The Freeman Law
International Tax Symposium

Join leading tax experts from across the globe, as we discuss tax trends that are
reshaping international taxation

Virtual Symposium
October 20th & 21st, 2022
The two-day virtual program will qualify for up to 14 hours of:
  • Continuing Legal Education (“CLE”)
  • NASBA Credit for Continuing Professional Education (“CPE”) for CPAs
  • IRS Continuing Education (“CE”)

An Experience Unlike Any Other

Find yourself on the cutting-edge of international tax law, with up-to-date insights and perspectives on cross-border taxation and current trends.

Prepare for the realities of today’s tax practice—and for that of tomorrow. Global economies are increasingly connected. Markets and supply chains cut across tax authorities. Never before has a well-rounded knowledge of the international tax rules and risks been more important.

leading experts from across the world

We have assembled leading experts from across the world, along with key government officials and other industry leaders, setting the stage for unparalleled thought leadership—all delivered in a format made for 2022 and beyond. Learn from recognized leaders, as we discuss:

  • Global Tax Reform
  • International Civil Penalty Enforcement
  • International Criminal Tax Enforcement
  • Transfer Pricing Developments
  • A Closer Look at GILTI and FDII
  • Cryptocurrency – Global Enforcement Trends
  • The Tax Information Age—Global Information Exchange
  • Cross-Border Tax Planning Opportunities

The two-day program will qualify for up to 14 hours of:

  • Continuing Legal Education (“CLE”)
  • NASBA Credit for Continuing Professional Education (“CPE”) for CPAs
  • IRS Continuing Education (“CE”)

Featured Speakers

Charles P. Rettig

IRS Commissioner

 

Charles P. Rettig is the 49th Commissioner of the IRS. As Commissioner, Mr. Rettig presides over the nation’s tax system, which collects more than $4.1 trillion in tax revenue each year representing about 96% of the total gross receipts of the United States. In this regard, since this revenue funds most government operations and public services, the continued success of our country depends upon a successful IRS. Mr. Rettig manages an agency of about 80,000 employees and a budget of more than $12 billion.

 

In leading the IRS, Mr. Rettig has worked to focus attention on the important work of the agency’s employees. “The IRS employees are the absolute strength of the agency,” he notes. “We are proud to be reflective of the diverse communities we serve. Our employees are dedicated and they care a lot, for both taxpayers and the nation.” Since joining the IRS, Mr. Rettig has also been heavily focused on improving service to the nation’s taxpayers, balancing appropriate enforcement of the nation’s tax laws while respecting taxpayer rights, with a particular focus on traditionally underserved communities. Subject to budgetary appropriations, the IRS maintains a strong, visible, robust tax enforcement presence in support of those who voluntarily comply with their filing and reporting requirements. Mr. Rettig has been leading efforts to enhance taxpayer experiences operating “through the eyes of the taxpayer.” These efforts include implementation of the multi-year IRS Integrated Modernization Plan and the Taxpayer First Act.

 

Mr. Rettig has held leadership roles in a number of professional organizations, most recently serving as Vice Chair-Administration, for the American Bar Association’s Section of Taxation, and President of the American College of Tax Counsel. He was a member of the IRS Advisory Council (IRSAC) and served as IRSAC’s chair from 2010 to 2011. He also served as Chair of the Taxation Section of the State Bar of California and has served on the advisory boards of both the Franchise Tax Board and the Board of Equalization in his home state of California.

 

He received a B.A. in Economics from the University of California at Los Angeles, as well as a J.D. with honors from Pepperdine University and an LL.M. in taxation from New York University.

MICHAEL DESMOND

Partner, Gibson, Dunn & Crutcher LLP

 

Prior to joining Gibson, Dunn, & Crutcher, Mr. Desmond served as the presidentially-appointed and Senate-confirmed 48th Chief Counsel of the U.S. Internal Revenue Service and as Assistant General Counsel in the U.S. Department of the Treasury, overseeing 1,500 attorneys in 47 offices across the United States. In this role, Mr. Desmond was the chief legal advisor to the Commissioner of Internal Revenue and was involved in all significant guidance and enforcement actions undertaken by Chief Counsel attorneys. During his tenure, Mr. Desmond oversaw the publication of more than 100 sets of proposed and final Regulations, in addition to other published guidance, implementing the 2017 Tax Cuts and Jobs Act (TCJA), the most comprehensive overhaul of federal tax law since 1986. Additionally, Mr. Desmond coordinated Congressional input, as well as provided legal advice, regarding the implementation of three significant pieces of tax legislation enacted in response to the COVID-19 Pandemic.

Caroline D. Ciraolo

Partner, Kostelanetz & Fink, LLP

 

Ms. Ciraolo is the former Acting Assistant Attorney General of the U.S. Department of Justice’s Tax Division and a partner with Kostelanetz & Fink, as well as a founder of the firm’s Washington, D.C. office. Her practice focuses on complex and sophisticated civil tax controversies, including representation in sensitive audits, administrative appeals, and litigation in federal and state courts and administrative tax tribunals, providing related tax advice, conducting internal investigations, consideration of domestic and foreign compliance options including voluntary disclosures, and representing individuals and institutions in criminal tax investigations and prosecutions.

