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

Advanced international tax course covering CFC planning, GILTI changes under OB3, outbound individual planning, and cross-border M&A strategies.

2025-07-17 08:45:00

12 hours

Program Details

2025-07-17 08:45:00

Program Details

2025-07-17 08:45:00

Over 1,000+ webinars

2025-07-17 08:45:00

12 hours

Course Overview

Mastering International Tax Planning Strategies

2025-07-17 08:45:00

Participants will learn advanced CFC planning techniques, GILTI modifications under OB3, and cross-border M&A structuring. These skills enable practitioners to optimize multinational tax positions while ensuring compliance.

Format

CLE Credit

12h CLE Credits

Level

Intermediate

Length

12

Key topics that will be covered

01
CFC Planning
Downward attribution rules restored under OB3 with new targeted Section 951(b) provisions.
02
GILTI Changes
OB3 eliminates QBAI and reduces GILTI deduction from 50% to 40%.
03
Section 962
Election allows individuals corporate treatment for GILTI deductions and indirect foreign tax credits.
04
338(g) Elections
Stock purchases treated as asset purchases providing basis step-up inside foreign targets.
05
Pillar Two
G7 agreement exempts U.S.-parented companies from IIR and UTPR rules.
06
Buyback Tax
1% tax applies when U.S. persons facilitate foreign parent stock repurchases.

Program schedule

clock 8:25 am - 11:30 am EST

Controlled Foreign Corporation Planning and GILTI Rules

This comprehensive session examines CFC planning opportunities under Subpart F, including the look-through rule, high-tax exceptions, and earnings and profits limitations. It covers GILTI rules, the impact of the One Big Beautiful Bill Act changes including QBAI elimination, and the restoration of Section 958(b)(4) limiting downward attribution.

Joseph M. Calianno..Joseph M. Calianno..
Enrica MaEnrica Ma
Brandon C. SvetcovBrandon C. Svetcov
Sean Dokko..Sean Dokko..
Thomas M. Giordano-Lascari..Thomas M. Giordano-Lascari..
Michael J.A KarlinMichael J.A Karlin
William S. DixonWilliam S. Dixon
Sam K. KaywoodSam K. Kaywood
William B. Sherman..William B. Sherman..
Adam BairAdam Bair
J.P. GregorcyJ.P. Gregorcy
Alan I. AppelAlan I. Appel
Heather RipleyHeather Ripley
Sean J. TevelSean J. Tevel
Jason SchwartzJason Schwartz
Matthew StevensMatthew Stevens
Megan L. BrackneyMegan L. Brackney
Victor A. JaramilloVictor A. Jaramillo
Lawrence A. SannicandroLawrence A. Sannicandro
Melissa L. WileyMelissa L. Wiley
clock 11:45 am - 1:00 pm EST

Outbound Planning and Entity Choice for Individuals

This session addresses the challenges individuals face owning foreign corporations after the Tax Cuts and Jobs Act, including the lack of qualified dividend treatment and indirect foreign tax credits. Participants will explore mitigation strategies including the Section 962 election and interposing U.S. holding companies.

Joseph M. Calianno..Joseph M. Calianno..
Enrica MaEnrica Ma
Brandon C. SvetcovBrandon C. Svetcov
Sean Dokko..Sean Dokko..
Thomas M. Giordano-Lascari..Thomas M. Giordano-Lascari..
Michael J.A KarlinMichael J.A Karlin
William S. DixonWilliam S. Dixon
Sam K. KaywoodSam K. Kaywood
William B. Sherman..William B. Sherman..
Adam BairAdam Bair
J.P. GregorcyJ.P. Gregorcy
Alan I. AppelAlan I. Appel
Heather RipleyHeather Ripley
Sean J. TevelSean J. Tevel
Jason SchwartzJason Schwartz
Matthew StevensMatthew Stevens
Megan L. BrackneyMegan L. Brackney
Victor A. JaramilloVictor A. Jaramillo
Lawrence A. SannicandroLawrence A. Sannicandro
Melissa L. WileyMelissa L. Wiley
clock 2:15 pm - 4:30 pm EST

International M&A: Tax Considerations and Planning Techniques

This session covers U.S. tax considerations for stock acquisitions of foreign companies, Section 338(g) elections, and CFC issues in deal structures. Topics include the stock buyback tax, qualified stock purchase attribution issues, and OB3 changes affecting interest expense limitations and pro rata share rules.

Joseph M. Calianno..Joseph M. Calianno..
Enrica MaEnrica Ma
Brandon C. SvetcovBrandon C. Svetcov
Sean Dokko..Sean Dokko..
Thomas M. Giordano-Lascari..Thomas M. Giordano-Lascari..
Michael J.A KarlinMichael J.A Karlin
William S. DixonWilliam S. Dixon
Sam K. KaywoodSam K. Kaywood
William B. Sherman..William B. Sherman..
Adam BairAdam Bair
J.P. GregorcyJ.P. Gregorcy
Alan I. AppelAlan I. Appel
Heather RipleyHeather Ripley
Sean J. TevelSean J. Tevel
Jason SchwartzJason Schwartz
Matthew StevensMatthew Stevens
Megan L. BrackneyMegan L. Brackney
Victor A. JaramilloVictor A. Jaramillo
Lawrence A. SannicandroLawrence A. Sannicandro
Melissa L. WileyMelissa L. Wiley
clock 8:45 am - 10:15 am EST

Advanced Foreign Tax Credit Rules and Regulations

This session dives into final foreign tax credit regulations, exploring creditability determinations and allocation rules across different baskets. Participants will examine the attribution and cost recovery requirements, treaty coordination rules, and rules for disregarded distributions and dispositions.

Joseph M. Calianno..Joseph M. Calianno..
Enrica MaEnrica Ma
Brandon C. SvetcovBrandon C. Svetcov
Sean Dokko..Sean Dokko..
Thomas M. Giordano-Lascari..Thomas M. Giordano-Lascari..
Michael J.A KarlinMichael J.A Karlin
William S. DixonWilliam S. Dixon
Sam K. KaywoodSam K. Kaywood
William B. Sherman..William B. Sherman..
Adam BairAdam Bair
J.P. GregorcyJ.P. Gregorcy
Alan I. AppelAlan I. Appel
Heather RipleyHeather Ripley
Sean J. TevelSean J. Tevel
Jason SchwartzJason Schwartz
Matthew StevensMatthew Stevens
Megan L. BrackneyMegan L. Brackney
Victor A. JaramilloVictor A. Jaramillo
Lawrence A. SannicandroLawrence A. Sannicandro
Melissa L. WileyMelissa L. Wiley
clock 10:30 am - 12:15 pm EST

FIRPTA Rules for Foreign Investment in Real Estate

This session addresses the definition of U.S. real property interests and tax rules for foreign persons disposing of such interests. Coverage includes REIT investment rules, exceptions for publicly traded companies and domestically controlled REITs, and exemptions for pension and sovereign investors.

Joseph M. Calianno..Joseph M. Calianno..
Enrica MaEnrica Ma
Brandon C. SvetcovBrandon C. Svetcov
Sean Dokko..Sean Dokko..
Thomas M. Giordano-Lascari..Thomas M. Giordano-Lascari..
Michael J.A KarlinMichael J.A Karlin
William S. DixonWilliam S. Dixon
Sam K. KaywoodSam K. Kaywood
William B. Sherman..William B. Sherman..
Adam BairAdam Bair
J.P. GregorcyJ.P. Gregorcy
Alan I. AppelAlan I. Appel
Heather RipleyHeather Ripley
Sean J. TevelSean J. Tevel
Jason SchwartzJason Schwartz
Matthew StevensMatthew Stevens
Megan L. BrackneyMegan L. Brackney
Victor A. JaramilloVictor A. Jaramillo
Lawrence A. SannicandroLawrence A. Sannicandro
Melissa L. WileyMelissa L. Wiley
clock 1:30 pm - 3:00 pm EST

Inbound Debt Investing by Foreign Persons

This session examines issues relating to foreign person investments in U.S. debt instruments, including U.S. trade or business status determinations. Topics include safe harbors for trading activities, season and sell techniques, and income tax treaty planning including bring your own treaty funds.

Joseph M. Calianno..Joseph M. Calianno..
Enrica MaEnrica Ma
Brandon C. SvetcovBrandon C. Svetcov
Sean Dokko..Sean Dokko..
Thomas M. Giordano-Lascari..Thomas M. Giordano-Lascari..
Michael J.A KarlinMichael J.A Karlin
William S. DixonWilliam S. Dixon
Sam K. KaywoodSam K. Kaywood
William B. Sherman..William B. Sherman..
Adam BairAdam Bair
J.P. GregorcyJ.P. Gregorcy
Alan I. AppelAlan I. Appel
Heather RipleyHeather Ripley
Sean J. TevelSean J. Tevel
Jason SchwartzJason Schwartz
Matthew StevensMatthew Stevens
Megan L. BrackneyMegan L. Brackney
Victor A. JaramilloVictor A. Jaramillo
Lawrence A. SannicandroLawrence A. Sannicandro
Melissa L. WileyMelissa L. Wiley
clock 3:15 pm - 4:30 pm EST

Current International Information Return Penalty Issues

This session discusses the complex filing requirements for international information returns and the severe penalties imposed for noncompliance. Recent court cases challenging these penalties on technical and reasonable cause grounds are analyzed along with their implications for practitioners.

