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Basics of International Taxation 2014

Author(s): Kristeen R. Witt, John L. Harrington, Linda E. Carlisle
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 practices international and domestic tax law, concentrating on the taxation of corporations, corporate reorganizations and flow-through entities, such as partnerships, limited liability companies and Subchapter S corporations. She also focuses on Public-Private Partnerships (or PPPs) and infrastructure transactions, and is one of the foremost practitioners in this area. 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 a leading authority on compliance issues related to the U.S. Foreign Account Tax Compliance Act (FATCA) and has extensive experience helping sovereigns negotiate intergovernmental agreements (IGAs) with respect to FATCA.

Ms. Carlisle advises on acquisitions and divestments of U.S. companies and businesses and in the establishment of finance structures and holding companies. She assists clients in structuring hybrid financial instruments and in devising and defending transfer pricing. Clients quoted by Chambers have said that Ms. Carlisle has "an approach that facilitates getting the job done."

She has testified before the U.S. Congress, obtained advance tax rulings approving proposed transactions, achieved favorable administrative and judicial resolutions of tax adjustments proposed by the Internal Revenue Service (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 Tax Partner in the Washington, D.C. office of White & Case and Cadwalader, Wickersham & Taft. She was in government service with the U.S. Department of the Treasury as an Attorney-Advisor in the Office of the Tax Legislative Counsel, and as the Special Assistant to the Assistant Secretary for Tax Policy. 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 is a frequent and sought after speaker on domestic and international tax issues.