JOHN D. (DON) FORT

Director of Investigations, Kostelanetz & Fink, LLP

 

As Chief of IRS-CI from 2017 to 2020, Mr. Fort led the sixth largest U.S. law enforcement agency, managing a budget of over $625 million and a worldwide staff of approximately 3,000, including 2,100 special agents in 21 IRS field offices and 11 foreign countries. Mr. Fort modernized IRS-CI by developing cutting-edge, data-centric methods of detecting criminal non-compliance through algorithms and other models. Mr. Fort also significantly expanded IRS-CI’s capabilities in cyber-crime and cryptocurrency investigations, and expanded the agency’s international presence and footprint. Mr. Fort led IRS-CI in identifying and investigating over $11.5 billion in tax loss and $14.8 billion in other criminal proceeds.

 

As both Chief and Deputy Chief of IRS-CI, he oversaw numerous high-profile matters, including the college admissions scandal known as “Varsity Blues” that ensnared several celebrities; the Paul Manafort and Michael Cohen federal tax investigations; the Michael Avenatti tax investigation; the takedown of the largest darknet child exploitation website funded by cryptocurrency; two Chinese nationals who were charged with laundering $100 million in the hack of a cryptocurrency exchange; the Swiss Bank Program in which 80 Swiss banks entered into agreements with the government and paid $1.36 billion in penalties; the Federation Internationale de Football Association (FIFA) worldwide money laundering, structuring, and tax evasion matter; the Credit Suisse guilty plea, and many more.

CAROLYN SCHENCK

IRS National Fraud Counsel and Assistant Division Counsel (International)

 

Ms. Schenck is currently National Fraud Counsel and is also Assistant Division Counsel (International) in the Small Business/Self Employed Division. In her role as National Fraud Counsel, Ms. Schenck works closely with the Office of Fraud Enforcement to provide advice on the program’s design, development, and delivery of major activities in support of the IRS’s Service-wide efforts to detect and deter fraud, as well as work with colleagues in all business operating divisions (TEGE, W&I, LB&I) with respect to criminal fraud referrals.

 

In her role as Assistant Division Counsel (International) for the last 12 years, Ms. Schenck has been assigned as counsel to the Service’s Offshore Compliance Initiatives. Ms. Schenck is responsible for coordination and management of all international and offshore tax and Report of Foreign Bank and Financial Accounts (FBAR) matters under the jurisdiction of SB/SE Division Counsel. She ensures that SB/SE attorneys consistently apply law and policy in international and offshore tax and FBAR matters, including non-docketed cases and cases docketed in the U.S. Tax Court, U.S. District Courts, the Court of Federal Claims, and the U.S. Courts of Appeals.

 

Before her law career, Ms. Schenck worked for U.S. Senator John McCain as a weapons analyst. She is a member of the California and Maryland state bars, and holds a J.D. from Pepperdine University School of Law, and a B.S., summa cum laude, from Northern Arizona University.

David Forst

Partner, Fenwick & West LLP

 

David focuses on international corporate taxation. David has been named 2021 Tax Leaders by the International Tax Review’s Tax Leaders Expert Guide. He is included in Euromoney’s Tax Advisors Expert Guides (World’s Leading Tax Advisors, World’s Leading Transfer Pricing Advisors and was named one of the Top 30 U.S. Tax Advisors). He is also in The Legal 500 Hall of Fame and is regularly recognized in the Law and Business Research’s International Who’s Who of Corporate and Tax Lawyers. David is listed in Chambers USA America’s Leading Lawyers for Business, and has been named a Northern California Super Lawyer in Tax by San Francisco Magazine.

 

David is a lecturer at Stanford Law School and UC Berkeley Law School where he focuses on international taxation. He is an editor of and regular contributor to the Journal of Taxation, where his publications have included articles on international joint ventures, international tax aspects of mergers and acquisitions, the dual consolidated loss regulations, and foreign currency issues. He is a regular contributor to the Journal of Passthrough Entities, where he writes a column on international issues. David is a frequent chair and speaker at tax conferences, including the NYU Tax Institute, the Tax Executives Institute, and the International Fiscal Association.

 

David graduated with an A.B. degree, cum laude, from Princeton University’s Woodrow Wilson School of Public and International Affairs, where he was a member of Phi Beta Kappa, and received his J.D., with distinction, from Stanford Law School. David is admitted to practice in California.

DANIEL N. PRICE

Attorney, Office of Chief Counsel of the Internal Revenue Service SB/SE Division (Former)

 

Dan Price’s legal practice focuses on federal tax and Title 31 matters including civil and criminal defense of IRS audits and investigations. Mr. Price also assists taxpayers in navigating the process of coming into compliance, especially international taxpayers who have for one reason or another, failed to comply fully with U.S. tax and Title 31 laws. His deep expertise concerning the IRS’ voluntary disclosure practice, the Streamlined Filing Compliance Procedures, and international penalty regimes allows him craft strategies to mitigate civil penalties and criminal exposure.

