Program Details
2026-07-20 08:25:00
Over 1,000+ webinars
Course Overview
2026-07-20 08:25:00
18.33h CLE Credits
Intermediate
18.33
8:25 am - 8:45 am ESTKathleen Costello, CMP, Assistant Director, NYU School of Professional Studies, New York, NY
Michael J. Miller, Esq., Partner, Roberts & Holland, New York, NY
Michael J. Miller 8:45 am - 12:00 pm ESTThis session covers the rules governing source of income; US trade or business; effectively connected income; FDAP income; withholding taxes; FIRPTA; branch profits tax; branch level interest tax; earnings-stripping; anti-conduit financing; and the base erosion anti-abuse tax (BEAT).
Michael J. Miller, Esq., Partner, Roberts & Holland, New York, NY
James S.H. Null, Esq., Partner, Kilpatrick Townsend & Stockton, New York, NY
Michael J. Miller
James S.H. Null 1:15 pm - 2:45 pm ESTTax treaties modify the statutory tax rules affecting cross-border taxation. This session explores the typical provisions of such treaties, who is eligible to benefit under a treaty, and how a treaty modifies the tax rules that would otherwise apply.
David G. Shapiro, Esq., Partner, Saul Ewing, Philadelphia, PA
Robert Christoffel, Esq., Counsel, Saul Ewing, Washington, DC
David G. Shapiro
Robert Christoffel 3:00 pm - 4:30 pm ESTCross-border transactions between related persons are subject to the transfer pricing rules of Section 482. This session addresses the general rules of Section 482 and the specific applications of those rules to certain categories of transactions, including transfers of tangible and intangible property; and services and loans. The session also explores the economic analysis relevant to transfer pricing; correlative relief; and cost-sharing agreements.
Oliver Minguillon, MBA, Managing Director, Economic and Valuation Services (Transfer Pricing), KPMG, New York, NY
Oliver Minguillon 8:45 am - 12:00 pm ESTThe Internal Revenue Code provides various regimes for the taxation of US shareholders of a controlled foreign corporation (CFC). This session explores the definitions of a CFC and US shareholder (including applicable stock ownership and attribution rules), the categories of Subpart F income and applicable exceptions, the net CFC tested income (NCTI, formerly GILTI) rules, and Section 956 inclusions, highlighting the changes introduced by the One Big Beautiful Bill Act, where applicable. The session also addresses the Section 962 election for non-corporate US shareholders, distributions of previously taxed earnings and profits (PTEP), the Section 245A dividends received deduction for corporate US shareholders, and the Section 1248 dividend recharacterization.
Logan E. Gans, Esq., Partner, Holland & Knight, Miami, FL
Lucas Giardelli, Esq., Partner, Mayer Brown, New York, NY
Logan E. Gans
Lucas Giardelli 1:15 pm - 2:45 pm ESTThe US taxation of US persons who are shareholders of passive foreign investment companies (PFICs) is complex and often misunderstood. This session covers the definitional provisions of the PFIC rules and the alternative methods of taxation of US shareholders of a PFIC. Certain proposed regulations addressing the treatment of PFICs held through domestic partnerships are also addressed.
Amitai Barth, Esq., Senior Manager, Deloitte, Washington, DC
Jason Robertson, Esq., Principal, Deloitte, Washington, DC
Amitai Barth
Jason Robertson 3:00 pm - 4:30 pm ESTThe US imposes worldwide taxation on US citizens, residents, and US business entities. This session explores how the provisions of Sections 901, 904, and 960 provide for, and limit the ability of such US taxpayers to claim tax credits for foreign taxes that they pay directly and indirectly.
Adam Bair, Esq., Principal, National Tax Services, PwC, New York, NY
Steven Burns, CPA, Director, National Tax Services, PwC, Washington, DC
Adam Bair
Steven Burns 8:45 am - 9:45 am ESTFor clients who have willfully failed to comply with tax or tax-related obligations relating to foreign income or foreign assets, submitting a voluntary disclosure may be a means to resolve non-compliance and limit exposure to criminal prosecution. This panel discusses the ethical responsibilities for tax professionals, including maintaining confidentiality, avoiding conflicts of interest, and the overarching rules of Circular 230, that come into play when advising clients about the pros and cons of voluntary disclosures and other corrective options to consider when addressing omissions and errors in complying with tax obligations.
