The Freeman Law

International Tax Symposium

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

November 18th & 19th, 2021

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”)

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 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

    Michael Desmond

    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

    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.

    Judge Travis A. Greaves

    Judge of the United States Tax Court

    Judge Greaves is a Judge of the United States Tax Court. Prior to his appointment, Judge Greaves served as Deputy Assistant Attorney General for Appellate and Review in the U.S. Department of Justice’s Tax Division. Before joining the Department of Justice, he was an attorney with Greaves Wu LLP; Caplin & Drysdale, Chartered; and Reed Smith, LLP. Earlier in his career, Judge Greaves served as an adjunct professor at Georgetown University Law Center and as an attorney advisor at the U.S. Tax Court. He previously served as Tax & Economic Policy Advisor for the Office of Governor Bobby Jindal of the State of Louisiana. He received his B.A. from the University of Tennessee, his J.D., cum laude, from South Texas College of Law, and an L.L.M. in Taxation, with distinction, from Georgetown University Law Center.

    Guinevere M. Moore

    Immediate Past Chair of the Standards of Practice Committee of the Section of Taxation

    Guinevere Marie Moore is a tax litigator who represents taxpayers in civil and criminal tax controversies. She advocates for taxpayers at the IRS examination and appeals levels and, if a settlement with the IRS cannot be reached, in litigation. She is also the Executive Director of US Partnership Representative, Inc., and in that role she serves as a professional partnership representative.

    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.

    Bruna Marrara

    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.

    Michelle Phillips

    Attorney in the IRS Office of Associate Chief Counsel (International)

    Ms. Phillips advises the IRS on a variety of issues, including in particular treaty-based exchange of information. She also works with the IRS and FinCEN on beneficial ownership rules relating to IRS reporting and the recently enacted Corporate Transparency Act. Prior to joining the government, she practiced with Baker McKenzie for more than 7 years. Her work took her between Washington, D.C., and Switzerland, advising banks and individuals on the DOJ Swiss Bank Program and its fallout. She also has extensive experience with FATCA and in other tax controversy matters, including transfer pricing.

    Daniel de Paiva Gomes

    Cryptolaw and Tax Partner of Vieira, Drigo, Vasconcellos e Paiva Gomes Law Firm

    Cryptolaw and Tax Partner of Vieira, Drigo, Vasconcellos e Paiva Gomes Law Firm. Former tax legal advisor of the Applied Tax Studies Group – GETAP. Professor at the Brazilian Institute of Tax Law – IBDT. PhD Candidate in Tax Law at Pontifical Catholic University (PUC/SP). Master in Tax Law at FGV Direito-SP. Specialist in International (IBDT) and National Tax Law (PUC-COGEAE/SP). Bachelor of Laws from Mackenzie Presbyterian University. Member of the Tax Law Committee at the Central and Pinheiros Branches of the Brazilian Law Association.

    Bradley C. Birkenfeld

    Former private Swiss banker and recipient of the largest whistleblower award in IRS history

    Bradley C. Birkenfeld is the most significant financial whistleblower in history and the author of Lucifer’s Banker UNCENSORED: The Untold Story of How I Destroyed Swiss Bank Secrecy, (September 2020). His bombshell revelations cracked the impenetrable fortress of Swiss banks, proving that offshore financial institutions systematically aided clients’ tax evasion, corruption and terrorist activities. His case triggered monumental changes in banking laws, the federal tax code and international tax treaties.

    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.

    Eric Hylton

    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.

    Marissa Rensen

    Managing Director at KPMG US

    Prior to joining KPMG in April 2020, Marissa was an attorney in the IRS’s Office of Associate Chief Counsel (International) for more than seven years, most recently as a special counsel. During her time with Chief Counsel, Marissa provided guidance to the IRS on transfer pricing matters in examination, appeals, and litigation. After the enactment of the Tax Cuts and Jobs Act, Marissa focused on guidance implementing U.S. tax reform, including FDII, the base erosion and anti-abuse tax (BEAT), and inventory sourcing. Earlier in her career, she was a clerk to the Honorable Joseph R. Goeke of the U.S. Tax Court and a tax associate at Mayer Brown LLP, in Washington. Marissa Rensen advises clients on U.S. international tax matters, specializing in cross-border transactions involving complex international tax issues.

    William Byrnes

    Professor

    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.

    Raúl Villarreal Garza

    Procopio

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

    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 has vast experience with business combinations, valuation modeling and purchase price allocations. His experience covers various industries, including Pharmaceuticals, Commercial Real Estate, Small Business operators, Family Office Management Companies and Restaurants. He also is extensively involved in business valuation and forensic projects related to USCIS business visa program (“E2”).

    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.