 

For over 19 years Mr. Price served as an attorney for the Office of Chief Counsel of the Internal Revenue Service. His prior government service included extensive work in the arena of international enforcement and included assisting the IRS in completely revising the Voluntary Disclosure Practice. Mr. Price also worked with the various Offshore Voluntary Disclosure Programs, the Streamlined Filing Compliance Procedures, foreign bank account reporting, Bank Secrecy Act investigations, various LB&I compliance campaigns, expatriation issues, international collection of taxes, and much more.

 

Mr. Price received his J.D., with honors, from the University of Texas School of Law. While attending law school, he passed the Uniform CPA exam (not licensed as a CPA) and was a staff member on two law journals.

JOSHUA WU

Counsel, Latham & Watkins LLP

 

Joshua Wu, former Deputy Assistant Attorney General (DAAG) for Appellate and Review in the Tax Division of the US Department of Justice (DOJ), counsels and advocates for companies and high net worth individuals on all aspects of tax controversies and litigation.

 

Mr. Wu advises on issues ranging from tax accounting disputes, to corporate and partnership transactional issues, international questions, employee benefits matters, and tax-exempt controversies. He brings a unique knowledge base and skillset to his clients, drawing on his experience both in senior leadership roles in the DOJ’s Tax Division and in private practice.

WILLIAM H. HORNBERGER

Partner, Jackson Walker, LLP

 

Mr. Hornberger is passionate about the practice of law and about helping people and enterprises achieve business goals. He is extremely grateful to his mentors, Larry Bean and Vester Hughes, because they not only taught him to be passionate about the law, they modeled character and class, and taught Mr. Hornberger how to have a rich and fulfilling life outside of the office.

 

For nearly 30 years, Mr. Hornberger has practiced in the areas of tax, transactional, international, and corporate law at Jackson Walker, and he has loved every minute of it! His tax practice has touched nearly every area of the tax law, including corporate, partnerships, and LLCs, international, real estate, corporate, oil and gas, bankruptcy, tax credit, tax controversy, and procedural matters.

 

His broad transactional practice includes mergers and acquisitions, complex partnerships, joint ventures, real estate and private equity arrangements, complicated cross-border business structuring matters involving investors from multiple countries, Tax Treaty, and IRS Competent Authority matters. He has represented taxpayers on tax controversy matters in IRS administrative appeals and before the U.S. Tax Court, the U.S. District Court, the U.S. Bankruptcy Court, the Courts of Appeals for the Fifth and Eleventh Circuits, and the U.S. Court of International Trade.

ERIC L. GREEN

Founding Partner of Greens & Sklarz LLC

 

Mr. Green’s practice focuses on taxpayer representation before the IRS, Department of Justice Tax Division, and state departments of revenue. He is a frequent lecturer on tax topics, including handling tax audits and tax controversies.

 

Mr. Green also has the weekly Tax Rep Network podcast, which can be found on Apple Podcasts, iTunes, Spotify, and all other podcasting platforms. He is the author of The Accountant’s Guide to IRS Collection and The Accountant’s Guide to Resolving Tax Debts: Offers-in-Compromise, Installment Agreements & Uncollectable Status. Mr. Green is the creator, author, and lecturer for the IRS Representation Certificate Program with the University of Connecticut Business School which trains tax professionals to properly represent taxpayers before the IRS. He is a frequent lecturer for national groups, including the AICPA, NATP, ABA, and CCH.

EDUARDO MICHÁN

Partner, Galicia

 

Eduardo is passionate about tax matters. With his advice, clients benefit from invaluable experience obtained from his participation in several complex transactions in different sectors and industries.

He frequently represents commercial and investment banks, private equity funds, pension funds, and international corporations with respect to the tax effects of mergers and acquisitions, financing, and real estate transactions.

Roy Berg JD, LLM

International Tax Lawyer,  Roy Berg International Tax

 

Mr. Berg has more than 28 years’ experience in IRS tax controversy, cross-border tax matters, estate planning, and finance, and has been admitted to the bar associations of the U.S. Tax Court, Alberta, California, Washington, and the United States Supreme Court. He has experience in public accounting, the private practice of law, and as general counsel.

 

Mr. Berg is a fellow of the American College of Trust and Estate Counsel (ACTEC), a member of the U.S. and Canadian Society of Trust and Estate Practitioners (STEP), and the American Bar Association tax section. He is a member of the advisory board to the Journal of International Taxation and a member of the Advisory Council to the International Tax Program of New York University School of Law. Mr. Berg is a frequent writer and speaker on IRS tax controversy, regulation, cross-border tax, and estate planning issues.

 

Mr. Berg received an LL.M in Taxation from New York University School of Law; a J.D., cum laude, from New York University School of Law and Willamette University; and a B.A. in Economics from the University of California Berkeley.