Barbara T. Kaplan, Esq., Shareholder, Greenberg Traurig, New York, NY
Scott D. Michel, Esq., Member, Caplin and Drysdale, Chartered, Washington, DC
Daniel N. Price, Esq., Managing Member, Law Offices of Daniel N. Price, San Antonio, TX
Alyssa Maloof Whatley, Esq., Director, Frost Law, Atlanta, GA
Barbara T. Kaplan
Scott D. Michel
Daniel N. Price
Alyssa Maloof Whatley 9:45 am - 10:45 am ESTSpecial income, estate, and gift tax rules, set forth in Sections 877A and 2801, limit the ability of US citizens and certain lawful permanent residents to achieve tax benefits by relinquishing their citizenship or terminating their status as lawful permanent residents. This session provides an overview of these provisions.
Bonnie J. Daniels, Esq., Associate, Roberts & Holland, New York, NY
Michael J. Miller, Esq., Partner, Roberts & Holland, New York, NY
Bonnie J. DanielsMichael J. Miller 11:00 am - 12:00 pm ESTThe rules of Sections 367 and 7874 curb the ability of US taxpayers to transfer assets to, or to receive assets from, foreign corporations in transactions that would otherwise qualify as tax-free, and to prevent US business entities from “inverting” to become foreign-owned.
Joseph M. Calianno, JD, LLM, MBA, CPA, Managing Director; National Tax Practice, Andersen Tax, Washington, DC
Joseph M. Calianno 1:15 pm - 2:45 pm ESTForeign individuals who invest in or move to the US are confronted with structuring and planning to minimize US income and estate and gift taxation, as well as integrating the US rules with their home country tax rules. This session addresses the application of the US rules and planning considerations for such foreign individuals.
Thomas M. Giordano-Lascari, Esq., Greenberg Glusker, Los Angeles, CA
Michael J.A. Karlin, Esq., Partner, Holland & Knight, Los Angeles, CA
Thomas M. Giordano-Lascari
Michael J.A. Karlin 3:00 pm - 4:30 pm ESTThis session incorporates the disparate rules covered in the preceding sessions into case studies dealing with both outbound and inbound investment scenarios and provides a review of the material covered during the entire program.
Alan I. Appel, Esq., Professor of Law, New York Law School, New York, NY
Michael J. Miller, Esq., Partner, Roberts & Holland, New York, NY
William B. Sherman, Esq., Partner, Holland & Knight, Fort Lauderdale, FL
Alan I. AppelMichael J. Miller
William B. ShermanMichael J. Miller is a Partner at Roberts & Holland LLP, where he has provided U.S. tax advice to domestic and international clients for more than 20 years. His practice centers on international taxation. For foreign clients, he structures inbound U.S. investments and operations to avoid creating a U.S. permanent establishment and designs structures that make use of U.S. income tax treaties, the portfolio interest withholding exemption, and other rules for minimizing U.S. tax, while accounting for anti-abuse rules such as earnings-stripping limitations and restrictions on treaty shopping and hybrid entities. He also works with U.S. multinationals to structure foreign investments and operations to reduce the impact of restrictions on outbound transfers and the anti-deferral rules applicable to shareholders of controlled foreign corporations and passive foreign investment companies, and to maximize the use of foreign tax credits.
Jamie Null is a leading tax lawyer with nearly eighteen years of experience advising on U.S. federal tax matters, including transactional tax issues associated with U.S. inbound and outbound investments, as well as domestic and international tax planning for individual, corporate, and partnership transactions. He advises on private equity investments and structures and on domestic and cross-border mergers and acquisitions. His diverse practice spans industries including real estate, entertainment, media, biotechnology, alternative energy, hospitality, transportation, and technology. He has substantial experience with real estate-related transactions, including sophisticated like-kind exchanges involving domestic and foreign interest holders, and works frequently in the media and entertainment sector, advising U.S. and non-U.S. entertainment clients on the production and talent side of U.S. and international entertainment investments. He is a member of Kilpatrick’s Transactional Tax Team in the firm’s Corporate, Finance and Real Estate Department.
