the Georgetown University Law Center.  Mr. Femia graduated, magna cum laude, from Georgetown University Law Center in 1995.  He received his B.A. in Economics from Duke University in 1991.


Background

  • Steven is a Principal at Ernst & Young LLP and is head of the firm’s international mergers & acquisitions practice.
  • Steven is an honors graduate of St. Ambrose College and the University of Notre Dame Law School and he was admitted to the practice by the Illinois Bar (1985).
  • Steven was named one of the world’s leading cross border M&A tax advisors by International Tax Review in each year from 2003 through 2012 as well as one of the world’s leading international tax advisors by Euromoney in each year from 1999 through 2012.

Professional experience

  • Steven represents both U.S. and non-U.S. multinational corporations in cross border mergers, acquisitions, restructurings, spin-offs, dispositions, financings and joint ventures. He has represented some of the world’s largest corporations in the technologies, pharmaceutical, financial services, natural resources, chemicals and manufacturing industries.
  • Steven is also an adjunct Professor of Law at Northwestern University School of Law where he teaches an advanced class on cross border M&A transactions.  He is a frequent speaker before a variety of tax organizations including the American Bar Association, The Tax Executives Institute, and the Practicing Law Institute. Steven has authored (or co-authored) tax articles for the Journal of International Taxation, Taxes, the Practicing Law Institute Handbook on Mergers and Acquisitions, the Journal of Taxation of Financial Products, and Tax Notes. Steven is also on the Planning Committees of the University of Chicago Federal Tax Conference.  Prior to joining Ernst & Young LLP, Steven was a partner at a major international law firm.


T. Timothy Tuerff is the Managing Partner of the Washington National Tax Office of Deloitte Tax, LLP.  In this role Mr. Tuerff leads the Washington National Tax practice in providing tax analysis to clients engaged in multinational corporate and investment transactions.  The professionals of this office analyze issues and transactions with respect to specific client matters as well as review current tax developments and their impact on Deloitte clients.

Mr. Tuerff specializes in international tax issues and serves U.S.-based multinational corporate clients engaged in cross-border transactions. His practice involves tax analysis related to structuring international business operations, mergers and acquisitions, financing and utilization of foreign tax credits. He testified before the U.S. Congress Ways and Means Subcommittee on Select Revenue Measures concerning Chairman Camp’s 2011 International Tax Reform Discussion Draft addressing a territorial system of taxation.

Mr. Tuerff formerly served as Special Assistant to the Chief Counsel and Special Assistant to the Associate Chief Counsel (International) of the Internal Revenue Service. He is a frequent contributor to tax periodicals, including Tax Notes and Tax Notes International and the Practicing Law Institute journal, Tax Planning for Domestic & Foreign Partnerships, LLCs, Joint Ventures & Other Strategic Alliances and the American Bar Association, International Franchising Journal.   Mr. Tuerff is also a frequent speaker at seminars on international tax issues addressing such groups as Tax Executives Institute, International Fiscal Association, and the Tax Council Policy Institute Symposium.  Tim currently serves on the 2012 Advisory Board for the Internal Revenue Service – George Washington University International Tax Symposium.

Mr. Tuerff is a graduate of Indiana University School of Law and School of Business. He is a member of the American Bar Association and the District of Columbia Bar Association and is a District of Columbia certified public accountant.


"extremely confident and persuasive in the courtroom and a pleasure to work with" Chambers USA 2008

Since joining Mayer Brown in 1990, Tom Kittle-Kamp has represented clients in all phases of tax controversy and litigation. His litigation experience includes the trial and appeal of major corporate cases involving Section 482 allocations, substance-over-form theories, intangible assets, debt-equity characterization, valuation disputes, capitalization questions, Subpart F and other international tax issues, Subchapter C issues, and leasing transactions. Tom also maintains an extensive practice of advising and representing clients with respect to administrative matters, including IRS audits, IRS Appeals (including Fast Track and appeals mediation procedures) and competent authority negotiations. He also represents corporate clients with respect to tax-sharing disputes.

Tom has deep experience in all aspects of international transfer pricing, particularly matters involving intangible assets and intellectual property. He provides tax planning advice with respect to cross-border transactions involving intangible assets, goods and services; transfer-pricing documentation; and the development, exploitation and disposition of intangible assets, including licenses, sales and cost-sharing arrangements. He is co-author of the treatise Federal Income Taxation of Intellectual Properties and Intangible Assets (Warren, Gorham & Lamont 1997), which is updated twice a year. Before law school, he worked for several years as a newspaper reporter.