Carla Reyes

Assistant Professor of Law, SMU Dedman School of Law

 

Professor Reyes is an Assistant Professor of Law at SMU Dedman School of Law. An outstanding teacher and distinguished scholar, Professor Reyes is a nationally recognized leader on issues raised by the intersection of business law and technology. Professor Reyes was appointed the Chair of the Texas Work Group on Blockchain Matters in September 2021. The work group is charged with considering policy priorities related to blockchain technology in Texas. Professor Reyes was also named an American Bar Foundation Fellow in June 2021 and named one of the Women of Legal Tech 2020, an honor bestowed by the American Bar Association Legal Technology Resource Center.

Professor Reyes currently serves as the Research Director for the Uniform Law Commission’s Technology Committee, a member of the Digital Asset Working Group of the Joint ALI/ULC Drafting Committee on the Uniform Commercial Code and Emerging Technologies, an Expert Member of the UNIDROIT Work Group on Private Law and Digital Assets, and an Expert Member of the UNIDROIT Work Group on Best Practices for Effective Enforcement.

 

Prior to joining SMU Dedman School of Law, Professor Reyes served Michigan State University College of Law as an Assistant Professor of Law and Director of the Center for Law, Technology & Innovation, and taught Business Enterprises, Technology Transactions, Artificial Intelligence & the Law, and Blockchain Law & Policy. Prior to teaching law, Professor Reyes practiced law as an associate in the Blockchain Technology and Digital Currency industry group at Perkins Coie LLP.

 

A former Fulbright Scholar, Professor Reyes had the opportunity to pursue her research as a Faculty Associate at the Berkman Klein Center for Internet & Society at Harvard University from September 2017-August 2019. Professor Reyes also actively contributes to blockchain technology initiatives at the Stanford CodeX as a RegTrax Curator, MIT’s Cryptoeconomic Systems program, the University College London’s Blockchain Research Centre as a Research Associate, and the American Bar Association.

Michael Quigley

U.S. Lawyer and Tax Partner, Kim & Chang

 

Mr. Quigley has tried more than 50 civil tax cases before the U.S. Tax Court, the U.S. Court of Federal Claims, and many U.S. federal district courts. His tax litigation experience is extensive, and he has been nationally ranked in the United States by Chambers & Partners, has been a master of the Inns of Court, and is frequently called upon to serve as lead tax litigation counsel.

 

Mr. Quigley is a leading authority on intercompany transfer pricing, tax treaties, permanent establishment issues and other tax matters affecting multinational corporations. He has represented clients in obtaining advance pricing agreements with the IRS and the tax authorities of many other jurisdictions including obtaining some of the first APAs between the United States and Korea and Japan. He has appeared before the U.S. Competent Authority and the competent authorities of many other countries including Korea, India, and Japan, among others, and is experienced in the use of the mutual assistance provisions of tax treaties to eliminate double taxation.

 

For many years, Mr. Quigley has studied the economic, business, and political affairs of the Republic of Korea and the Korean Peninsula, with a particular emphasis on U.S.-Korea relations. He has a developed interest in Japan and its relations with the United States and Korea, and with U.S.-India relations, and the political and economic affairs of India. More broadly, Mr. Quigley is keenly focused on U.S. relations with Asia.

Nanette Davis

Senior Litigation Counsel, Department of Justice Tax Division

JONATHAN BARROS VITA

Partner, Gaudêncio Advogados

 

Specialist in tax law by IBET, master’s degree in by PUC-SP and by Bocconi University and PhD at PUC-SP.

Senior visiting research fellow at WU (Wirtschaftsuniversität Wien) – Vienna – Austria.

 

Full professor and Director of the Master’s and PhD programs at UNIMAR.

 

Administrative Tax Judge of the City of São Paulo tax counsel (CMT-SP) and former member of the Tax Tribunal of the state of São Paulo (TIT-SP) and of the Federal Administrative Tax Counsel (CARF).

 

Mr. Vitas was the former Secretary of the Brazilian Bar Association’s (OAB) special commission on tax law.

Mariana Eguiarte

Partner,  Sanchez Devanny

 

Mariana is a tax partner at the law firm Sánchez Devanny Eseverri, S.C., with almost 20 years of professional experience. She has a bachelor’s in law, with honors, from Universidad Panamericana, and is authorized to practice law in Mexico and in the State of New York. Mariana also obtained a Masters in Tax Law from Universidad Panamericana, an LL.M. in International Tax Law from New York University (NYU), and Accounting and Corporate Finance diplomas from ITAM.

 

Mariana is a professor of the course “Income Tax for Foreign Tax Residents” for almost 10 years at the Masters in Tax Law of Universidad Panamericana, and adjunct professor of CPA José Ángel Eseverri Ahuja in the course “Tax Planning” of the same Masters in Tax Law.

 

She is a speaker at diverse national and international congresses, organized by the International Fiscal Association (IFA), American Bar Association (ABA), International Bar Association (IBA), and the New York State Bar Association (NYSBA), among others.