David Shapiro leads Saul Ewing’s Tax Practice and advises clients on international and domestic business tax planning, including domestic and cross-border expansion, joint ventures, mergers, acquisitions, and financing transactions. His practice includes entity formation and structure planning, securities offerings and hybrid financings, joint ventures, and strategic acquisitions and dispositions, and he represents both equity sponsors and investors in real estate transactions and structures, including Qualified Opportunity Funds and cross-border real estate deals. He also advises clients on evaluating tax risks, including whether those risks may be insurable, has obtained tax rulings for multiple clients, and handles audits, appeals, and litigation when tax authorities disagree with taxpayer positions. A client described him as the best tax attorney they had ever worked with, praising his responsiveness and authoritative guidance.
Robert Christoffel advises clients on U.S. domestic and cross-border transactional matters as well as international tax issues. Public and private companies and private equity funds turn to him to structure and negotiate taxable and tax-free corporate mergers and acquisitions (share and asset deals), reorganizations including spinoffs, dispositions of ongoing businesses, and investments into domestic and foreign portfolio companies, and he negotiates and drafts tax provisions for membership interest purchases, joint ventures, and partnership and LLC formations. He also counsels on public offerings of debt and equity securities, credit and financing transactions, investment fund closings, tax-efficient structuring of multinational operations and intercompany transactions, IRS and foreign tax authority audits (including transfer pricing audits) and tax litigation, and developments in U.S. and global tax reform, including OECD Pillar I and II and digital taxes. He is a fully qualified German lawyer, having passed both German bar exams, and has particular experience with clients in the technology, media, energy, and consumer goods industries.
Oliver Minguillon is a Managing Director in KPMG’s Economic and Valuation Services Department with over fifteen years of transfer pricing experience. He specializes in operational transfer pricing as a member of the KPMG National Operational Transfer Pricing team, and in addition to operational transfer pricing engagements, he specializes in the financial services and banking industries. He directs large-scale operational transfer pricing projects for Fortune 1000 companies, assessing current states and implementing end-to-end transfer pricing processes that align transfer pricing policies with financial systems and tools, and coordinates global transfer pricing planning and documentation initiatives, including functional interviews and managing interactions with local country member firms.
Logan E. Gans is a private wealth services and tax attorney in Holland & Knight’s Miami office and co-chair of the firm’s State and Local Tax Team. He advises high-net-worth individuals, family offices, closely held businesses, and institutional clients on complex federal, state, and international tax matters, with particular strengths in Florida state and local tax (including documentary stamp tax and nonrecurring intangible personal property tax), business aviation tax, cross-border structuring, and tax controversy. His aviation work includes structuring aircraft acquisitions and dispositions, bonus depreciation and Section 280F analysis, leasing and management arrangements, charter and Part 135 operations, and fractional and co-ownership structures. He counsels real estate developers, lenders, and borrowers on Florida and multistate tax matters and on Qualified Opportunity Fund investments; represents clients in federal and state tax controversies, including audits, penalty appeals, voluntary disclosures, IRS streamlined filing procedures, and delinquent FBAR submissions; and advises on outbound planning (Subpart F, GILTI, PFIC, and FDII) and inbound investment structuring, including real property, portfolio debt planning, and cross-border M&A.
Multinational companies rely on Lucas Giardelli for the structuring and execution of business transactions and for corporate and international tax planning. He advises clients across industries on the tax aspects of acquisitions, divestitures, joint ventures, financings, and other corporate transactions, particularly in the cross-border context, and regularly assists U.S. and international clients with internal restructurings and financings, holding company structures, double tax treaties, tax attribute optimization, supply chain and IP planning, and post-acquisition integration. He also counsels high-net-worth individuals and family offices on international tax matters.
Amitai Barth is a Senior Manager in Deloitte’s Washington National Tax – International Tax Services group, where he handles complex inbound and outbound issues, transactions, and restructurings, with specializations in financing, corporate tax, PFICs, and insurance. Drawing on Big Four, Biglaw, and IRS Office of Chief Counsel experience in identifying, analyzing, distilling, and resolving complex transactional and controversy issues, he adds value for clients by pairing broad technical knowledge with sharp research, analytical, and writing skills to develop tax-efficient solutions. His strengths include spotting potential tax traps in restructurings and reorganizations, probing the Code, regulations, case law, and IRS guidance to flesh out applicable authorities, translating technical language and legalese into plain English, and developing overall strategy and specific tax advice tailored to a taxpayer’s unique facts and risk profile.