According to Chambers USA, Tom is "extremely confident and persuasive in the courtroom and a pleasure to work with." According to Legal 500, Tom is "a very rare combination - a subtle courtroom advocate and a real tax expert." Tom has been recognized by Chambers USA from 2008 through 2012, by Legal 500 from 2008 through 2012, by the International Tax Review Tax Controversy Leaders guide for 2011 and 2012, and by the Euromoney 2010 "Guide to theWorld's Leading Tax Advisors."

News & Publications

  • "Massachusetts District Court Explores the United States’ Burden of Proof Argument on Deductions of Government Settlements," Mayer Brown Legal Update, 21 May 2013
  • "US Ninth Circuit Reverses Course in Xilinx, Rejects IRS Effort to Require Cost Sharing of Employee Stock Options," Mayer Brown Legal Update, 24 March 2010
  • "Ninth Circuit Reverses Tax Court in Xilinx, Rules IRS Administrative Position Contrary to Arm’s Length Standard," Mayer Brown Legal Update, 29 May 2009
  • "Federal Income Taxation of Intellectual Properties & Intangible Assets," (Warren, Gorham & Lamont 1997)


Tom is a principal in the International Tax Group of KPMG’s Washington National Tax practice.

Tom focuses on structuring the operations of multinational corporations, primarily in the industrial and consumer market sectors. Tom has led a number of international supply chain redesign projects for U.S. multinationals involving the establishment of regional entrepreneur companies.  He also has significant experience advising non-U.S. multinationals on issues related to the establishment and operation of their U.S. businesses, including the application of treaty provisions, the U.S. effectively connected income rules, and the U.S. interest-stripping rules.

Tom has considerable experience in tax controversy matters, particularly those involving transfer pricing. He has represented taxpayers before IRS Appeals throughout the US, in the US Tax Court, and in competent authority proceedings.

Tom served as the United States reporter on business restructurings to the 2011 International Fiscal Association World Congress.  He has spoken at many of the world’s leading tax forums, including the George Washington/IRS Tax Conference, the University of Chicago Tax Conference, several national and international meetings of the International Fiscal Association, the American Bar Association’s annual meeting, and the Tax Executive Institute’s annual meeting.

Tom is recognized in both Euromoney’s Guide to the World’s Leading Tax Advisors and Guide to the World’s Leading Transfer Pricing Advisors.

Tom received his B.A. in Economics, summa cum laude, from Columbia University and his J.D., cum laude, from the Harvard Law School.


Will is an investment banker at Citigroup Global Markets Inc., where he focuses on tax-advantaged domestic and cross-border M&A transactions and capital structure solutions for public and private companies.

Will has served as an adjunct assistant professor at Brooklyn Law School where he has taught classes on the taxation of securities and derivatives and the taxation of partnerships.  He has given guest lectures for classes at Harvard Law School and NYU’s Leonard N. Stern School of Business.

Will currently serves on the Board of Directors of the International Tax Institute, is a member of the New York Steering Committee of the International Fiscal Association, and was formerly Chair of the U.S. Activities of Foreigners and Tax Treaties Committee of the ABA’s Section of Taxation.  He is a former John S. Nolan Fellow and also served on the ABA’s Task Force on International Tax Reform.  Will speaks frequently about Federal income tax matters.

Prior to joining Citigroup, Will was employed as a Senior Attorney at Cravath, Swaine & Moore LLP, a law firm in New York City.  He earned his J.D. (magna cum laude) from Boston University School of Law in 1997.


Lowell D. Yoder is a partner in the law firm of McDermott Will & Emery’s Chicago office, and is head of the U.S. & International Tax Practice Group.  He focuses his practice on cross-border mergers and acquisitions, global tax planning and international tax controversies, representing high-tech, pharmaceutical, ecommerce, financial, consumer and industrial companies.  He advises on tax efficient structuring of cross-border acquisitions, dispositions, financings, internal reorganizations and joint ventures, as well as tax beneficial planning for intangible holding companies, global supply chains, and multi-jurisdictional services arrangements.  Lowell also represents clients before the Internal Revenue Service handling audits and obtaining tax rulings.  He works with an extensive network of lawyers worldwide developing tax favorable transactional and operational cross-border structures.

Lowell has spoken on a variety of international topics before numerous professional organizations.  He is the editor-in-chief of CCH’s International Tax Journal, and has authored and published numerous articles and treatises on international topics. Lowell was an adjunct professor at the Northwestern University School of Law, where he taught advanced international taxation.

Lowell is an active member of International Committees and Advisory Boards. He chairs Practising Law Institute’s International Tax Issues.  He is a fellow of the American College of Tax Counsel and is USA Branch Counsel of the International Fiscal Association.  He is a member of the Planning Committees for the University of Chicago Law School’s Annual Federal Tax Conference and the GWU/IRS Annual Institute on International Taxation, and on the Advisory Board of the Tax Management International Journal.