Joseph M. Calianno..Joseph M. Calianno..
Enrica MaEnrica Ma
Brandon C. SvetcovBrandon C. Svetcov
Sean Dokko..Sean Dokko..
Thomas M. Giordano-Lascari..Thomas M. Giordano-Lascari..
Michael J.A KarlinMichael J.A Karlin
William S. DixonWilliam S. Dixon
Sam K. KaywoodSam K. Kaywood
William B. Sherman..William B. Sherman..
Adam BairAdam Bair
J.P. GregorcyJ.P. Gregorcy
Alan I. AppelAlan I. Appel
Heather RipleyHeather Ripley
Sean J. TevelSean J. Tevel
Jason SchwartzJason Schwartz
Matthew StevensMatthew Stevens
Megan L. BrackneyMegan L. Brackney
Victor A. JaramilloVictor A. Jaramillo
Lawrence A. SannicandroLawrence A. Sannicandro
Melissa L. WileyMelissa L. Wiley
Joseph M. Calianno..

Joseph M. Calianno..

Andersen Tax LLC

Enrica Ma

Enrica Ma

EY

Brandon C. Svetcov

Brandon C. Svetcov

EY

Sean Dokko..

Sean Dokko..

Andersen Tax

Thomas M. Giordano-Lascari..

Thomas M. Giordano-Lascari..

Greenberg Glusker Fields Claman & Machtinger LLP

Michael J.A Karlin

Michael J.A Karlin

Karlin & Peebles, LLPKarlin & Peebles, LLP

William S. Dixon

William S. Dixon

Citigroup Global Markets

Sam K. Kaywood

Sam K. Kaywood

Alston & Bird LLP

William B. Sherman..

William B. Sherman..

Holland & Knight LLP

Adam Bair

Adam Bair

PwC

J.P. Gregorcy

J.P. Gregorcy

PwC

Alan I. Appel

Alan I. Appel

New York Law School

Heather Ripley

Heather Ripley

Alston & Bird

Sean J. Tevel

Sean J. Tevel

Holland & Knight LLP

Jason Schwartz

Jason Schwartz

Cahill Gordon & Reindel

Matthew Stevens

Matthew Stevens

EY

Megan L. Brackney

Megan L. Brackney

Kostelanetz LLP

Victor A. Jaramillo

Victor A. Jaramillo

Caplin & Drysdale

Lawrence A. Sannicandro

Lawrence A. Sannicandro

Pillsbury Winthrop Shaw Pittman

Melissa L. Wiley

Melissa L. Wiley

Kostelanetz

Joseph M. Calianno..

Joseph M. Calianno..

Andersen Tax LLC

Enrica Ma

Enrica Ma

EY

Enrica Ma is a Principal in the National Tax practice at Ernst & Young LLP in Washington, D.C. She advises multinational corporations on complex U.S. and international tax matters, with a practice focused on cross-border acquisitions and divestitures, internal restructurings, intellectual property planning, supply chain planning, and tax-efficient repatriation strategies. Enrica regularly counsels clients on the international tax provisions enacted under the Tax Cuts and Jobs Act of 2017, including foreign tax credits, expense apportionment, BEAT, FDII, and GILTI planning. She also has significant experience advising pharmaceutical, medical device, and life sciences companies on corporate and international tax issues, including licensing and collaboration transactions.

Education & Credentials

Enrica is a tax professional whose practice focuses on U.S. and international corporate taxation, particularly for multinational enterprises. Prior to joining Ernst & Young LLP in January 2022, she served as an international tax partner at a law firm and previously worked as in-house tax counsel for a Fortune 100 company. (The information provided does not include details regarding her educational background or professional licenses.)

Recognition & Leadership

As a Principal in the National Tax practice at Ernst & Young LLP, Enrica serves in a leadership role advising multinational corporations on sophisticated international tax planning and transactional matters. Before joining EY, she served as the engagement partner for multiple clients, including several Fortune 500 companies, reflecting her extensive experience leading complex tax engagements for global organizations.

Professional Involvement

Enrica works closely with multinational corporations on a broad range of international tax planning and transactional matters. Her practice includes advising clients on evolving international tax rules, cross-border business structures, and strategic tax planning for global operations. She has developed particular experience serving clients in the pharmaceutical, medical device, and life sciences industries, where she advises on corporate tax matters as well as licensing and collaboration transactions.

Experience

Enrica has extensive experience advising multinational corporations on cross-border acquisitions, divestitures, internal restructurings, intellectual property planning, supply chain planning, and tax-efficient repatriation strategies. She regularly counsels clients on international tax issues arising under the Tax Cuts and Jobs Act of 2017, including foreign tax credits, expense apportionment, BEAT, FDII, GILTI planning, and transaction structures involving intellectual property onshoring. Prior to joining EY, she served as an international tax partner at a law firm, leading engagements for numerous Fortune 500 companies, and previously worked as in-house tax counsel for a Fortune 100 company, providing her with both private practice and in-house perspectives on complex international tax matters.
Brandon C. Svetcov

Brandon C. Svetcov

EY

Brandon C. Svetcov is an attorney with Ernst & Young LLP in New York, where he advises clients on complex tax and legal matters. His practice focuses on helping businesses navigate sophisticated legal and regulatory issues through strategic planning and practical solutions. As part of EY’s tax practice, Brandon works with clients on matters involving corporate and transactional tax issues, drawing on his legal background to provide integrated business and tax advice.

Education & Credentials

Brandon earned his Juris Doctor from Benjamin N. Cardozo School of Law and was admitted to practice law in New York in 2010 by the Appellate Division, Second Judicial Department. He is currently registered as an attorney in New York and practices with Ernst & Young LLP.

Recognition & Leadership

Brandon serves as an attorney within the tax practice at Ernst & Young LLP, advising clients on complex legal and tax matters. He has also participated in professional educational programs and industry webcasts, contributing his knowledge on evolving tax and legal developments. (The information provided does not identify any verified awards, honors, or formal leadership positions.)

Professional Involvement

Brandon is actively engaged in professional education through his participation in industry webcasts and events focused on legal and tax developments. His work reflects an ongoing commitment to helping clients understand changing regulatory and tax issues while supporting practical business solutions. (The information provided does not identify memberships in professional organizations or publications.)

Experience

Brandon has practiced law in New York since 2010 and is currently an attorney with Ernst & Young LLP. His experience includes advising clients on legal and tax matters within EY's professional services practice, where he assists businesses in addressing complex corporate, transactional, and regulatory issues through strategic legal and tax planning.
Sean Dokko..

Sean Dokko..

Andersen Tax

Thomas M. Giordano-Lascari..

Thomas M. Giordano-Lascari..

Greenberg Glusker Fields Claman & Machtinger LLP

Michael J.A Karlin

Michael J.A Karlin

Karlin & Peebles, LLPKarlin & Peebles, LLP

William S. Dixon

William S. Dixon

Citigroup Global Markets

Will Dixon is a Managing Director at Citigroup Global Markets Inc., where he advises clients on complex tax-advantaged domestic and cross-border mergers and acquisitions, capital structure solutions, and financings. His practice encompasses public and private company transactions, including mergers, acquisitions, spin-offs, divestitures, buyouts, and SPAC transactions. In addition to his transactional practice, Will serves on the firm’s Fairness Opinion Committee and is widely recognized for his extensive knowledge of U.S. federal income taxation, combining experience in investment banking, legal practice, and academia.

Education & Credentials

Will earned his Juris Doctor, magna cum laude, from Boston University School of Law. Before transitioning to investment banking, he practiced as a Senior Attorney at Cravath, Swaine & Moore LLP in New York City, where he developed significant experience in sophisticated tax matters that continues to inform his work advising clients on complex transactions.

Recognition & Leadership

Will serves as a member of the Fairness Opinion Committee at Citigroup Global Markets Inc. and has held numerous leadership positions within the tax profession. He has served on the Board of Directors of the International Tax Institute and on the New York Steering Committee of the International Fiscal Association. He is a former Chair of the U.S. Activities of Foreigners and Tax Treaties Committee of the American Bar Association Section of Taxation, previously served on the ABA's Task Force on International Tax Reform, and is a former John S. Nolan Fellow.

Professional Involvement

Will has made significant contributions to tax education and the legal profession through his teaching and speaking activities. He has served as an adjunct assistant professor at Brooklyn Law School, teaching courses on the taxation of securities, derivatives, and partnerships, and has also taught as an adjunct at the Peter J. Tobin College of Business at St. John's University. In addition, he has delivered guest lectures at numerous institutions, including Harvard Law School and New York University Leonard N. Stern School of Business. He is also a frequent speaker at conferences and professional forums on U.S. federal income tax matters.