 

From 2019 to 2021, Mariana served as the Chair of the Young IFA Network (YIN) committee for the Mexican branch of IRA. From 2015 to 2019, she served as Vice Chari of the YIN committee for the Mexican branch of IRA, as well as chair-elect of the Latin American Counsel of NYSBA’s International Law Section, and co-chair of the Diversity Committee of NYSBA’s International Law Section.

Mariana is the author and co-author of numerous specialized publications in tax law. She  is recognized by peers and clients as a top tax practitioner in Mexico by such specialized law publications as Chambers and Partners Global, Chambers and Partners Latin America, Legal 500, Best Lawyers, Who’s Who Legal, Leaders League, World Tax, and International Tax Review.

Francisco Noguez

Partner, EY Mexico

 

Mr. Noguez is a Tax Partner of EY Mexico based in Houston, Texas. He is a Mexican Public Accountant with over 12 years of experience advising local companies and multinationals on international tax issues arising in Mexico and other Latin America countries.

 

Mr. Noguez joined EY in 2012 and was promoted to partner in 2019. During his professional career, Mr. Noguez has worked in EY offices located in Mexico City, New York, and Houston. He regularly advises companies doing business in Mexico and Latin America, with an emphasis on cross border transactions, the development of capital structures, and the financing of energy and infrastructure projects, including participating as an advisor in all types of auctions, structured financing and access to capital markets. In addition, he has experience coordinating global tax compliance engagements for multinationals.

 

Additionally, Mr. Noguez worked as a Senior Tax Specialist for Latin America for Qatar Energy Group, a state-owned oil and gas company in the Middle East. There, he supported the execution of the company’s investment plan in the Americas and Portuguese-speaking African countries.

 

Mr. Noguez is the author and co-author of various articles on tax issues and has participated as a speaker at various international tax events.

Karina Robledo

Counsel at Santamarina + Steta

 

Ms. Robledo has more than 18 years of experience with a focus on tax advisory and money laundering prevention. She provides international and domestic tax advice to numerous Mexican and foreign clients. Ms. Robledo actively participates in domestic and foreign corporate reorganizations, reviewing contracts, designing and implementing tax structures for mergers and acquisitions, and project financing transactions.

 

Her practice also includes tax examinations and settlement negotiations with the tax authorities, as well as tax treaty issues including double taxation, tax residency, and permanent establishment questions. Ms. Robledo has extensive experience handling expatriates’ issues. Additionally, Ms. Robledo advises companies with tax issues arising from insolvency and bankruptcy proceedings.

Raúl Villarreal Garza

Partner, Procopio, Cory, Hargreaves & Savitch LLP

 

Mr. Garza advises clients on a variety of matters related to international tax law. He participates as an international tax advisor to business leaders expanding their foreign operations into the United States. Mr. Garza has extensive experience counseling families with multiple nationalities on their international estate planning needs and is a trusted advisor to family offices in a wide range of tax and legal issues.

Niles Elber

Member, Caplin & Drysdale

 

Niles A. Elber, a Member in Caplin & Drysdale’s Washington, D.C., office, has more than 20 years of experience representing clients in civil and criminal tax controversies. His practice is broad, ranging on the civil side from IRS examinations, Appeals matters, collections and proceedings in federal court while on the criminal side handling both administrative and grand jury tax investigations.  With considerable experience in offshore compliance matters for U.S. taxpayers, Mr. Elber has assisted hundreds of clients with their voluntary disclosures and income tax and FBAR penalty exams related to unreported foreign bank accounts.

 

Mr. Elber is particularly focused these days on defending clients who find themselves caught up in aggressive IRS campaigns against alleged abusive tax shelters and transactions. Most recently, he represented a defendant in one of the largest and most significant tax cases brought by the U.S. Department of Justice in the “conservation easement” area.

 

Mr. Elber lectures regularly on matters involving tax controversies and co-authored the BNA Portfolio Report of Foreign Bank and Financial Accounts (FBAR). He is a Fellow of the American College of Tax Counsel (ACTC), an honor reserved for those at the top of their profession. Mr. Elber is a past chair of the ABA Tax Section Civil and Criminal Tax Penalties Committee, serving from 2017 until 2019.  Prior to that, he served as a vice-chair on the same committee for five years. Mr. Elber is also a former ABA Nolan Fellow, which honors a select group of outstanding young tax lawyers from across the nation who have shown significant contribution, service, and leadership.

Melissa Wiley

Member, Caplin & Drysdale

 

Melissa L. Wiley is a Member in Caplin & Drysdale’s Washington, D.C. office. Ms. Wiley’s practice focuses on assisting clients to come into compliance with their U.S. tax obligations and advising U.S. taxpayers on all types of civil and criminal tax controversy matters at the federal and state level.

 

Prior to joining the firm, Ms. Wiley was a Senior Manager in the National Tax Department at a Big Four accounting firm, where she specialized in tax controversy. In addition to serving clients, Ms. Wiley served as a firm subject matter expert on a variety of tax controversy topics and regularly spoke on firm webinars, and taught classes to colleagues and clients. With that firm she also served as internal counsel, providing legal guidance on a variety of matters related to the firm’s tax practice. Prior to that, Ms. Wiley was a tax controversy attorney at an international law firm, where she represented clients in federal and state controversy matters, including taking three cases through trial. Ms. Wiley previously worked as an analyst in the insurance industry before attending Georgetown University Law Center.