Jason Robertson is a Principal in Deloitte Tax LLP’s Washington National Tax practice, where he is a member of the International Tax Group. He specializes in advising U.S. and foreign-based multinationals on a broad range of international tax matters and is a member of the Deloitte Tax Cryptocurrency Working Group.
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.
Steven Burns, CPA, is a tax professional with an extensive career at PwC, where he served as a Tax Partner for more than 19 years. His professional background includes significant experience in tax services and a long-standing tenure with the firm, culminating in his retirement from PwC on December 31, 2020.
Barbara T. Kaplan chairs Greenberg Traurig’s New York Tax Practice and focuses her tax litigation practice on representing domestic and foreign corporations, partnerships, and individuals in federal, state, and local tax examinations, controversies, and litigation, including administrative and grand jury criminal tax investigations. Her concentrations include tax compliance counseling, offshore account reporting, sensitive audits, promoter audits, preparer penalties, civil tax controversies, complex tax litigation, criminal tax investigations, voluntary disclosures, tax penalties and procedure, Bank Secrecy Act compliance, Circular 230 violations, ERISA litigation, regulatory investigations, state and local tax, and audits and litigation involving tax-exempt organizations.
Scott D. Michel has worked on cutting-edge tax enforcement cases his entire career, advising individuals, families, corporations, tax professionals, financial institutions, and others on five continents in criminal and civil tax enforcement and compliance matters. Since the early 1980s his client representations have paralleled the domestic and international enforcement priorities of the IRS and the Department of Justice, including unreported income and false deduction cases, unreported foreign assets and structures, criminal tax shelter, Employee Retention Credit, conservation easement, and Malta Pension Plan cases, and employment tax, cash-reporting, and cryptocurrency reporting failures. He has helped many thousands of taxpayers return to compliance through the voluntary disclosure process and is routinely consulted by other practitioners on sensitive ethical questions in tax practice.
Dan Price’s practice focuses on tax and Title 31 (Bank Secrecy Act) controversy matters with the IRS and tax matters before certain state tax authorities. For over nineteen years, Dan served as an attorney in the IRS Office of Chief Counsel, and his experience as a former trial attorney, supervisory trial attorney, and Special Assistant United States Attorney gives him a distinctive perspective on tax controversy and tax administration. For federal tax and federal immigration matters, he accepts clients nationally.
Alyssa Maloof Whatley is the Director of Tax Controversy (Domestic) at Frost Law, bringing extensive experience and a client-centered approach to resolving complex tax matters. An experienced tax lawyer with a proven record of reducing tax liability, she is a dedicated advocate in navigating the IRS, crafting tailored solutions for each tax problem, from audits to negotiated settlements, and emphasizing clear communication, education, and client-focused technology.
Bonnie J. Daniels provides comprehensive tax planning to high-net-worth individuals by crafting domestic and cross-border gift and estate tax-efficient plans, structuring closely held businesses, and facilitating philanthropic objectives. Her practice includes drafting wills and domestic and foreign trusts (including dynasty trusts, insurance trusts, and defective grantor trusts), forming closely held family companies, and structuring gift, estate, and income tax-efficient transactions. She advises inbound and outbound clients on their tax and reporting obligations, including the specific U.S. issues that arise in the context of foreign trusts, helps clients structure their qualified opportunity zone (QOZ) investments, advises on the New York State pass-through entity tax, and forms private foundations while providing operational advice on avoiding self-dealing pitfalls and related issues.
Joe Calianno is a Managing Director in Andersen’s US National Tax practice in the Washington, D.C. office, where he serves as the USNT leader for international tax. He advises clients on all areas of international tax, including provisions related to the Tax Cuts and Jobs Act, the One Big Beautiful Bill Act, and cross-border restructurings.
Thomas Giordano-Lascari is a Partner in Greenberg Glusker’s Private Client Services Group with nearly two decades of experience counseling high-net-worth individuals and closely held businesses on international income tax and estate planning matters. Well known for his work with global families whose holdings span multiple jurisdictions, he helps clients structure worldwide assets to advance family objectives while minimizing income and transfer taxes, and regularly handles pre-immigration planning, foreign investment in the United States, U.S. residency planning and management, and expatriation planning. He is a sought-after advisor on foreign trusts, guiding foreign fiduciaries, U.S. beneficiaries, and grantors through compliance obligations and tax consequences.