Experience

Will advises public and private companies on a broad range of sophisticated domestic and cross-border transactions, including mergers and acquisitions, spin-offs, divestitures, buyouts, SPAC transactions, capital structure solutions, and financings. His practice emphasizes tax-efficient transaction structuring and strategic planning for complex corporate transactions. Before joining Citigroup Global Markets Inc., he practiced as a Senior Attorney at Cravath, Swaine & Moore LLP, where he focused on complex tax matters. His combined experience in private legal practice, investment banking, and academia provides him with a multidisciplinary perspective on transactional tax planning and corporate finance.
Sam K. Kaywood

Sam K. Kaywood

Alston & Bird LLP

Sam Kaywood is Senior Counsel in Alston & Bird’s Federal & International Tax Group and a co-chair of the firm’s International Team. Over a career spanning more than 30 years, he concentrated his practice on federal income tax and international tax, including cross-border M&A and joint ventures and inbound investment into the United States, offering an innovative approach to complicated federal and international tax issues wherever his clients’ global business objectives took them. He worked on virtually all forms of cross-border investment, with substantial experience in Canada, Europe, China, and Latin America, and was particularly active structuring investments and acquisitions in Latin America, including Brazil, Mexico, Argentina, and Chile.

Education & Credentials

Mr. Kaywood received his J.D. from Emory University in 1986 and his B.S. from Babson College in 1979. He is admitted to the Georgia Bar.

Recognition & Leadership

Mr. Kaywood has been listed in Chambers USA: America's Leading Lawyers for Business since 2006 and in Chambers Global since 2011, and is recognized in The Best Lawyers in America for Tax, which named him “Lawyer of the Year” in Tax Law for 2021. He served as chair of the ABA Tax Section Committee on U.S. Activities of Foreigners & Tax Treaties.

Professional Involvement

Mr. Kaywood is a member of the International Bar Association, the ABA Tax Section, and the International Fiscal Association, where he has been active, and serves on the advisory board of the CCH International Tax Journal. He is an adjunct professor at Emory University School of Law, where he teaches International Tax, and is a frequent author and speaker on international tax topics, having addressed organizations such as the International Bar Association, the International Fiscal Association, the ABA Tax Section, the Tax Executives Institute, and the Atlanta Tax Forum Georgia Federal Tax Conference in cities across the country and abroad.

Experience

Mr. Kaywood's representative work includes structuring the $500 million sale of a multinational food and beverage company's operations in Ireland, Spain, and the Netherlands and defending the related IRS audit; representing a U.S. manufacturer in acquisitions and restructurings over 13 years, including a $2.5 billion acquisition of European operations; representing a worldwide financier in investments across 25 countries; handling international restructurings responding to the Tax Cuts and Jobs Act of 2017, including hybrid entities and instruments, OECD BEPS, and ATAD II; handling numerous IRS audits at the Exam and Appeals levels over more than 32 years; working on international technology-related arrangements, including offshore licensing and R&D structures; and defending a $58 million foreign tax credit position before the IRS.
William B. Sherman..

William B. Sherman..

Holland & Knight LLP

Adam Bair

Adam Bair

PwC

Adam Bair is a Principal in PwC’s National Tax Services practice, where he advises high-net-worth individuals, family offices, and closely held businesses on sophisticated tax planning strategies. With deep expertise in partnership taxation, estate and gift tax, and income-shifting techniques, Adam works closely with clients and advisors to structure tax-efficient solutions aligned with wealth preservation and succession goals. He is a licensed attorney with extensive experience navigating the intersection of legal strategy and federal tax law.

Education & Credentials

Adam earned his LL.M. in Taxation (2010–2011) and his J.D. in Business Law (2008–2011) from the University of Miami School of Law, where he served as President of the Effective Firm Management Society, participated in the Student Bar Association, the Asian Pacific American Law Student Association, the Entertainment and Sports Law Society, the Tax Law Society, Books and Buddies, and the Rathskeller Advisory Board, and received the Dean's Certificate of Academic Achievement in Constitutional Law (2008). He earned his B.A. in Journalism/Advertising from The University of North Carolina at Chapel Hill (2004–2008), where he made the Dean's List in five semesters and was a member of the Sigma Alpha Lambda National Leadership & Honors Organization, the Advertising Club, and the College Republicans. He is a Florida licensed attorney.

Recognition & Leadership

Adam served as President of the Effective Firm Management Society during law school and received the Dean's Certificate of Academic Achievement in Constitutional Law.

Professional Involvement

Adam frequently presents on topics related to advanced estate planning, entity structuring, and IRS compliance. Earlier in his career, he served as an Associate Editor of the Wealth Strategies Journal (August–November 2011).

Experience

Adam has spent nearly fifteen years at PwC, serving as Principal since July 2021 in New York. He previously served as Director, International Tax Services (July 2017 – June 2021, New York); Manager, International Tax Services (July 2015 – June 2017, Houston); Senior Associate, International Tax Services (July 2013 – June 2015, Houston); and Associate, International Tax Services (November 2011 – June 2013, Houston). His international tax consulting work focused on U.S. and non-U.S. headquartered multinational corporations in the energy industry, including structuring outbound U.S. investments, tax-efficient financing structures and repatriation strategies, foreign tax credit and other attribute utilization techniques, cross-border leasing structures, and post-acquisition U.S. integration, advising clients in manufacturing, oil and gas exploration and production, and oilfield services. Before PwC, he was a Manager of Business Development at Foreya Partners and at Accounting Asia (both May–December 2010), a Legal Intern at the Guilford County District Attorney's Office (2007), and an Intern at ComputerNet Resource Group (2006).
J.P. Gregorcy

J.P. Gregorcy

PwC

Alan I. Appel

Alan I. Appel

New York Law School

Alan I. Appel specializes in international and domestic tax planning involving the taxation of mergers and acquisitions, partnerships, joint ventures, and limited liability companies, as well as tax controversy matters. He is a Professor of Law at New York Law School and Director of its International Tax Program.

Education & Credentials

Professor Appel earned his LL.M. from New York University (1980), his J.D. from New York Law School (1976), and his B.B.A. from Baruch College (1973).

Recognition & Leadership

Professor Appel is a Fellow of the American College of Tax Counsel and serves on the Board of Advisors for the Journal of International Taxation. He has appeared on radio and television to discuss income tax issues and was featured in AccountingToday.com's coverage of FATCA's requirements.

Professional Involvement

On behalf of the ABA Tax Section, Professor Appel had primary responsibility for drafting comments to the Treasury Department and IRS on proposed regulations under Section 1446 of the Internal Revenue Code, and the Office of Chief Counsel asked him to train its attorneys on the issue. He formerly served as Council Director of the ABA Tax Section's U.S. Activities of Foreigners and Tax Treaties Committee, Foreign Activities of U.S. Taxpayers Committee, Transfer Pricing Committee, and Foreign Lawyers Forum, and chaired the U.S. Activities of Foreigners and Tax Treaties Committee. He has published extensively, including in Tax Notes, The Journal of Taxation, Tax Management Memorandum, the Tax Management International Journal, The Journal of International Taxation, and the New York Law Journal, and has contributed multiple chapters to the New York University Institute on Federal Taxation.

Experience

Professor Appel began his career as a trial attorney in the IRS Office of Chief Counsel in Washington, D.C. and New York City, and later spent 13 years as Counsel at Bryan Cave Leighton Paisner LLP (formerly Bryan Cave LLP). He began teaching at New York Law School as an adjunct professor in 2009 and joined the faculty full-time in 2013, where he teaches Commercial Law, Federal Income Tax (Individual and Corporate), International Taxation, and an International Tax Planning Seminar.
Heather Ripley

Heather Ripley

Alston & Bird

Heather Ripley is a partner in Alston & Bird’s Federal & International Tax Group and a member of the firm’s REITs and Real Estate Funds tax team. She helps U.S. and foreign business entities and high-net-worth individuals navigate U.S. federal and international tax law, counseling on tax-efficient structuring of U.S. and cross-border investments and activities, U.S. tax and compliance obligations and risks, and the correction of noncompliance. Her advisory work covers income tax treaty application, FATCA, FIRPTA, and other inbound investment issues, the CFC and PFIC anti-deferral regimes for outbound investments, tax aspects of M&A transactions, and tax information reporting regimes.

Education & Credentials

Ms. Ripley received her J.D. from Harvard University in 2009 and her Master of Accountancy and B.B.A. from the University of Georgia in 2006. She is admitted to the New York Bar.

Recognition & Leadership

Ms. Ripley has been recognized by The Best Lawyers in America in Tax Law and as a New York Law Journal Rising Star. She chairs the ABA Tax Section's Committee on Foreign and U.S. Taxation – Individuals and Passthroughs and serves as International Organizations liaison officer for the International Bar Association's Taxes Committee.

