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Basics of International Taxation 2014

 
Author(s): Linda E. Carlisle, Kristeen R. Witt, John L. Harrington
Practice Area: International Law, Tax
Published: Jul 2014
PLI Item #: 51229
CHB Spine #: D414

John L. Harrington is a partner in Dentons’ tax practice.  He advises clients on tax planning, transactional and compliance issues; international tax legislative, regulatory, and treaty matters; and a variety of substantive and legislative domestic tax issues.  In particular, he has extensive experience in dealing with the foreign tax credit, anti-deferral regimes (including Subpart F income), cross-border activities of companies and individuals, and other international tax issues.

Prior to joining Dentons, Mr. Harrington served as International Tax Counsel for the U.S. Department of Treasury.  As International Tax Counsel, he directed and supervised the staff of the Office of the International Tax Counsel which provides legal advice and analysis relating to international tax issues, including legislation, regulations, and treaties. 

At the Treasury Department, he worked closely with the Internal Revenue Service to develop regulations and other administrative guidance.  He also interacted frequently with other Executive Branch officials, especially in the State Department, the Commerce Department, the Office of the U.S. Trade Representative, and the White House.

He represented the Treasury Department before Congress, including testifying at hearings.  He worked regularly with Congressional committees and staff on the international tax aspects of legislation, conducting briefings and participating in the development of legislative proposals.

While at the Treasury Department, Mr. Harrington worked closely with tax officials in other countries.  He represented the United States at tax-related meetings of the Organisation for Economic Cooperation and Development (OECD) and in tax-related trade disputes before the World Trade Organization.   

Before joining the Treasury Department, Mr. Harrington was a tax counsel on the U.S. House Committee on Ways and Means.  On the committee staff, Mr. Harrington was responsible for international, pass-through entities, financial institutions and products, real estate, environment, energy, and other tax issues.


Kristeen is a Legislation Counsel for the Joint Committee on Taxation, a nonpartisan committee that provides assistance to members of Congress and staff in the formulation of tax legislation. She specializes in the areas of international tax, excise tax, and estate and gift tax. Kristeen joined the Joint Committee in 2008. Prior to joining the Joint Committee, Kristeen held various positions in the private sector including, Tax Director for Zimmer Holdings, Inc.; Director of Domestic Tax Planning at Tricon Global Restaurants, Inc. (now Yum! Brands, Inc.), and Tax Planning Manager at Coopers & Lybrand.

Kristeen earned her Bachelor of Business Administration (Accounting Emphasis) with honors from the University of Washington, her J.D. magna cum laude from the University of Florida, and her LL.M. in Taxation from the University of Florida. She is also a certified public accountant.


Linda E. Carlisle's practice focuses on advising corporations and flow-through entities, such as partnerships, limited liability companies and Subchapter S corporations on both domestic and international tax issues. In addition, Ms. Carlisle assists clients with employee stock ownership plans (ESOPs), intercompany pricing issues, financial derivative product issues, and legislative, regulatory and administrative tax matters. Ms. Carlisle is also a leading authority on the taxation of publicly traded partnerships.

Ms. Carlisle advises U.S. and non-U.S. companies on reorganization and acquisition and sale transactions and successfully obtains private letter rulings from the Internal Revenue Service (IRS) when necessary. She also assists clients in devising and defending their transfer pricing. Clients quoted by Chambers have said that Ms. Carlisle is "a great technical resource. She renders her service in a very efficient way, and is very prompt and responsive. She does really good quality work and has excellent relationships with the IRS and Treasury."

She has testified before the U.S. Congress and the IRS, obtained numerous IRS private letter rulings, achieved favorable administrative and judicial resolutions of tax adjustments proposed by the IRS, obtained refunds of overpaid U.S. tax and successfully contested proposed foreign tax adjustments through tax treaty provisions ("competent authority" proceedings).

Before joining Miller & Chevalier, Ms. Carlisle was a Partner in the Washington, DC, office of White & Case and Cadwalader, Wickersham & Taft. She was in government service with the U.S. Department of the Treasury as the Special Assistant to the Assistant Secretary for Tax Policy and as an Attorney-Advisor in the Office of the Tax Legislative Counsel. While at the Treasury Department, Ms. Carlisle advised senior Treasury, White House and Congressional officials on domestic and international issues examined in the enactment of the Tax Reform Act of 1986. Ms. Carlisle, an Adjunct Professor at Georgetown University Law Center, is a frequent and sought after speaker on domestic and international tax issues, and has authored numerous articles.

Representative Engagements

  • Tax Counsel to a U.S.-based multinational corporation in structuring corporate reorganization and obtaining IRS ruling for transaction.
  • Tax Counsel to a U.S.-based multinational corporation in analyzing and resolving ESOP issues.
  • Tax Counsel to two trade associations representing their interests before Congress and the Administration.
  • Tax Counsel to U.S. and foreign-based multinational corporations on transfer pricing issues.
  • Advises foreign governments on possible legislative changes.

Government Experience

  • Special Assistant to the Assistant Secretary for Tax Policy, Office of the Tax Legislative Counsel, U.S. Department of the Treasury, 1985 - 1987
  • Attorney Advisor, Office of the Tax Legislative Counsel, U.S. Department of the Treasury, 1984 - 1985

Rankings and Recognition

  • Chambers USA: Tax (District of Columbia), 2009 - 2016
  • The Best Lawyers in America®: Tax Law, 2007 - 2017
  • International Tax Review: Women in Tax Leaders, 2015 - 2016
  • Legal 500: Government:Government Relations, 2015
  • Legal 500: Tax: Domestic Tax, 2007, 2010 - 2011, 2013 - 2015
  • Legal 500: Tax: International Tax, 2014
  • Tax Directors Handbook: U.S. Tax, 2008, 2011 - 2012, 2014
  • Expert Guides: Women in Business Law:Tax, 2013 - 2014
  • Expert Guides: Tax Advisers, 2014

Professional and Community Involvement

  • Adjunct Professor, Georgetown University Law Center
  • Former Chair, Tax Section, District of Columbia Bar
  • Former Chair, Sections Council, District of Columbia Bar
  • Fellow, American Bar Association
  • Advisory Board Member, The American Law Institute
  • Advisory Board Member, Journal of Taxation of Investments
  • Advisory Board Member, Journal of Financial Products
  • Co-Chair and Speaker, Practicing Law Institute (PLI), "Tax Strategies for Corporate Acquisitions, Dispositions, Spin-Offs, Joint Ventures, Financings, Reorganizations and Restructurings" Seminar
  • Co-Chair and Speaker, PLI, "Basics of International Tax" Seminar
  • Editorial Board, The Practical Tax Lawyer, The American Law Institute
  • Member, Taxation and Financial Instruments Committee, New York Bar Association
  • Member, Taxation and Financial Transactions Committee, American Bar Association
  • Member, The Tax Coalition

Bar Admissions

  • District of Columbia
  • New York

Court Admissions

  • United States Tax Court
  • United States District Court for the District of Columbia
  • United States Court of Appeals for the District of Columbia Circuit

Education

  • LL.M., Georgetown University Law Center, 1984
  • J.D., The Catholic University of America, 1980
  • B.A., The University of Texas at Austin, 1970