Michael J.A. Karlin is a private wealth services and tax attorney in Holland & Knight’s Century City office. He advises corporate and individual clients on tax, estate planning, and business matters that involve a cross-border element. For more than 45 years, his practice has centered on private client work: he counsels individuals and families from abroad who invest in or move to the United States, as well as U.S. individuals and families investing or moving abroad, including on the ever-increasing regulatory and reporting obligations these activities carry. Pre-immigration and expatriation planning form an important part of his practice.
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.
William B. Sherman is a partner in Holland & Knight’s Miami and Fort Lauderdale offices, where he concentrates his practice on domestic and international taxation. He provides sophisticated tax planning for mergers and acquisitions, restructurings, joint ventures, and investments for clients in industries as diverse as private equity, healthcare, hospitality, petrochemicals, aluminum, real estate, transportation, telecommunications, retailing, investment management, and pharmaceuticals. His work spans U.S. investment overseas and foreign investment in the United States, along with international, federal, state, and local tax issues involving investment management fund structuring, corporate reorganizations, partnerships, equipment leasing, Subchapter S, executive compensation, stock options, and trusts and estates.
Michael J. Miller is a Partner at Roberts & Holland LLP, where he has provided U.S. tax advice to domestic and international clients for more than 20 years. His practice centers on international taxation. For foreign clients, he structures inbound U.S. investments and operations to avoid creating a U.S. permanent establishment and designs structures that make use of U.S. income tax treaties, the portfolio interest withholding exemption, and other rules for minimizing U.S. tax, while accounting for anti-abuse rules such as earnings-stripping limitations and restrictions on treaty shopping and hybrid entities. He also works with U.S. multinationals to structure foreign investments and operations to reduce the impact of restrictions on outbound transfers and the anti-deferral rules applicable to shareholders of controlled foreign corporations and passive foreign investment companies, and to maximize the use of foreign tax credits.
Jamie Null is a leading tax lawyer with nearly eighteen years of experience advising on U.S. federal tax matters, including transactional tax issues associated with U.S. inbound and outbound investments, as well as domestic and international tax planning for individual, corporate, and partnership transactions. He advises on private equity investments and structures and on domestic and cross-border mergers and acquisitions. His diverse practice spans industries including real estate, entertainment, media, biotechnology, alternative energy, hospitality, transportation, and technology. He has substantial experience with real estate-related transactions, including sophisticated like-kind exchanges involving domestic and foreign interest holders, and works frequently in the media and entertainment sector, advising U.S. and non-U.S. entertainment clients on the production and talent side of U.S. and international entertainment investments. He is a member of Kilpatrick’s Transactional Tax Team in the firm’s Corporate, Finance and Real Estate Department.
David Shapiro leads Saul Ewing’s Tax Practice and advises clients on international and domestic business tax planning, including domestic and cross-border expansion, joint ventures, mergers, acquisitions, and financing transactions. His practice includes entity formation and structure planning, securities offerings and hybrid financings, joint ventures, and strategic acquisitions and dispositions, and he represents both equity sponsors and investors in real estate transactions and structures, including Qualified Opportunity Funds and cross-border real estate deals. He also advises clients on evaluating tax risks, including whether those risks may be insurable, has obtained tax rulings for multiple clients, and handles audits, appeals, and litigation when tax authorities disagree with taxpayer positions. A client described him as the best tax attorney they had ever worked with, praising his responsiveness and authoritative guidance.
Robert Christoffel advises clients on U.S. domestic and cross-border transactional matters as well as international tax issues. Public and private companies and private equity funds turn to him to structure and negotiate taxable and tax-free corporate mergers and acquisitions (share and asset deals), reorganizations including spinoffs, dispositions of ongoing businesses, and investments into domestic and foreign portfolio companies, and he negotiates and drafts tax provisions for membership interest purchases, joint ventures, and partnership and LLC formations. He also counsels on public offerings of debt and equity securities, credit and financing transactions, investment fund closings, tax-efficient structuring of multinational operations and intercompany transactions, IRS and foreign tax authority audits (including transfer pricing audits) and tax litigation, and developments in U.S. and global tax reform, including OECD Pillar I and II and digital taxes. He is a fully qualified German lawyer, having passed both German bar exams, and has particular experience with clients in the technology, media, energy, and consumer goods industries.