Professional Involvement

Ms. Ripley is a member of the New York State Bar Association's Tax Section and Under 10 Club, the Harvard Club of New York, and the University of Georgia Terry College of Business Alumni, and serves on the board of Volunteers of Legal Service (VOLS). She is a frequent speaker at tax conferences and writes regularly on international tax developments, and has provided volunteer income tax assistance for low-income individuals.

Experience

Ms. Ripley has significant federal tax controversy experience, having guided numerous clients through IRS voluntary disclosure procedures, letter rulings, and competent authority requests, and has counseled charitable and nonprofit organizations on incorporation, tax exemption applications and restrictions, and related tax issues. Her representative matters include serving as U.S. tax counsel to one of the largest foreign multinational financial services groups, representing significant European multinationals on their U.S. structures, restructurings, and operations, and advising European funds and their advisors on optimal tax structures, subscription agreements, and tax certifications.
Sean J. Tevel

Sean J. Tevel

Holland & Knight LLP

Sean Tevel is a private wealth services and international tax attorney in Holland & Knight’s Miami office. He advises foreign and domestic clients on U.S. federal income, gift, and estate tax matters associated with their cross-border investments and businesses. His international tax practice includes advising on multinational trust and business structures, including the controlled foreign corporation rules, the Passive Foreign Investment Company (PFIC) rules, and international tax treaties.

Education & Credentials

Mr. Tevel received his LL.M. in Taxation and his J.D., cum laude, from the University of Miami School of Law, and his B.A. in Economics and Political Science from McGill University. He is admitted to The Florida Bar and speaks French.

Recognition & Leadership

Mr. Tevel is recognized in the Chambers USA guide for Tax (2022–2026) and the Chambers High Net Worth guide for Private Wealth Law: Florida (2024–2025), where industry sources have praised his ability to solve complex cross-border tax matters. He was named among The Best Lawyers in America Miami Tax Law “Ones to Watch” (2021–2024) and a Florida Super Lawyers Rising Star (2020).

Professional Involvement

Mr. Tevel is a member of the Society of Trust and Estate Practitioners (STEP) and of The Florida Bar's Tax Section and International Law Section.

Experience

Mr. Tevel has significant experience structuring U.S. real estate investments, including the application of the Foreign Investment in Real Property Tax Act of 1980 (FIRPTA). He frequently represents domestic and foreign funds on fund formation and structuring considerations for non-U.S. investors, regularly advises on domestic and cross-border joint venture transactions, and has assisted many clients in establishing Qualified Opportunity Funds and maximizing the tax benefits of Opportunity Zone investments. Before joining Holland & Knight, he was a tax attorney in the Miami office of an international law firm.
Jason Schwartz

Jason Schwartz

Cahill Gordon & Reindel

Jason Schwartz is a tax partner in CahillNXT, Cahill’s premier practice for Digital Assets and Emerging Technology, based in Washington, D.C. He specializes in tax issues relating to digital assets, financial products, securitizations, funds, treaties, and lending.

Education & Credentials

Mr. Schwartz received his LL.M. from New York University School of Law, his J.D., magna cum laude and Order of the Coif, from American University Washington College of Law, and his B.A., cum laude, from New York University. He is admitted to practice in New York and the District of Columbia.

Recognition & Leadership

Mr. Schwartz is ranked by Chambers USA, Legal 500 US, and Best Lawyers, and Chambers USA sources have singled him out as a resource for sophisticated tax planning relating to cryptocurrency. He oversees Cahill's 501Foundry, a pro bono program that incorporates, advises, and obtains tax exemption for charitable and other nonprofit organizations; under his ten-plus years of oversight, the program has helped hundreds of charitable organizations obtain tax-exempt status.

Professional Involvement

Mr. Schwartz is frequently asked to speak on panels and podcasts across a wide range of tax topics and is committed to pro bono work and community service.

Experience

Mr. Schwartz has authored numerous tax articles, a Bloomberg BNA Tax Management Portfolio on the taxation of CLOs, and a Practising Law Institute chapter on the taxation of digital assets. Before joining Cahill, he was a partner at a large international law firm.
Matthew Stevens

Matthew Stevens

EY

Matthew Stevens is a Principal in EY’s International Tax and Transaction Services practice in Washington, D.C. He advises multinational corporations, financial institutions, and investment clients on complex U.S. and cross-border tax matters, with a particular focus on international taxation, financial products, capital markets transactions, and tax controversy. Throughout his career, he has built a distinguished reputation for his work in international tax, financial products, and tax policy, combining experience in private practice, government service, academia, and the financial services industry.

Education & Credentials

Matthew Stevens earned his J.D. from Harvard Law School and his B.A. from the University of Kansas.

Recognition & Leadership

Matthew is widely recognized for his leadership in the tax profession. He serves as Chair of the annual Practising Law Institute program Taxation of Financial Products and Transactions and previously chaired the Financial Transactions Committee of both the American Bar Association Section of Taxation and the District of Columbia Bar Tax Section. He has also been recognized by Chambers USA: America's Leading Lawyers for Business for his work in tax law.

Professional Involvement

Matthew has co-taught United States Taxation of International Income II at Georgetown University Law Center and has authored numerous publications on international tax and the taxation of financial products. His professional involvement reflects his commitment to legal education and advancing thought leadership in the field of taxation.

Experience

Before joining EY, Matthew served as Special Counsel to the Chief Counsel of the Internal Revenue Service, where he advised on published guidance involving financial products and cross-border transactions. He has also held senior positions in private practice and the financial services industry, bringing extensive experience to his work advising clients on complex domestic and international tax matters.
Megan L. Brackney

Megan L. Brackney

Kostelanetz LLP

Victor A. Jaramillo

Victor A. Jaramillo

Caplin & Drysdale

Lawrence A. Sannicandro

Lawrence A. Sannicandro

Pillsbury Winthrop Shaw Pittman

Lawrence “Larry” Sannicandro is a partner in Pillsbury’s New York office. He focuses his practice on a broad range of federal and state tax disputes affecting individual private clients as well as their estates, trusts, and businesses, both public and private. These disputes span the full range of civil and criminal tax matters, including audits and examinations, administrative appeals, collection matters, summons proceedings, grand jury subpoenas, criminal tax investigations and prosecutions, and litigation before the U.S. Tax Court, the U.S. Court of Federal Claims, federal district and appellate courts, and state tax tribunals.

Education & Credentials

Mr. Sannicandro received his LL.M. in Taxation from Georgetown University Law Center in 2010, his J.D. from the University of Florida College of Law in 2006, and his M.B.A. in Finance (2003) and B.A. in Political Science (2001) from Binghamton University. He is admitted in New Jersey, New York, and the District of Columbia, and before the U.S. Supreme Court, the U.S. Courts of Appeals for the Second, Third, Fourth, Eleventh, and D.C. Circuits, the U.S. Court of Federal Claims, the U.S. Tax Court, and several federal district courts. He clerked for the Hon. David Laro of the U.S. Tax Court from 2010 to 2012.

Recognition & Leadership

Mr. Sannicandro received the ABA Section of Taxation's Janet Spragens Pro Bono Award (2020), the section's highest honor for pro bono service, and its John S. Nolan Fellowship (2016). He has been recognized by Lawdragon among its 500 Leading Global Tax Lawyers (2025), by Chambers for tax law (2023–2025), and by Super Lawyers (2021); was selected Bloomberg Tax Portfolio Author of the Year (2023); served on Law360's 2023 Tax Authority Federal Editorial Advisory Board; was named a 2022 ROI-NJ Influencer in Law and a 2018 New Jersey Law Journal Leader of the Bar; and received the New York County Lawyers' Association Pro Bono Award (2015). He chairs the ABA Tax Section's Court Procedure Practice Committee.

Professional Involvement

Mr. Sannicandro is a member of the IRS Advisory Council, a Fellow of the American College of Tax Counsel, and a member of the Supreme Court of New Jersey District VA Ethics Committee. He previously taught corporate and partnership tax, tax practice and procedure, and legal ethics at several universities, and speaks extensively before organizations including the Practising Law Institute, the ABA Section of Taxation, the Federal Bar Association, the D.C. Bar, and the NYU Tax Controversy Forum, including a presentation on current penalty issues at the NYU Summer 2025 Institute in International Taxation.

