The Freeman Law
International Tax Symposium
Join leading tax experts from across the globe, as we discuss tax trends that are reshaping international taxation
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.
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 2021 and beyond. Learn from recognized leaders, as we discuss:
- Global Tax Reform
- International Civil Penalty Enforcement
- International Criminal Tax Enforcement
- The Untold Story of Swiss Bank Secrecy and a
revolutionary Era of International 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 immediate past Chief Counsel of the IRS and a former Assistant General Counsel in the U.S. Department of the Treasury. Mr. Desmond is currently a partner in the Los Angeles and Washington, DC offices of Gibson, Dunn & Crutcher and a member of the Firm’s Tax Practice Group.
Prior to joining Gibson Dunn, 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 around the United States. In this role, he was the chief legal advisor to the IRS Commissioner and was involved in all significant guidance and enforcement actions undertaken by Chief Counsel lawyers. During his tenure, he 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. He also coordinated input to Congress on and provided legal advice regarding the implementation of three significant pieces of tax legislation enacted in response to the pandemic.
Caroline D. Ciraolo
Former Acting Assistant Attorney General of the U.S. Department of Justice’s Tax Division
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.
Sandra R. Brown
Served as First Assistant United States Attorney for the Central District of California
Judge Travis A. Greaves
Judge of the United States Tax Court
Guinevere M. Moore
Chair of the Standards of Practice Committee of the Section of Taxation
Ms. Moore has represented taxpayers throughout her career, and draws on her experience in working with her clients, with the IRS, and with opposing counsel to help craft and execute the best possible plan to resolve the issues her clients are facing. Ms. Moore has successfully defended taxpayers against assessment of all types of federal tax, including income tax, employment tax, estate tax, gift tax, civil penalties, and criminal penalties.
Member of the Academic Committee of the Brazilian Institute of Tax Law
Bruna is a specialist in tax law, more specifically on the provision of consultancy related to direct taxes and international taxation. Her practice mostly consists of the structuring of investments acquisition in Brazil, corporate reorganizations, analysis of tax impacts arising from alternatives for raising funds and financial and capital markets’ transactions, in addition to the provision of support on the identification of the different models adopted in infrastructure projects.
Augusto Lara dos Santos
Partner, Lara & Associados
Founding partner of the law firm LARA & COELHO Advogados Associados, he is an enthusiast of Tax Law, an area he has been dedicated to since his first year of college. He taught at renowned Universities and worked in traditional law firms and multinational companies, deepening his tax knowledge. He expanded his activities to related matters – such as Customs, Shipping and Port Law – which enables him to offer unparalleled advisory and litigation advice in the sector.
Attorney in the IRS Office of Associate Chief Counsel (International)
Daniel de Paiva Gomes
Cryptolaw and Tax Partner of Vieira, Drigo, Vasconcellos e Paiva Gomes Law Firm
Bradley C. Birkenfeld
Former private Swiss banker and recipient of the largest whistleblower award in IRS history
John D. (Don) Fort
Director of Investigations, Immediate past Chief of the IRS’s Criminal Investigation (CI) Division
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.
Former IRS Commissioner of the Small Business/Self Employed Division; alliantgroup National Director of Compliance
Hylton held several prominent positions at the IRS, including serving as Deputy of the Criminal Investigation Division and as CI’s head of International Operations. In his most recent role as IRS Commissioner, Small Business/ Self-Employed Division, Hylton oversaw a nationwide staff of approximately 20,000 employees who were responsible for taxpayer programs and services that directly impacted American SMBs. As National Director of Compliance for alliantgroup, Mr. Hylton employs his years of experience at the IRS to assist clients as an ambassador for U.S. small and medium sized businesses (SMBs) and in helping others become tax compliant.
Managing Director at KPMG US
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.
Raúl Villarreal Garza
Currently, he is the Chair of the International Tax Committee of the California Lawyers Association (formerly, The California Bar Association). He is a professor of the course of International Estate Planning at the University of San Diego School of Law.
David Matos, CPA, CFA, CISA
Founder of Matos & Jawad PLLC. Specialized in International Tax Compliance
Mr. Matos was previously the Finance Director at Nabors Industries and acted as the Country Controller at Pride International and Latin America Controller at Tetra Technologies. He holds a bachelor’s degree in Accounting and Master’s in professional accountancy from Florida State University.
Amanda Barraza de Wong
Recognized International Tax Practitioner at Prestigious Panamanian law firm, Morgan & Morgan.