Oliver Minguillon is a Managing Director in KPMG’s Economic and Valuation Services Department with over fifteen years of transfer pricing experience. He specializes in operational transfer pricing as a member of the KPMG National Operational Transfer Pricing team, and in addition to operational transfer pricing engagements, he specializes in the financial services and banking industries. He directs large-scale operational transfer pricing projects for Fortune 1000 companies, assessing current states and implementing end-to-end transfer pricing processes that align transfer pricing policies with financial systems and tools, and coordinates global transfer pricing planning and documentation initiatives, including functional interviews and managing interactions with local country member firms.
Logan E. Gans is a private wealth services and tax attorney in Holland & Knight’s Miami office and co-chair of the firm’s State and Local Tax Team. He advises high-net-worth individuals, family offices, closely held businesses, and institutional clients on complex federal, state, and international tax matters, with particular strengths in Florida state and local tax (including documentary stamp tax and nonrecurring intangible personal property tax), business aviation tax, cross-border structuring, and tax controversy. His aviation work includes structuring aircraft acquisitions and dispositions, bonus depreciation and Section 280F analysis, leasing and management arrangements, charter and Part 135 operations, and fractional and co-ownership structures. He counsels real estate developers, lenders, and borrowers on Florida and multistate tax matters and on Qualified Opportunity Fund investments; represents clients in federal and state tax controversies, including audits, penalty appeals, voluntary disclosures, IRS streamlined filing procedures, and delinquent FBAR submissions; and advises on outbound planning (Subpart F, GILTI, PFIC, and FDII) and inbound investment structuring, including real property, portfolio debt planning, and cross-border M&A.
Multinational companies rely on Lucas Giardelli for the structuring and execution of business transactions and for corporate and international tax planning. He advises clients across industries on the tax aspects of acquisitions, divestitures, joint ventures, financings, and other corporate transactions, particularly in the cross-border context, and regularly assists U.S. and international clients with internal restructurings and financings, holding company structures, double tax treaties, tax attribute optimization, supply chain and IP planning, and post-acquisition integration. He also counsels high-net-worth individuals and family offices on international tax matters.
Amitai Barth is a Senior Manager in Deloitte’s Washington National Tax – International Tax Services group, where he handles complex inbound and outbound issues, transactions, and restructurings, with specializations in financing, corporate tax, PFICs, and insurance. Drawing on Big Four, Biglaw, and IRS Office of Chief Counsel experience in identifying, analyzing, distilling, and resolving complex transactional and controversy issues, he adds value for clients by pairing broad technical knowledge with sharp research, analytical, and writing skills to develop tax-efficient solutions. His strengths include spotting potential tax traps in restructurings and reorganizations, probing the Code, regulations, case law, and IRS guidance to flesh out applicable authorities, translating technical language and legalese into plain English, and developing overall strategy and specific tax advice tailored to a taxpayer’s unique facts and risk profile.
Jason Robertson is a Principal in Deloitte Tax LLP’s Washington National Tax practice, where he is a member of the International Tax Group. He specializes in advising U.S. and foreign-based multinationals on a broad range of international tax matters and is a member of the Deloitte Tax Cryptocurrency Working Group.
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.
Steven Burns, CPA, is a tax professional with an extensive career at PwC, where he served as a Tax Partner for more than 19 years. His professional background includes significant experience in tax services and a long-standing tenure with the firm, culminating in his retirement from PwC on December 31, 2020.
Barbara T. Kaplan chairs Greenberg Traurig’s New York Tax Practice and focuses her tax litigation practice on representing domestic and foreign corporations, partnerships, and individuals in federal, state, and local tax examinations, controversies, and litigation, including administrative and grand jury criminal tax investigations. Her concentrations include tax compliance counseling, offshore account reporting, sensitive audits, promoter audits, preparer penalties, civil tax controversies, complex tax litigation, criminal tax investigations, voluntary disclosures, tax penalties and procedure, Bank Secrecy Act compliance, Circular 230 violations, ERISA litigation, regulatory investigations, state and local tax, and audits and litigation involving tax-exempt organizations.