Experience

A former estate and gift tax attorney for the IRS, Mr. Sannicandro is uniquely well-versed in estate and gift tax planning techniques, the valuation of closely held businesses, and defending those techniques in disputes with tax authorities. He has favorably resolved hundreds of tax disputes involving income taxes, estate and gift taxes, employment and payroll taxes, excise taxes, sales and use taxes, federal and state tax credits, and employee plan matters, and advises clients on uncertain tax positions and the identification, quantification, and procedural management of tax-based risks. Representative matters include persuading the U.S. Tax Court that a closing agreement precluded proposed assessments relating to allegedly unreported foreign assets; obtaining full IRS concessions for taxpayers claiming Puerto Rico Act 22 benefits; securing invalidation-driven concessions on a disaster loss carryback regulation; resolving a global high wealth audit of a private equity and family office founder; and securing a non-custodial sentence in a criminal matter involving cryptocurrency-related income while persuading the government to reduce the alleged tax loss by approximately 90 percent. He is the author of Bloomberg BNA portfolios on IRS National Office procedures and innocent spouse relief and a chapter of the ABA's Effectively Representing Your Client Before the IRS, along with numerous articles.
Melissa L. Wiley

Melissa L. Wiley

Kostelanetz

Melissa Wiley is a Partner at Kostelanetz LLP with more than 20 years of experience in tax law, having represented a diverse range of clients—from large corporations to high-net-worth individuals—in complex disputes with federal and state taxing authorities. Known for her calm, empathetic style, she excels at distilling intricate tax issues into clear, actionable insights, helping clients efficiently resolve disputes and focus on what matters most in their businesses and lives. Melissa serves as a trusted advisor to clients at all levels of administrative tax controversy, including audits, cases before the IRS Office of Appeals, and investigations by the IRS Office of Professional Responsibility, and she has significant experience handling penalty and international information reporting matters. When an administrative resolution cannot be reached, she is well-equipped to litigate, and she also represents clients facing government and third-party subpoenas and investigations while frequently advising on voluntary disclosures of prior tax noncompliance. An actuary by training, Melissa pairs a scrupulous, detail-oriented approach with a thorough understanding of how tax affects her clients’ financial affairs, and her background in statistics and the insurance industry has fostered a natural ability to collaborate effectively with technical and forensic experts.

Education & Credentials

Melissa received her J.D., cum laude, from the Georgetown University Law Center in 2003, and earned her B.S. in Actuarial Science, summa cum laude and as valedictorian, from The College of Insurance in 1998. She is admitted to practice in the District of Columbia, New York, and Virginia, as well as before the U.S. Tax Court, the Court of Federal Claims, the U.S. Court of Appeals for the Eleventh Circuit, and the U.S. District Court for the District of Columbia.

Recognition & Leadership

Melissa is a Fellow of the American College of Tax Counsel (since May 2019) and serves as its Regent for the Federal Circuit (since March 2023). She is a member of the J. Edgar Murdock Inn of Court. Within the ABA Section of Taxation, she serves as Vice Chair for Membership, Diversity and Inclusion (since August 2024) and Chair of the Loretta Collins Argrett Fellowship Committee, and she was named a Nolan Fellow in 2011. She is recognized for her in-depth knowledge of tax controversy topics and frequently speaks on IRS filing requirements, enforcement priorities, penalties, ethics, and the Corporate Transparency Act.

Professional Involvement

Melissa is deeply engaged in the tax community across multiple organizations. Within the ABA Section of Taxation, in addition to her current leadership roles, she has served as Vice-Chair of the Appointments to the Tax Court Committee, Vice Chair of Committee Operations (2020–2022), a Council Member (2016–2019), and former Chair of both the Young Lawyer's Forum and the Law Student Tax Challenge. At the AICPA, she has been a member of the IRS Advocacy and Relations Committee since January 2019, currently serving as its Chair (since May 2024) after serving as Vice-Chair (2023–2024), and is a member of the National Tax Conference Committee. She chaired the DC Bar Association Tax Section's Tax Audits and Litigation Committee (2022–2024) after serving as its Vice-Chair (2020–2022). She also serves as an adjunct professor at her alma mater, Georgetown University Law Center, where she will teach an upcoming course on Tax Research and Writing. Her pro bono and community service includes board service with the Community Tax Law Project (since November 2022) and more than 15 years with the Children's Law Center, where she has served on the Board of Directors, as Treasurer, and on its Emeritus Board, offering pro bono assistance in custody and abuse/neglect cases.

Experience

Melissa represents corporate, institutional, and individual clients in tax controversy matters in litigation and before all levels of the IRS, including audits, cases before the IRS Office of Appeals, and investigations by the IRS Office of Professional Responsibility. She has significant experience handling penalty and international information reporting matters, and her litigation experience spans the U.S. Tax Court, the Court of Federal Claims, and various federal district courts. She also represents clients facing government and third-party subpoenas and investigations and counsels clients on voluntary disclosures of prior tax noncompliance. Her practice is informed by six years as an Assistant General Counsel at a Big Four accounting firm, which gave her a deep understanding of the regulations and professional standards governing tax practice, as well as her earlier background as an actuary in statistics and the insurance industry.
Joseph M. Calianno..

Joseph M. Calianno..

Andersen Tax LLC

Enrica Ma

Enrica Ma

EY

Enrica Ma is a Principal in the National Tax practice at Ernst & Young LLP in Washington, D.C. She advises multinational corporations on complex U.S. and international tax matters, with a practice focused on cross-border acquisitions and divestitures, internal restructurings, intellectual property planning, supply chain planning, and tax-efficient repatriation strategies. Enrica regularly counsels clients on the international tax provisions enacted under the Tax Cuts and Jobs Act of 2017, including foreign tax credits, expense apportionment, BEAT, FDII, and GILTI planning. She also has significant experience advising pharmaceutical, medical device, and life sciences companies on corporate and international tax issues, including licensing and collaboration transactions.

Education & Credentials

Enrica is a tax professional whose practice focuses on U.S. and international corporate taxation, particularly for multinational enterprises. Prior to joining Ernst & Young LLP in January 2022, she served as an international tax partner at a law firm and previously worked as in-house tax counsel for a Fortune 100 company. (The information provided does not include details regarding her educational background or professional licenses.)

Recognition & Leadership

As a Principal in the National Tax practice at Ernst & Young LLP, Enrica serves in a leadership role advising multinational corporations on sophisticated international tax planning and transactional matters. Before joining EY, she served as the engagement partner for multiple clients, including several Fortune 500 companies, reflecting her extensive experience leading complex tax engagements for global organizations.

Professional Involvement

Enrica works closely with multinational corporations on a broad range of international tax planning and transactional matters. Her practice includes advising clients on evolving international tax rules, cross-border business structures, and strategic tax planning for global operations. She has developed particular experience serving clients in the pharmaceutical, medical device, and life sciences industries, where she advises on corporate tax matters as well as licensing and collaboration transactions.

Experience

Enrica has extensive experience advising multinational corporations on cross-border acquisitions, divestitures, internal restructurings, intellectual property planning, supply chain planning, and tax-efficient repatriation strategies. She regularly counsels clients on international tax issues arising under the Tax Cuts and Jobs Act of 2017, including foreign tax credits, expense apportionment, BEAT, FDII, GILTI planning, and transaction structures involving intellectual property onshoring. Prior to joining EY, she served as an international tax partner at a law firm, leading engagements for numerous Fortune 500 companies, and previously worked as in-house tax counsel for a Fortune 100 company, providing her with both private practice and in-house perspectives on complex international tax matters.
Brandon C. Svetcov

Brandon C. Svetcov

EY

Brandon C. Svetcov is an attorney with Ernst & Young LLP in New York, where he advises clients on complex tax and legal matters. His practice focuses on helping businesses navigate sophisticated legal and regulatory issues through strategic planning and practical solutions. As part of EY’s tax practice, Brandon works with clients on matters involving corporate and transactional tax issues, drawing on his legal background to provide integrated business and tax advice.

Education & Credentials

Brandon earned his Juris Doctor from Benjamin N. Cardozo School of Law and was admitted to practice law in New York in 2010 by the Appellate Division, Second Judicial Department. He is currently registered as an attorney in New York and practices with Ernst & Young LLP.

Recognition & Leadership

Brandon serves as an attorney within the tax practice at Ernst & Young LLP, advising clients on complex legal and tax matters. He has also participated in professional educational programs and industry webcasts, contributing his knowledge on evolving tax and legal developments. (The information provided does not identify any verified awards, honors, or formal leadership positions.)

Professional Involvement

Brandon is actively engaged in professional education through his participation in industry webcasts and events focused on legal and tax developments. His work reflects an ongoing commitment to helping clients understand changing regulatory and tax issues while supporting practical business solutions. (The information provided does not identify memberships in professional organizations or publications.)

Experience

Brandon has practiced law in New York since 2010 and is currently an attorney with Ernst & Young LLP. His experience includes advising clients on legal and tax matters within EY's professional services practice, where he assists businesses in addressing complex corporate, transactional, and regulatory issues through strategic legal and tax planning.
Sean Dokko..

Sean Dokko..

Andersen Tax

Thomas M. Giordano-Lascari..

Thomas M. Giordano-Lascari..