 

Ms. Wiley is active in tax professional organizations, including the AICPA and the ABA Tax Section, where she currently serves as Vice Chair for Committee Operations.  She is also dedicated to assisting local children and caretakers through the Children’s Law Center, where she serves on the board and has provided pro bono services for more than 15 years.

Rosy Lor

Managing Director, BDO National Tax Office/Private Client Services

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Rosy Lor is a Managing Director in the BDO National Tax Office/Private Client Services. Prior to joining BDO, she was a Senior Manager in the EY Private National Tax Department. Before entering the private sector, she spent over 13 years with the IRS Office of Chief Counsel, where she last served as the Senior Technical Reviewer of Branch 1 of the Office of Associate Chief Counsel (International) focusing on issues related to tax treaties, the inbound taxation of foreign corporations, and cross-border tax issues affecting individuals.​

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Ms. Lor’s areas of expertise include pre-immigration and expatriation tax planning, the interpretation of tax treaties and other international agreements, tax controversy, and voluntary disclosure.​

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She received her Master of Laws in Taxation from the Georgetown University Law Center and her Juris Doctor from the American University, Washington College of Law.

Olga Torres

Managing Member, Torres Trade Law

 

Olga Torres is the Founder and Managing Member of Torres Trade Law, PLLC an International Trade and National Security Law Firm. Ms. Torres handles notable trade and national security matters for numerous companies worldwide and specializes in the areas of U.S. customs, exports, economic sanctions, anti-corruption compliance, and industrial security matters.

 

In the area of customs, Ms. Torres advises clients on import compliance matters, including customs rulings, classification, country of origin, special duty programs, focused assessments, C-TPAT, and seizures of goods by U.S. Customs and Border Protection. She also assists with antidumping/countervailing duty matters before the Import Administration of the U.S. Department of Commerce. In the area of U.S. export control, Ms. Torres counsels clients on compliance with the International Traffic in Arms Regulations (ITAR), the U.S. Export Administration Regulations (EAR), and the various embargo and sanctions programs administered by the Office of Foreign Asset Controls (OFAC). She regularly represents clients before the U.S. Department of State Directorate of Defense Trade Controls (DDTC), U.S. Department of Commerce Bureau of Industry and Security (BIS), and the U.S. Department of the Treasury.

 

Throughout her career, Ms. Torres has been selected for recognition in multiple attorney ranking guides and publications including in Chambers and Partners USA and Global (2022, 2021, 2019, 2018), Who’s Who Legal (2017-2022), and SuperLawyers Rising Stars (2015-2018). Ms. Torres was awarded the Global Attorney of the Year by the Dallas Global Chamber in 2018. In 2019 and 2020, she was nominated for Compliance Lawyer of the Year at the Women in Compliance Awards in London, United Kingdom. Prior to founding Torres Trade Law, she was an attorney in the International & Cross Border Transactions group at an Am 100 Law Firm in Washington, D.C.

 

Ms. Torres was recently reappointed by the U.S. Assistant Secretary of State to the Defense Trade Advisory Group (DTAG). In this capacity, she advises the Bureau of Political-Military Affairs, which is the U.S. Department of State’s principal link to the Department of Defense, on its regulation of defense trade in accordance with the Arms Export Control Act and its implementing regulations under the International Traffic in Arms Regulations. Ms. Torres was also recently appointed to the North Texas District Export Council by the Acting Deputy Assistant Secretary and National Director on behalf of the U.S. Department of Commerce.

 

Ms. Torres is a frequent speaker and moderator. She has lectured on international trade for organizations, universities, and government agencies in different countries, including the United Kingdom, the Netherlands, Mexico, Thailand, France, and Canada. She is licensed to practice law in Washington, D.C., the State of Texas, Pennsylvania, and the U.S. Court of International Trade.

Sandra R. Brown

Principal, Hochman Salkin Toscher Perez P.C.

 

Ms. Brown’s practice focuses on individuals and organizations who are involved in criminal tax investigations, including related grand jury matters, court litigation and appeals, as well as representing and advising taxpayers involved in complex and sophisticated civil tax controversies, including representing and advising taxpayers in sensitive-issue audits and administrative appeals, as well as civil litigation in federal, state and tax court.

 

Ms. Brown previously served as the First Assistant United States Attorney for the Central District of California.

William Byrnes

Executive Professor of Law, Texas A&M University School of Law

 

Professor Byrnes is leading tax authority with nine Lexis treatises and compendia, and co-author with Robert Bloink of Tax Facts books. His nine Lexis titles are: Tax of Oil & Gas Transactions; LexisNexis Guide to FATCA & CRS Compliance; Practical Guide to U.S. Transfer Pricing; Money Laundering, Asset Forfeiture and Recovery, and Compliance–A Global Guide; Taxation of Intellectual Property and Technology; Foreign Tax and Trade Briefs; Tax Havens of the World; Texas Estate Planning; and International Withholding Tax Treaty Guide.