Scott D. Michel has worked on cutting-edge tax enforcement cases his entire career, advising individuals, families, corporations, tax professionals, financial institutions, and others on five continents in criminal and civil tax enforcement and compliance matters. Since the early 1980s his client representations have paralleled the domestic and international enforcement priorities of the IRS and the Department of Justice, including unreported income and false deduction cases, unreported foreign assets and structures, criminal tax shelter, Employee Retention Credit, conservation easement, and Malta Pension Plan cases, and employment tax, cash-reporting, and cryptocurrency reporting failures. He has helped many thousands of taxpayers return to compliance through the voluntary disclosure process and is routinely consulted by other practitioners on sensitive ethical questions in tax practice.
Dan Price’s practice focuses on tax and Title 31 (Bank Secrecy Act) controversy matters with the IRS and tax matters before certain state tax authorities. For over nineteen years, Dan served as an attorney in the IRS Office of Chief Counsel, and his experience as a former trial attorney, supervisory trial attorney, and Special Assistant United States Attorney gives him a distinctive perspective on tax controversy and tax administration. For federal tax and federal immigration matters, he accepts clients nationally.
Alyssa Maloof Whatley is the Director of Tax Controversy (Domestic) at Frost Law, bringing extensive experience and a client-centered approach to resolving complex tax matters. An experienced tax lawyer with a proven record of reducing tax liability, she is a dedicated advocate in navigating the IRS, crafting tailored solutions for each tax problem, from audits to negotiated settlements, and emphasizing clear communication, education, and client-focused technology.
Bonnie J. Daniels provides comprehensive tax planning to high-net-worth individuals by crafting domestic and cross-border gift and estate tax-efficient plans, structuring closely held businesses, and facilitating philanthropic objectives. Her practice includes drafting wills and domestic and foreign trusts (including dynasty trusts, insurance trusts, and defective grantor trusts), forming closely held family companies, and structuring gift, estate, and income tax-efficient transactions. She advises inbound and outbound clients on their tax and reporting obligations, including the specific U.S. issues that arise in the context of foreign trusts, helps clients structure their qualified opportunity zone (QOZ) investments, advises on the New York State pass-through entity tax, and forms private foundations while providing operational advice on avoiding self-dealing pitfalls and related issues.
Joe Calianno is a Managing Director in Andersen’s US National Tax practice in the Washington, D.C. office, where he serves as the USNT leader for international tax. He advises clients on all areas of international tax, including provisions related to the Tax Cuts and Jobs Act, the One Big Beautiful Bill Act, and cross-border restructurings.
Thomas Giordano-Lascari is a Partner in Greenberg Glusker’s Private Client Services Group with nearly two decades of experience counseling high-net-worth individuals and closely held businesses on international income tax and estate planning matters. Well known for his work with global families whose holdings span multiple jurisdictions, he helps clients structure worldwide assets to advance family objectives while minimizing income and transfer taxes, and regularly handles pre-immigration planning, foreign investment in the United States, U.S. residency planning and management, and expatriation planning. He is a sought-after advisor on foreign trusts, guiding foreign fiduciaries, U.S. beneficiaries, and grantors through compliance obligations and tax consequences.
Michael J.A. Karlin is a private wealth services and tax attorney in Holland & Knight’s Century City office. He advises corporate and individual clients on tax, estate planning, and business matters that involve a cross-border element. For more than 45 years, his practice has centered on private client work: he counsels individuals and families from abroad who invest in or move to the United States, as well as U.S. individuals and families investing or moving abroad, including on the ever-increasing regulatory and reporting obligations these activities carry. Pre-immigration and expatriation planning form an important part of his practice.
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.
William B. Sherman is a partner in Holland & Knight’s Miami and Fort Lauderdale offices, where he concentrates his practice on domestic and international taxation. He provides sophisticated tax planning for mergers and acquisitions, restructurings, joint ventures, and investments for clients in industries as diverse as private equity, healthcare, hospitality, petrochemicals, aluminum, real estate, transportation, telecommunications, retailing, investment management, and pharmaceuticals. His work spans U.S. investment overseas and foreign investment in the United States, along with international, federal, state, and local tax issues involving investment management fund structuring, corporate reorganizations, partnerships, equipment leasing, Subchapter S, executive compensation, stock options, and trusts and estates.
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