Greenberg Glusker Fields Claman & Machtinger LLP

Michael J.A Karlin

Michael J.A Karlin

Karlin & Peebles, LLPKarlin & Peebles, LLP

William S. Dixon

William S. Dixon

Citigroup Global Markets

Will Dixon is a Managing Director at Citigroup Global Markets Inc., where he advises clients on complex tax-advantaged domestic and cross-border mergers and acquisitions, capital structure solutions, and financings. His practice encompasses public and private company transactions, including mergers, acquisitions, spin-offs, divestitures, buyouts, and SPAC transactions. In addition to his transactional practice, Will serves on the firm’s Fairness Opinion Committee and is widely recognized for his extensive knowledge of U.S. federal income taxation, combining experience in investment banking, legal practice, and academia.

Education & Credentials

Will earned his Juris Doctor, magna cum laude, from Boston University School of Law. Before transitioning to investment banking, he practiced as a Senior Attorney at Cravath, Swaine & Moore LLP in New York City, where he developed significant experience in sophisticated tax matters that continues to inform his work advising clients on complex transactions.

Recognition & Leadership

Will serves as a member of the Fairness Opinion Committee at Citigroup Global Markets Inc. and has held numerous leadership positions within the tax profession. He has served on the Board of Directors of the International Tax Institute and on the New York Steering Committee of the International Fiscal Association. He is a former Chair of the U.S. Activities of Foreigners and Tax Treaties Committee of the American Bar Association Section of Taxation, previously served on the ABA's Task Force on International Tax Reform, and is a former John S. Nolan Fellow.

Professional Involvement

Will has made significant contributions to tax education and the legal profession through his teaching and speaking activities. He has served as an adjunct assistant professor at Brooklyn Law School, teaching courses on the taxation of securities, derivatives, and partnerships, and has also taught as an adjunct at the Peter J. Tobin College of Business at St. John's University. In addition, he has delivered guest lectures at numerous institutions, including Harvard Law School and New York University Leonard N. Stern School of Business. He is also a frequent speaker at conferences and professional forums on U.S. federal income tax matters.

Experience

Will advises public and private companies on a broad range of sophisticated domestic and cross-border transactions, including mergers and acquisitions, spin-offs, divestitures, buyouts, SPAC transactions, capital structure solutions, and financings. His practice emphasizes tax-efficient transaction structuring and strategic planning for complex corporate transactions. Before joining Citigroup Global Markets Inc., he practiced as a Senior Attorney at Cravath, Swaine & Moore LLP, where he focused on complex tax matters. His combined experience in private legal practice, investment banking, and academia provides him with a multidisciplinary perspective on transactional tax planning and corporate finance.
Sam K. Kaywood

Sam K. Kaywood

Alston & Bird LLP

Sam Kaywood is Senior Counsel in Alston & Bird’s Federal & International Tax Group and a co-chair of the firm’s International Team. Over a career spanning more than 30 years, he concentrated his practice on federal income tax and international tax, including cross-border M&A and joint ventures and inbound investment into the United States, offering an innovative approach to complicated federal and international tax issues wherever his clients’ global business objectives took them. He worked on virtually all forms of cross-border investment, with substantial experience in Canada, Europe, China, and Latin America, and was particularly active structuring investments and acquisitions in Latin America, including Brazil, Mexico, Argentina, and Chile.

Education & Credentials

Mr. Kaywood received his J.D. from Emory University in 1986 and his B.S. from Babson College in 1979. He is admitted to the Georgia Bar.

Recognition & Leadership

Mr. Kaywood has been listed in Chambers USA: America's Leading Lawyers for Business since 2006 and in Chambers Global since 2011, and is recognized in The Best Lawyers in America for Tax, which named him “Lawyer of the Year” in Tax Law for 2021. He served as chair of the ABA Tax Section Committee on U.S. Activities of Foreigners & Tax Treaties.

Professional Involvement

Mr. Kaywood is a member of the International Bar Association, the ABA Tax Section, and the International Fiscal Association, where he has been active, and serves on the advisory board of the CCH International Tax Journal. He is an adjunct professor at Emory University School of Law, where he teaches International Tax, and is a frequent author and speaker on international tax topics, having addressed organizations such as the International Bar Association, the International Fiscal Association, the ABA Tax Section, the Tax Executives Institute, and the Atlanta Tax Forum Georgia Federal Tax Conference in cities across the country and abroad.

Experience

Mr. Kaywood's representative work includes structuring the $500 million sale of a multinational food and beverage company's operations in Ireland, Spain, and the Netherlands and defending the related IRS audit; representing a U.S. manufacturer in acquisitions and restructurings over 13 years, including a $2.5 billion acquisition of European operations; representing a worldwide financier in investments across 25 countries; handling international restructurings responding to the Tax Cuts and Jobs Act of 2017, including hybrid entities and instruments, OECD BEPS, and ATAD II; handling numerous IRS audits at the Exam and Appeals levels over more than 32 years; working on international technology-related arrangements, including offshore licensing and R&D structures; and defending a $58 million foreign tax credit position before the IRS.
William B. Sherman..

William B. Sherman..

Holland & Knight LLP

Adam Bair

Adam Bair

PwC

Adam Bair is a Principal in PwC’s National Tax Services practice, where he advises high-net-worth individuals, family offices, and closely held businesses on sophisticated tax planning strategies. With deep expertise in partnership taxation, estate and gift tax, and income-shifting techniques, Adam works closely with clients and advisors to structure tax-efficient solutions aligned with wealth preservation and succession goals. He is a licensed attorney with extensive experience navigating the intersection of legal strategy and federal tax law.

Education & Credentials

Adam earned his LL.M. in Taxation (2010–2011) and his J.D. in Business Law (2008–2011) from the University of Miami School of Law, where he served as President of the Effective Firm Management Society, participated in the Student Bar Association, the Asian Pacific American Law Student Association, the Entertainment and Sports Law Society, the Tax Law Society, Books and Buddies, and the Rathskeller Advisory Board, and received the Dean's Certificate of Academic Achievement in Constitutional Law (2008). He earned his B.A. in Journalism/Advertising from The University of North Carolina at Chapel Hill (2004–2008), where he made the Dean's List in five semesters and was a member of the Sigma Alpha Lambda National Leadership & Honors Organization, the Advertising Club, and the College Republicans. He is a Florida licensed attorney.

Recognition & Leadership

Adam served as President of the Effective Firm Management Society during law school and received the Dean's Certificate of Academic Achievement in Constitutional Law.

Professional Involvement

Adam frequently presents on topics related to advanced estate planning, entity structuring, and IRS compliance. Earlier in his career, he served as an Associate Editor of the Wealth Strategies Journal (August–November 2011).

Experience

Adam has spent nearly fifteen years at PwC, serving as Principal since July 2021 in New York. He previously served as Director, International Tax Services (July 2017 – June 2021, New York); Manager, International Tax Services (July 2015 – June 2017, Houston); Senior Associate, International Tax Services (July 2013 – June 2015, Houston); and Associate, International Tax Services (November 2011 – June 2013, Houston). His international tax consulting work focused on U.S. and non-U.S. headquartered multinational corporations in the energy industry, including structuring outbound U.S. investments, tax-efficient financing structures and repatriation strategies, foreign tax credit and other attribute utilization techniques, cross-border leasing structures, and post-acquisition U.S. integration, advising clients in manufacturing, oil and gas exploration and production, and oilfield services. Before PwC, he was a Manager of Business Development at Foreya Partners and at Accounting Asia (both May–December 2010), a Legal Intern at the Guilford County District Attorney's Office (2007), and an Intern at ComputerNet Resource Group (2006).
J.P. Gregorcy

J.P. Gregorcy

PwC

Alan I. Appel

Alan I. Appel

New York Law School

Alan I. Appel specializes in international and domestic tax planning involving the taxation of mergers and acquisitions, partnerships, joint ventures, and limited liability companies, as well as tax controversy matters. He is a Professor of Law at New York Law School and Director of its International Tax Program.

Education & Credentials

Professor Appel earned his LL.M. from New York University (1980), his J.D. from New York Law School (1976), and his B.B.A. from Baruch College (1973).

Recognition & Leadership

Professor Appel is a Fellow of the American College of Tax Counsel and serves on the Board of Advisors for the Journal of International Taxation. He has appeared on radio and television to discuss income tax issues and was featured in AccountingToday.com's coverage of FATCA's requirements.

Professional Involvement

On behalf of the ABA Tax Section, Professor Appel had primary responsibility for drafting comments to the Treasury Department and IRS on proposed regulations under Section 1446 of the Internal Revenue Code, and the Office of Chief Counsel asked him to train its attorneys on the issue. He formerly served as Council Director of the ABA Tax Section's U.S. Activities of Foreigners and Tax Treaties Committee, Foreign Activities of U.S. Taxpayers Committee, Transfer Pricing Committee, and Foreign Lawyers Forum, and chaired the U.S. Activities of Foreigners and Tax Treaties Committee. He has published extensively, including in Tax Notes, The Journal of Taxation, Tax Management Memorandum, the Tax Management International Journal, The Journal of International Taxation, and the New York Law Journal, and has contributed multiple chapters to the New York University Institute on Federal Taxation.