 

Professor William Byrnes has written over 1,000 media and published articles. After peer review, the National Press Club (Washington, D.C.) voted to admit him as a journalist. In July 2014, he was further recognized when appointed the co-editor of the International Financial Professor Law Blog for the Law Professor Blogs Network. “In the field of international tax, Prof. William Byrnes is among LexisNexis’s best-selling authors and a leading authority in the fields of anti-money laundering and FATCA compliance.” Ray Camiscioli, Esq., Director, Product Strategy & Development for Tax, Accounting and Estates/Elder Law, LexisNexis, Inc.

Frank Agostino, Esq.

Founder and President, Agostino & Associates

 

Frank Agostino is the founder and president of Agostino & Associates, P.C. Prior to entering private practice, Mr. Agostino was an attorney with the Internal Revenue Service’s District Counsel in Springfield, Illinois and Newark, New Jersey. He also served as a Special Assistant United States Attorney, where he prosecuted primarily criminal tax cases. As an adjunct professor, Mr. Agostino taught tax controversy at Seton Hall University W. Paul Stillman School of Business and Rutgers School of Law. He also served as the co-director of the Rutgers Federal Tax Law Clinic.

 

Mr. Agostino is a frequent speaker and author on tax controversy and litigation matters. He serves on the Advisory Board of the Journal of Tax Practice and Procedure. Mr. Agostino is actively involved with the American Bar Association and the New York County Lawyers’ Association. Mr. Agostino is also the President of Taxpayers Assistance Corp., which provides tax and legal advice to low income taxpayers in the NY/NJ area.

Annette Nellen, CPA, CGMA, Esq.

Professor and Director, San José State University Graduate Tax Program

 

Annette Nellen, CPA, CGMA, Esq., is a professor in and director of San José State University’s graduate tax program (MST), teaching courses in tax research, accounting methods, property transactions, high tech tax matters, employment tax, ethics, and tax policy.

 

Professor Nellen served on the AICPA Tax Executive Committee for over six years (chair from October 2016 to May 2019). She is a past chair of the AICPA Individual Taxation Technical Resource Panel. Professor Nellen was the lead author of the AICPA tax policy concept statement #1, Guiding Principles of Good Tax Policy: A Framework for Evaluating Tax Proposals (2001, updated 2017), still in use today. Professor Nellen is the recipient of the 2013 Arthur J. Dixon Memorial Award given by the Tax Division of the AICPA, the highest award given by the accounting profession in the area of taxation. In fall 2013, Professor Nellen completed a three-year term on the Executive Committee of the Taxation Section of the California Bar. She was the first co-chair of the CA Bar Tax Section’s Women in Tax Committee. Prof. Nellen is the recipient of the 2019 Benjamin F. Miller Award from the Taxation Section of the California Lawyers Association for achievement and contribution in the filed of state and local taxation law. She is a former chair of the ABA Tax Section’s Sales, Exchanges & Basis Committee.

Ruben D. Valdes EA, USTCP

Founder, Tax Professionals of Austin

 

Ruben D. Valdes, EA, USTCP specializes in representing taxpayers before examinations, collections, and appeals before the Internal Revenue Service. In addition, Mr. Valdes is also admitted to practice before the United States Tax Court; a privilege earned by less than 300 non-attorneys in the United States.

 

Mr. Valdes is also a national tax instructor; he understands the importance of high-level education in the profession. One of his missions is to teach taxpayers and other professionals the “Taxpayer Bill of Rights”; so every taxpayer gets fair and just treatment, as the tax law intends.

Arnold A. Spencer

Managing Partner, Spencer & Associates

 

Arnold A. Spencer has successfully represented clients in a wide range of white-collar criminal matters in federal courts around the country, including securities, commodities and financial frauds, money laundering, health care, and environmental fraud, as well as asset forfeiture. Mr. Spencer is qualified to handle all types of federal white-collar criminal cases and advises cryptocurrency companies in regulatory compliance.

 

Mr. Spencer has professional experiences as a financial analyst with an elite investment bank in New York City, as a federal prosecutor handling white-collar criminal matters in Texas and in partnership positions with national law firms. He has represented corporations, executives, and governmental entities in criminal and civil litigation.

 

Previously an Assistant United States Attorney in the Eastern District of Texas, Mr. Spencer’s legal focuses included securities fraud, financial fraud, and anti-money laundering concerns. As a prosecutor, he prosecuted more than 100 federal cases, was a trial lawyer who prosecuted criminal violations associated with the Enron fraud scandals and has taken on many other high-profile cases. He has been a nationally known and active speaker, author, and advisor on white-collar criminal developments.

 

Mr. Spencer graduated from the University of Texas Law School and Amherst College. He serves on several non-profit boards for local and national educational institutions and is a leader at his local church.