Her practice includes advising companies and individuals in matters regarding to the Panamanian tax system, including special tax regimes. Additionally, she has experience handling administrative procedures before tax authorities, tax litigation, tax planning, expat´s tax compliance assessment, regional operation efficiency assessment, corporate tax compliance assessment, custom taxes and international taxation.
Enrique worked for ten years in the Mexican government in the areas of tax, finance and administration, acting as Subprocurador Fiscal de la Federación (Under Fiscal Federal General Attorney) in charge of consultation and legislative issues, Director General Jurídico (Legal General Director) of IPAB (Mexico’s Bank Deposit Insurance Federal Authority) and Director Jurídico (General Counsel) of FIDELIQ.
Enrique is a past chair of the International Law Section and of the International Tax Committee of the Tax Section of the California State Bar and of the International Law Section of the San Diego Bar Association. He is a member of the Practice Council for NYU’s School of Law’s LLM in International Tax and of the Council for the Center for US- Mexican Studies of the University of California in San Diego.
A Master of Laws in international taxation from the University of Florida
She is the founding partner of Parodi Consultores, an advisory firm that offers tax and legal services in Chile. Previously she worked in PwC Chile – Santiago Office and Baker & McKenzie Chile.
Bernardita has over 10 years of experience in tax and legal consulting services, focusing her practice on international taxation.
Frank Agostino, Esq.
Former Attorney with the Internal Revenue Service’s District Counsel
Partner, Basham, Ringe Y Correa, S.C
He is a professor to different universities in Mexico in relation to Tax, International Taxation and Tax Treaties and a member of various professional associations such as the International Fiscal Association, the Mexican Bar Association, and the International Tax Committee of the Mexican Institute of Public Accountants. His practice areas include among others International Taxation, Tax Planning, Corporate Taxation, Partnership Taxation, Estate Tax, among others. Languages: Spanish, English, and Portuguese.
Brian C. McManus
Chair of Latham & Watkins’ Boston Tax Department
Victor A. Jaramillo
Member, Caplin & Drysdale Washington, D.C.
Mr. Jaramillo’s major areas of practice include subpart F, tax treaty issues and competent authority proceedings, FATCA entity classification and compliance, withholding and information reporting, financial products, and individual compliance.
Mr. Jaramillo also advises on the international tax issues of high-net-worth clients with respect to pre-immigration and structuring cross-border investments. He has extensive experience advising both U.S. taxpayers and individuals living abroad with undisclosed foreign assets on U.S. tax compliance issues, especially those with foreign business and trust interests.
The Honorable Julian Alfonso Olivas Ugalde
Magistrate Judge of the Federal Court of Administrative Justice of Mexico.
As a Magistrate Judge of the Superior Chamber of the Federal Court of Administrative Justice in Mexico, (the equivalent of the U.S. Tax Court), Magistrate Judge Olivas rules on the most select and complex federal tax and administrative cases in Mexico.
Magistrate Judge Olivas was appointed to the bench by the President of Mexico and was ratified by the Mexican Senate in 2015. Prior to his appointment, he acted as the Under Secretary of Administrative Responsibilities and Government Procurement within the Federal Department of Public Accounts. He has held several relevant public offices within the Executive, Legislative, and Judiciary branches. Among others, he has acted as the Deputy Director of Resources for the Department of the Treasury, the Executive Secretary of Services for the Supreme Court of Mexico, Vice-president of the National Insurance Commission, and Deputy advisor to the Federal Tax Attorney’s Office.
Daniel N. Price
Attorney, U.S. Department of Treasury; Office of Chief Counsel of the Internal Revenue Service (SB/SE Division)
Daniel N. Price is an attorney with the Office of Chief Counsel of the Internal Revenue Service (SB/SE Division) in Austin, Texas. Dan advises the IRS on national issues relating to Offshore Voluntary Disclosure Programs and the Streamlined Filing Compliance Procedures. His role in these special compliance initiatives includes planning, developing, and writing FAQs for public guidance, developing new forms, speaking at practitioner events, training and advising IRS personnel, developing job aids and templates, and much more.
Dan has a tax litigation background and also handles complex cases involving tax fraud and willful FBAR violations. Dan received an undergraduate degree in accounting, summa cum laude, from the University of Texas at San Antonio, and a master’s degree in accounting from Trinity University. Dan received his J.D., with honors, from the University of Texas School of Law. During the first year of law school, Dan passed the Uniform CPA exam (not licensed as a CPA).