Experience

Professor Appel began his career as a trial attorney in the IRS Office of Chief Counsel in Washington, D.C. and New York City, and later spent 13 years as Counsel at Bryan Cave Leighton Paisner LLP (formerly Bryan Cave LLP). He began teaching at New York Law School as an adjunct professor in 2009 and joined the faculty full-time in 2013, where he teaches Commercial Law, Federal Income Tax (Individual and Corporate), International Taxation, and an International Tax Planning Seminar.
Heather Ripley

Heather Ripley

Alston & Bird

Heather Ripley is a partner in Alston & Bird’s Federal & International Tax Group and a member of the firm’s REITs and Real Estate Funds tax team. She helps U.S. and foreign business entities and high-net-worth individuals navigate U.S. federal and international tax law, counseling on tax-efficient structuring of U.S. and cross-border investments and activities, U.S. tax and compliance obligations and risks, and the correction of noncompliance. Her advisory work covers income tax treaty application, FATCA, FIRPTA, and other inbound investment issues, the CFC and PFIC anti-deferral regimes for outbound investments, tax aspects of M&A transactions, and tax information reporting regimes.

Education & Credentials

Ms. Ripley received her J.D. from Harvard University in 2009 and her Master of Accountancy and B.B.A. from the University of Georgia in 2006. She is admitted to the New York Bar.

Recognition & Leadership

Ms. Ripley has been recognized by The Best Lawyers in America in Tax Law and as a New York Law Journal Rising Star. She chairs the ABA Tax Section's Committee on Foreign and U.S. Taxation – Individuals and Passthroughs and serves as International Organizations liaison officer for the International Bar Association's Taxes Committee.

Professional Involvement

Ms. Ripley is a member of the New York State Bar Association's Tax Section and Under 10 Club, the Harvard Club of New York, and the University of Georgia Terry College of Business Alumni, and serves on the board of Volunteers of Legal Service (VOLS). She is a frequent speaker at tax conferences and writes regularly on international tax developments, and has provided volunteer income tax assistance for low-income individuals.

Experience

Ms. Ripley has significant federal tax controversy experience, having guided numerous clients through IRS voluntary disclosure procedures, letter rulings, and competent authority requests, and has counseled charitable and nonprofit organizations on incorporation, tax exemption applications and restrictions, and related tax issues. Her representative matters include serving as U.S. tax counsel to one of the largest foreign multinational financial services groups, representing significant European multinationals on their U.S. structures, restructurings, and operations, and advising European funds and their advisors on optimal tax structures, subscription agreements, and tax certifications.
Sean J. Tevel

Sean J. Tevel

Holland & Knight LLP

Sean Tevel is a private wealth services and international tax attorney in Holland & Knight’s Miami office. He advises foreign and domestic clients on U.S. federal income, gift, and estate tax matters associated with their cross-border investments and businesses. His international tax practice includes advising on multinational trust and business structures, including the controlled foreign corporation rules, the Passive Foreign Investment Company (PFIC) rules, and international tax treaties.

Education & Credentials

Mr. Tevel received his LL.M. in Taxation and his J.D., cum laude, from the University of Miami School of Law, and his B.A. in Economics and Political Science from McGill University. He is admitted to The Florida Bar and speaks French.

Recognition & Leadership

Mr. Tevel is recognized in the Chambers USA guide for Tax (2022–2026) and the Chambers High Net Worth guide for Private Wealth Law: Florida (2024–2025), where industry sources have praised his ability to solve complex cross-border tax matters. He was named among The Best Lawyers in America Miami Tax Law “Ones to Watch” (2021–2024) and a Florida Super Lawyers Rising Star (2020).

Professional Involvement

Mr. Tevel is a member of the Society of Trust and Estate Practitioners (STEP) and of The Florida Bar's Tax Section and International Law Section.

Experience

Mr. Tevel has significant experience structuring U.S. real estate investments, including the application of the Foreign Investment in Real Property Tax Act of 1980 (FIRPTA). He frequently represents domestic and foreign funds on fund formation and structuring considerations for non-U.S. investors, regularly advises on domestic and cross-border joint venture transactions, and has assisted many clients in establishing Qualified Opportunity Funds and maximizing the tax benefits of Opportunity Zone investments. Before joining Holland & Knight, he was a tax attorney in the Miami office of an international law firm.
Jason Schwartz

Jason Schwartz

Cahill Gordon & Reindel

Jason Schwartz is a tax partner in CahillNXT, Cahill’s premier practice for Digital Assets and Emerging Technology, based in Washington, D.C. He specializes in tax issues relating to digital assets, financial products, securitizations, funds, treaties, and lending.

Education & Credentials

Mr. Schwartz received his LL.M. from New York University School of Law, his J.D., magna cum laude and Order of the Coif, from American University Washington College of Law, and his B.A., cum laude, from New York University. He is admitted to practice in New York and the District of Columbia.

Recognition & Leadership

Mr. Schwartz is ranked by Chambers USA, Legal 500 US, and Best Lawyers, and Chambers USA sources have singled him out as a resource for sophisticated tax planning relating to cryptocurrency. He oversees Cahill's 501Foundry, a pro bono program that incorporates, advises, and obtains tax exemption for charitable and other nonprofit organizations; under his ten-plus years of oversight, the program has helped hundreds of charitable organizations obtain tax-exempt status.

Professional Involvement

Mr. Schwartz is frequently asked to speak on panels and podcasts across a wide range of tax topics and is committed to pro bono work and community service.

Experience

Mr. Schwartz has authored numerous tax articles, a Bloomberg BNA Tax Management Portfolio on the taxation of CLOs, and a Practising Law Institute chapter on the taxation of digital assets. Before joining Cahill, he was a partner at a large international law firm.
Matthew Stevens

Matthew Stevens

EY

Matthew Stevens is a Principal in EY’s International Tax and Transaction Services practice in Washington, D.C. He advises multinational corporations, financial institutions, and investment clients on complex U.S. and cross-border tax matters, with a particular focus on international taxation, financial products, capital markets transactions, and tax controversy. Throughout his career, he has built a distinguished reputation for his work in international tax, financial products, and tax policy, combining experience in private practice, government service, academia, and the financial services industry.

Education & Credentials

Matthew Stevens earned his J.D. from Harvard Law School and his B.A. from the University of Kansas.

Recognition & Leadership

Matthew is widely recognized for his leadership in the tax profession. He serves as Chair of the annual Practising Law Institute program Taxation of Financial Products and Transactions and previously chaired the Financial Transactions Committee of both the American Bar Association Section of Taxation and the District of Columbia Bar Tax Section. He has also been recognized by Chambers USA: America's Leading Lawyers for Business for his work in tax law.

Professional Involvement

Matthew has co-taught United States Taxation of International Income II at Georgetown University Law Center and has authored numerous publications on international tax and the taxation of financial products. His professional involvement reflects his commitment to legal education and advancing thought leadership in the field of taxation.

Experience

Before joining EY, Matthew served as Special Counsel to the Chief Counsel of the Internal Revenue Service, where he advised on published guidance involving financial products and cross-border transactions. He has also held senior positions in private practice and the financial services industry, bringing extensive experience to his work advising clients on complex domestic and international tax matters.
Megan L. Brackney

Megan L. Brackney

Kostelanetz LLP

Victor A. Jaramillo

Victor A. Jaramillo

Caplin & Drysdale

Lawrence A. Sannicandro

Lawrence A. Sannicandro

Pillsbury Winthrop Shaw Pittman

Lawrence “Larry” Sannicandro is a partner in Pillsbury’s New York office. He focuses his practice on a broad range of federal and state tax disputes affecting individual private clients as well as their estates, trusts, and businesses, both public and private. These disputes span the full range of civil and criminal tax matters, including audits and examinations, administrative appeals, collection matters, summons proceedings, grand jury subpoenas, criminal tax investigations and prosecutions, and litigation before the U.S. Tax Court, the U.S. Court of Federal Claims, federal district and appellate courts, and state tax tribunals.

Education & Credentials

Mr. Sannicandro received his LL.M. in Taxation from Georgetown University Law Center in 2010, his J.D. from the University of Florida College of Law in 2006, and his M.B.A. in Finance (2003) and B.A. in Political Science (2001) from Binghamton University. He is admitted in New Jersey, New York, and the District of Columbia, and before the U.S. Supreme Court, the U.S. Courts of Appeals for the Second, Third, Fourth, Eleventh, and D.C. Circuits, the U.S. Court of Federal Claims, the U.S. Tax Court, and several federal district courts. He clerked for the Hon. David Laro of the U.S. Tax Court from 2010 to 2012.