Kent Stackhouse

International Tax and Transfer Pricing Partner, EY

 

Kent Stackhouse advises multinational clients in the areas of federal and international tax dispute resolution and tax planning, with an emphasis on transfer pricing. A significant part of his practice involves advance pricing agreements, mutual agreement procedure negotiations, and transfer pricing documentation. Mr. Stackhouse also has a background in corporate tax planning for domestic and international transactions, including post-acquisition restructurings.

Pedro Corona

Partner, Procopio, Cory, Hargreaves & Savitch

 

Pedro Corona advises clients in international estate planning, international tax, and cross-border mergers and acquisitions. He focuses on U.S. investment structures, cross-border transactions, tax treaty planning, withholding obligations, and reporting compliance on international transactions. The leader of Procopio’s International Tax practice, Mr. Corona brings his clients experience in assisting clients and closely held companies with cross-border transactions involving the U.S., Mexico, and other Latin American countries. He is a frequent speaker on international tax topics and recent tax developments affecting cross-border investments from and into Latin America.

MATTHEW L. ROBERTS

Principal, Freeman Law

 

Mr. Roberts is a Principal with Freeman Law, PLLC. He devotes a substantial portion of his legal practice to helping his clients successfully navigate and resolve their federal tax disputes, either administratively, or, if necessary, through litigation. As a trusted advisor he has provided legal advice and counsel to hundreds of clients, including individuals and entrepreneurs, non-profits, trusts and estates, partnerships, and corporations.

 

Having served nearly three years as an attorney-advisor to the Chief Judge of the United States Tax Court in Washington, D.C., Mr. Roberts leverages his unique insight into government processes to offer his clients creative, innovative, and cost-effective solutions to their tax problems. In private practice, he has successfully represented clients in all phases of a federal tax dispute, including IRS audits, appeals, litigation, and collection matters. Mr. Roberts also has significant experience representing clients in employment tax audits, voluntary disclosures, FBAR penalties and litigation, trust fund penalties, penalty abatement and waiver requests, and criminal tax matters.

FERNANDO JUAREZ

Attorney, Freeman Law

 

Fernando Juarez, LL.M. EA, is an International Tax Principal with Freeman Law. He advises on complex U.S. and international tax planning. His practice focuses on domestic and cross-border transactions. Additionally, he is experienced in voluntary disclosures, FBAR, and international compliance.

 

Fernando’s expertise in tax planning extends to Fortune 500 companies, family offices, and medium and small businesses. His primary areas of expertise include inbound structures for international investors and outbound tax planning for U.S. based companies. He is a frequent speaker at conferences involving tax topics in the U.S. and around the world. Recent speaking engagements include the Organization for the Economic Cooperation and Development (OECD) in Paris, France; the Tax Executives Institute in Houston, the Start Up Week in San Antonio and the Hispanic Chamber of Commerce in Texas. Fernando has published multiple tax articles with international editors such as Thomson Reuters and the International Bureau of Fiscal Documentation (IBFD) in the Netherlands.

 

Fernando received his law degree from the Escuela Libre de Derecho in Mexico City and holds a Master’s in Laws from Stanford Law School, where he served as the first Hispanic Chair of the Stanford Tax Club. He is licensed to provide tax advice in the U.S. and Mexico.

 

Currently, he is a National Reporter for the Observatory for the Protection of Taxpayer’s Rights by the IBFD. Until 2020, he was serving as the Secretary of the International section of the San Antonio Bar Association

TL FAHRING

Attorney, Freeman Law

 

Mr. Fahring focuses on helping individuals and businesses with a wide variety of matters involving state, federal, and international taxation. He has represented clients in all stages of federal and state tax disputes, including audits, administrative appeals, litigation, and collection matters. Mr. Fahring also uses his tax knowledge to assist clients in planning complex domestic and international transactions, including advising as to potential reporting and withholding requirements.

STEPHANIE URIBE

International Tax Consultant, Freeman Law

 

Ms. Uribe is Freeman Law’s international tax consultant with more than a decade of professional experience in Mexican taxation and international tax advisory matters.  She maintains a particular focus on acquisitions (including due diligence), transfers, mergers, spin-offs, and various corporate reorganizations. Ms. Uribe is experienced with cross-border transactions, including advising clients with respect to federal and state tax obligations in Mexico; the application of international tax treaties and the avoidance of double taxation, including permanent establishment status; complex international tax strategies; expatriate compensation plans; and tax audits.

 

Ms. Uribe received her law degree from the Facultad Libre de Derecho de Monterrey, in Monterrey, Mexico, where she graduated with honors, and she holds a Master’s in Law in International Taxation from Vienna University of Economics and Business (WU), in Vienna, Austria. For her Master Thesis, Ms. Uribe published the article “Taxation of Capital Gains: The Substantial Participation Clause in Article 13(5)” in Special Features of the UN Model Convention. Ms. Uribe is licensed to practice law in Mexico.

 

Ms. Uribe is a member of the International Fiscal Association and has participated as a speaker in several Mexican and international tax conferences. She holds a certification in Management from the Harvard Business School’s ManageMentor Program.

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