Partner in the Federal & International Tax Group | Alston & Bird
Laura focuses her practice on the business dealings and asset holdings of U.S. taxpayers abroad. She has extensive knowledge of the IRS’s international exchange-of-information techniques, including treaty requests and other methods of cross-border cooperation among taxing authorities.
Michael A. Villa, Jr.
Meadows, Collier, Reed, Cousins, Crouch & Ungerman, LLP
Prior to joining the firm in 2007, Mike worked in Washington, D.C. as a Congressional intern to U.S. Senator John Breaux (Retired) and worked as an Associate with a regional law firm in New Orleans, Louisiana. In 2004-2005, he served as a Judicial Clerk to the Honorable James J. Brady, U.S. District Court, Middle District of Louisiana.
Mike was admitted to practice in Texas in 2005 and in Louisiana in 2004.
Kostelanetz & Fink, LLP
Mr. Russell advises clients on domestic and international tax reporting and transactional analysis. He has assisted clients in navigating the international tax provisions of the Tax Cuts and Jobs Act, including the effect of implementing regulations and administrative guidance for Global Intangible Low-Taxed Income (GILTI), Base Erosion Anti-Abuse Tax (BEAT) and Foreign-Derived Intangible Income (FDII), as well as corporate conversions and the IRC 199A pass-through provisions. Mr. Russell also handles tax controversy matters involving international information tax reporting, captive insurance arrangements, and digital currency transactions.
Mr. Russell served as visiting counsel for the Joint Committee on Taxation (JCT), where he advised staff on potential tax legislation and arranged materials for congressional hearings related to taxation. In April 2016, he testified before the House of Representatives Small Business Committee on the international aspects of tax simplification and reform.
Principal, Freeman Law, PLLC
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. He 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.
William H. Hornberger
William H. Hornberger Partner, Jackson Walker, LLP
William 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 also modeled for him character and class and taught him how to have a rich and fulfilling life outside of the office. For nearly 30 years, he has practiced in the areas of tax, transactional, international and corporate law at Jackson Walker and 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 and tax controversy and procedural matters.
His broad transactional practice includes mergers and acquisitions, complex partnership, joint venture, 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.
Senior Tax lawyer, Santamarina & Steta
Stephanie earned her law degree from the Facultad Libre de Derecho de Monterrey, Mexico, and holds a Specialization in Tax Law and a Diploma in Finance for Lawyers from the Instituto Tecnológico Autónomo de México, in Mexico. She also holds a Diploma in Business Management from Harvard Business School, a Diploma in Accounting for Non-accountants from the Instituto Tecnológico Autónomo de México, in Mexico City and an LL.M. in International Taxation at WU (Vienna University of Economics and Business), in Vienna, Austria.
IRS Director of the Office of Fraud Enforcement
As the Director of the Office of Fraud Enforcement, Damon Rowe provides IRS service-wide leadership and guidance related to the development and delivery of significant activities in support of IRS’ efforts to detect and deter fraud. This encompasses focusing on taxpayers and professional enablers’ unethical actions that undermine our Federal Tax Laws and address emerging threats related to fraudulent filings and related activities. In this position, he also acts as the principal advisor and consultant to IRS Division Commissioners and Deputy Commissioners on all issues involving fraud enforcement strategic plans, programs, and policy.
Mr. Rowe began his IRS career in 1998 in Criminal Investigation (CI) as a Special Agent in Los Angeles, CA. Since then, he has held positions with increasing responsibility, including serving as a Senior Analyst in the Narcotics and Counterterrorism section and a Supervisory Special Agent in the Dallas Field Office (2007 – 2011). In late 2011, Mr. Rowe was promoted to Assistant Special Agent in Charge for the New Orleans Field Office. In January 2014, he was promoted to Special Agent in Charge of the Dallas Field Office and subsequently returned to Los Angeles as the Special Agent in Charge in April 2017.
In January 2019, Mr. Rowe served as the Executive Director of International Operations for IRS CI headquartered in Washington, DC. In this role, he was responsible for international law enforcement cooperation between foreign governments and CI field offices as it related to investigating potential criminal violations of the Internal Revenue Code and related financial crimes.
IRS National Fraud Counsel and Assistant Division Counsel (International)
Before her law career, Carolyn worked for U.S. Senator John McCain and 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.