Recognition & Leadership

Mr. Sannicandro received the ABA Section of Taxation's Janet Spragens Pro Bono Award (2020), the section's highest honor for pro bono service, and its John S. Nolan Fellowship (2016). He has been recognized by Lawdragon among its 500 Leading Global Tax Lawyers (2025), by Chambers for tax law (2023–2025), and by Super Lawyers (2021); was selected Bloomberg Tax Portfolio Author of the Year (2023); served on Law360's 2023 Tax Authority Federal Editorial Advisory Board; was named a 2022 ROI-NJ Influencer in Law and a 2018 New Jersey Law Journal Leader of the Bar; and received the New York County Lawyers' Association Pro Bono Award (2015). He chairs the ABA Tax Section's Court Procedure Practice Committee.

Professional Involvement

Mr. Sannicandro is a member of the IRS Advisory Council, a Fellow of the American College of Tax Counsel, and a member of the Supreme Court of New Jersey District VA Ethics Committee. He previously taught corporate and partnership tax, tax practice and procedure, and legal ethics at several universities, and speaks extensively before organizations including the Practising Law Institute, the ABA Section of Taxation, the Federal Bar Association, the D.C. Bar, and the NYU Tax Controversy Forum, including a presentation on current penalty issues at the NYU Summer 2025 Institute in International Taxation.

Experience

A former estate and gift tax attorney for the IRS, Mr. Sannicandro is uniquely well-versed in estate and gift tax planning techniques, the valuation of closely held businesses, and defending those techniques in disputes with tax authorities. He has favorably resolved hundreds of tax disputes involving income taxes, estate and gift taxes, employment and payroll taxes, excise taxes, sales and use taxes, federal and state tax credits, and employee plan matters, and advises clients on uncertain tax positions and the identification, quantification, and procedural management of tax-based risks. Representative matters include persuading the U.S. Tax Court that a closing agreement precluded proposed assessments relating to allegedly unreported foreign assets; obtaining full IRS concessions for taxpayers claiming Puerto Rico Act 22 benefits; securing invalidation-driven concessions on a disaster loss carryback regulation; resolving a global high wealth audit of a private equity and family office founder; and securing a non-custodial sentence in a criminal matter involving cryptocurrency-related income while persuading the government to reduce the alleged tax loss by approximately 90 percent. He is the author of Bloomberg BNA portfolios on IRS National Office procedures and innocent spouse relief and a chapter of the ABA's Effectively Representing Your Client Before the IRS, along with numerous articles.
Melissa L. Wiley

Melissa L. Wiley

Kostelanetz

Melissa Wiley is a Partner at Kostelanetz LLP with more than 20 years of experience in tax law, having represented a diverse range of clients—from large corporations to high-net-worth individuals—in complex disputes with federal and state taxing authorities. Known for her calm, empathetic style, she excels at distilling intricate tax issues into clear, actionable insights, helping clients efficiently resolve disputes and focus on what matters most in their businesses and lives. Melissa serves as a trusted advisor to clients at all levels of administrative tax controversy, including audits, cases before the IRS Office of Appeals, and investigations by the IRS Office of Professional Responsibility, and she has significant experience handling penalty and international information reporting matters. When an administrative resolution cannot be reached, she is well-equipped to litigate, and she also represents clients facing government and third-party subpoenas and investigations while frequently advising on voluntary disclosures of prior tax noncompliance. An actuary by training, Melissa pairs a scrupulous, detail-oriented approach with a thorough understanding of how tax affects her clients’ financial affairs, and her background in statistics and the insurance industry has fostered a natural ability to collaborate effectively with technical and forensic experts.

Education & Credentials

Melissa received her J.D., cum laude, from the Georgetown University Law Center in 2003, and earned her B.S. in Actuarial Science, summa cum laude and as valedictorian, from The College of Insurance in 1998. She is admitted to practice in the District of Columbia, New York, and Virginia, as well as before the U.S. Tax Court, the Court of Federal Claims, the U.S. Court of Appeals for the Eleventh Circuit, and the U.S. District Court for the District of Columbia.

Recognition & Leadership

Melissa is a Fellow of the American College of Tax Counsel (since May 2019) and serves as its Regent for the Federal Circuit (since March 2023). She is a member of the J. Edgar Murdock Inn of Court. Within the ABA Section of Taxation, she serves as Vice Chair for Membership, Diversity and Inclusion (since August 2024) and Chair of the Loretta Collins Argrett Fellowship Committee, and she was named a Nolan Fellow in 2011. She is recognized for her in-depth knowledge of tax controversy topics and frequently speaks on IRS filing requirements, enforcement priorities, penalties, ethics, and the Corporate Transparency Act.

Professional Involvement

Melissa is deeply engaged in the tax community across multiple organizations. Within the ABA Section of Taxation, in addition to her current leadership roles, she has served as Vice-Chair of the Appointments to the Tax Court Committee, Vice Chair of Committee Operations (2020–2022), a Council Member (2016–2019), and former Chair of both the Young Lawyer's Forum and the Law Student Tax Challenge. At the AICPA, she has been a member of the IRS Advocacy and Relations Committee since January 2019, currently serving as its Chair (since May 2024) after serving as Vice-Chair (2023–2024), and is a member of the National Tax Conference Committee. She chaired the DC Bar Association Tax Section's Tax Audits and Litigation Committee (2022–2024) after serving as its Vice-Chair (2020–2022). She also serves as an adjunct professor at her alma mater, Georgetown University Law Center, where she will teach an upcoming course on Tax Research and Writing. Her pro bono and community service includes board service with the Community Tax Law Project (since November 2022) and more than 15 years with the Children's Law Center, where she has served on the Board of Directors, as Treasurer, and on its Emeritus Board, offering pro bono assistance in custody and abuse/neglect cases.

Experience

Melissa represents corporate, institutional, and individual clients in tax controversy matters in litigation and before all levels of the IRS, including audits, cases before the IRS Office of Appeals, and investigations by the IRS Office of Professional Responsibility. She has significant experience handling penalty and international information reporting matters, and her litigation experience spans the U.S. Tax Court, the Court of Federal Claims, and various federal district courts. She also represents clients facing government and third-party subpoenas and investigations and counsels clients on voluntary disclosures of prior tax noncompliance. Her practice is informed by six years as an Assistant General Counsel at a Big Four accounting firm, which gave her a deep understanding of the regulations and professional standards governing tax practice, as well as her earlier background as an actuary in statistics and the insurance industry.

Credits by state

AK12.0
AL12.0
AR12.0
AZ12.0
CA12.0
CO12.0
CT12.0
DC12.0
DE12.0
FL12.0
GA6.0
HI12.0
IA12.0
ID12.0
IL12.0
IN12.0
KS12.0
KY12.0
LA12.0
MA12.0
MD12.0
ME12.0
MI12.0
MN12.0
MO14.4
MS12.0
MT12.0
NC12.0
ND12.0
NE12.0
NH720.0
NJ14.4
NM12.0
NV12.0
NY14.0
OH12.0
OK14.5
OR12.0
PA12.0
RI14.5
SC12.0
SD12.0
TN12.0
TX12.0
UT12.0
VA12.0
VT12.0
WA12.0
WI14.0
WV14.4
WY12.0

Upcoming Live Online CLE Broadcasts

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Trusted by Legal Professionals

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Live stream programs

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Trusted by Legal Professionals

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Live stream programs

24/7

Access to live webinars & recordings

10,000+

Trusted by Legal Professionals

1000+

Live stream programs

24/7

Access to live webinars & recordings

70,000+

Trusted by Legal Professionals

MCLE Credits

Alabama
Pending
Alaska
Approved
Arizona
Approved
Arkansas
Approved
California
Approved
Colorado
Pending
Connecticut
Approved
Delaware
Pending
District of Columbia
No Required
Florida
Approved
Georgia
Pending
Hawaii
Approved
Idaho
Pending
Illinois
Pending
Indiana
Pending
Iowa
Pending
Kansas
Pending
Kentucky
Pending
Louisiana
Pending
Maine
Pending
Maryland
No Required
Massachusetts
No Required
Michigan
No Required
Minnesota
Pending
Mississippi
Pending
Missouri
Approved
Montana
Pending
Nebraska
Pending
Nevada
Pending
New Hampshire
Approved
New Jersey
Approved
New Mexico
Pending
New York
Approved
North Carolina
Pending
North Dakota
Approved
Ohio
Approved
Oklahoma
Pending
Oregon
Pending
Pennsylvania
Pending
Rhode Island
Pending
South Carolina
Pending
South Dakota
No Required
Tennessee
Pending
Texas
Pending
Utah
Pending
Vermont
Approved
Virginia
Not Eligible
Washington
Approved
West Virginia
Pending
Wisconsin
Pending
Wyoming
Pending

Alabama

Requirements

The Alabama State Bar MCLE Commission requires attorneys to complete 12 credits, including 1 ethics, by December 31 of each year. All credits must be reported by February 15 of the following year. A maximum of 12 credits, including 1 ethics credit, may be carried over for 1 year only.  

Formats

  • Attorneys can earn unlimited “live” credit through live seminars, live webcasts, and co-sponsored locations with MyLAWCLE-Alabama approved programs
  • Attorneys are limited to 6 credits per compliance period of “online” programs through MyLAwCLE On-Demand programs