Mr. Gomez represents clients in administrative and policy matters before the U.S. Department of the Treasury and the Internal Revenue Service, including commenting on regulations, tax treaties and other tax policy issues, and in connection with applications for private letter rulings and pre-filing agreements.
He advises clients on legislative matters, including commenting on proposed legislation, developing strategies for new legislative proposals and representing clients before the congressional tax writing committees. He also represents clients in connection with congressional investigations, including in the largest-ever congressional investigation of a single corporate taxpayer.
In recent years, Mr. Gomez’s transactional practice has focused on representing developers and investors in connection with various renewable energy projects. He also advises clients on structuring and financing other partnerships and joint ventures.
Annette Nellen, CPA, CGMA, Esq.
Professor and Director, San José State University Graduate Tax Program
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.
Internal Revenue Service, Associate Chief Counsel (International)
Prior to joining the Office of Chief Counsel, Brad was an international tax associate at a Chicago law firm. He is admitted to practice in Illinois and is also a Certified Public Accountant (Registered).
J.D., University of Notre Dame
Fernando’s expertise in tax planning extends to Fortune 500 companies, family offices and medium & 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 on 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.
Global Head of Transfer Pricing Dispute Resolution Services | KPMG
Prior to joining KPMG, Sean was the Director of the IRS Advance Pricing Agreements (APA) Program, an alternative dispute resolution procedure for international transfer pricing issues. In this role, Sean regularly met with foreign competent authorities to discuss APA related issues and was the principle reviewer of all of the APA’s and the US’s negotiating positions. Sean clerked for Justice Ruth Bader Ginsburg when she served on the US Court of Appeals; and served as legislative director to Congressman Sander Levin, currently the ranking member of the House Ways and Means Committee.
He has an LL.M. in Taxation (with distinction) and a J.D. (summa cum laude) from the Georgetown University Law Center. Sean has served as an adjunct law professor in the LL.M. programs at Georgetown and the University of Florida. He is the past chair of the American Bar Association Transfer Pricing Committee.
Alejandro H. Calderón
Calderón, González y Carvajal, S.C.
He has advised and litigated complex cross-border transactions and tax treaty issues. In 2011 he won the first case before the Supreme Court involving fundamental rights of taxpayers.
He is co-author of the following books: International treaties to avoid double taxation; Introduction to international taxation; Interpretation of tax treaties; and Transfer pricing, a theoretical, legal and practical framework, among others.
He is a member of the Executive Committee of IFA Mexico and former chairman of the Scientific Committee. He is also an active member of the Tax Committee in the Mexican Bar, IBA and Academy of Tax Studies.
He has been mentioned as a leading tax practitioner by the International Tax Review and Chambers and Partners Latin America.
Christopher H. Hanna
Counsel, Baker McKenzie
From June 2000 until April 2001, he assisted the US Joint Committee on Taxation in its complexity study of the US tax system and, from May 2002 until February 2003, he assisted the Joint Committee in its study of Enron, and upon completion of the study, continued to serve as a consultant to the Joint Committee on tax legislation.
From May 2011 until December 31, 2018, he served as Senior Policy Advisor for Tax Reform (Republican staff) to the United States Senate Committee on Finance, working extensively on the Tax Cuts and Jobs Act of 2017.
Jason B. Freeman
Founding Member of Freeman Law, PLLC
Mr. Freeman has been named by Chambers & Partners as among the leading tax and litigation attorneys in the United States and to U.S. News and World Report’s Best Lawyers in America list. He is a former recipient of the American Bar Association’s “On the Rise – Top 40 Young Lawyers” in America award. Mr. Freeman was named the “Leading Tax Controversy Litigation Attorney of the Year” for the State of Texas for 2019 and 2020 by AI.
Mr. Freeman has been recognized multiple times by D Magazine , a D Magazine Partner service, as one of the Best Lawyers in Dallas, and as a Super Lawyer by Super Lawyers, a Thomson Reuters service. He has previously been recognized by Super Lawyers as a Top 100 Up-And-Coming Attorney in Texas.
Mr. Freeman currently serves as the chairman of the Texas Society of CPAs (TXCPA). He is a former chairman of the Dallas Society of CPAs (TXCPA-Dallas). Mr. Freeman also served multiple terms as the President of the North Texas chapter of the American Academy of Attorney-CPAs. He has been previously recognized as the Young CPA of the Year in the State of Texas (an award given to only one CPA in the state of Texas under 40).
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