    Luis Ignacio Martel

    Partner at Kavanagh Gorozpe- Mexico City

    Luis Ignacio has extensive experience in tax planning and consulting, both in domestic and international matters, as well as in corporate, contractual, and financial matters; his practice has focused mainly on estate planning, mergers and acquisitions, venture capital –including search funds–, corporate restructuring, real estate operations and investment structuring.

    Luis has been co-founder and member of the board of directors of companies in various sectors, including search funds and companies dedicated to the generation and supply of content and information.

    Luis Ignacio co-chairs the Academic Committee of STEP (Mexican Chapter). He currently teaches Income Tax, Tax Strategies, and Tax Law in Universidad Nacional Autónoma de México and in Universidad Panamericana, and is the author of several articles specialized on the subjects, which have been published in prestigious journals

    Enrique Hernández-Pulido

    Procopio

    Enrique Hernández-Pulido’s legal practice includes representing clients in international tax planning and related international matters, particularly Mexican and US-Mexican legal matters. Enrique represents clients in the development of business transactions, worldwide investment and financing structures, planning for worldwide income and estate and inheritance taxes. He is licensed to practice in California and Mexico. He serves on Procopio’s Management Committee and chairs its Latin America – US Cross-Border Practice Group and Co-chairs its Beer, Wine and Spirits Practice Group.

    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.

    Bernardita Parodi

    A Master of Laws in international taxation from the University of Florida

    Bernardita Parodi is an admitted lawyer from Pontifical Catholic University of Chile and has a Master of Laws in international taxation from the University of Florida, US. She is member of the Chilean Tax Law Institute.

    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

    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.

    Alejandro Barrera

    Partner, Basham, Ringe Y Correa, S.C

    Alejandro earned his law degree, summa cum laude, from Universidad Nacional Autonoma de Mexico in 1994. He has undertaken several graduate studies at Universidad Panamericana such as in Taxation, Commercial Law, Administrative Law, Intellectual Property and Constitutional Proceedings (Amparo); as well as the Doctor of the Science of Law (J.S.D.) program of study. Awarded with the Fulbrigh-García Robles scholarship (1998-1999), he successfully pursued his LL.M in International Taxation degree at New York University School of Law.

    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

    Widely recognized as one of the nation’s leading tax litigators, Mr. McManus helps clients confidentially resolve a range of controversies — from Internal Revenue Service (IRS) audits and appeals to litigation before federal and state courts throughout the United States. He delivers clear and technically astute counsel to a diverse mix of American and international clients, including multinational and Fortune 500 corporations from diverse industries (such as technology, banking, insurance, energy, pharmaceuticals, airlines, entertainment, and retail), global professional services firms, international charitable organizations, trust companies, and offshore corporate providers.

    Victor A. Jaramillo

    Member, Caplin & Drysdale Washington, D.C.

    Victor Jaramillo is a Member in Caplin & Drysdale’s Washington, D.C. office and is a member of the firm’s Board of Directors. He advises multinational corporations, financial institutions, and individual clients on a broad range of tax matters, including tax controversies, risk management and international compliance, and cross-border structuring. He also utilizes his Spanish fluency to advise Spanish-speaking clients.

    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). 

    Laura Gavioli

    Partner in the Federal & International Tax Group | Alston & Bird

    Laura L. Gavioli is a partner in the Federal & International Tax Group and a member of the Tax Controversy Team. As an experienced first-chair trial lawyer, Laura is known for achieving practical, client-driven goals when defending against IRS inquiries. She has represented clients involved in some of the largest white-collar criminal tax evasion cases ever brought in the U.S. and advises clients on the IRS Whistleblower Program. She attained taxpayer victories in civil tax cases in U.S. Tax Court and federal district courts, eliminating IRS penalties.

    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

    Mike was named a Texas Super Lawyer in Texas Monthly and Texas Super Lawyer Magazines in 2013-2021. In 2010-2013, he was named a Texas Rising Star. Mike focuses on resolving federal tax controversies and white collar crime, including securities, tax and bank fraud. He represents individuals, closely-held businesses, and large corporations in IRS audits, appeals, and litigation, as well as in business disputes and lawsuits involving fraud, breach of contract, breach of fiduciary duty, deceptive trade practices act violations, non-compete violations, business torts, and other commercial disputes.

    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.

    Robert Russell

    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.

    Matthew Roberts

    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.

    Stephanie Uribe

    Senior Tax lawyer, Santamarina & Steta

    Stephanie is a Senior tax lawyer with the recognized firm of Santamarina & Steta (Mexico), with more than 10 years of proven professional experience in domestic and international tax advisory matters, mainly in mergers & acquisitions, spin-offs and several corporate reorganizations. She has experience in advising international clients as to their federal tax obligations in Mexico including permanent establishment status, tax strategies, expatriate compensations plans and tax controversies.

    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.

    Damon Rowe

    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.

    Carolyn Schenck

    IRS National Fraud Counsel and Assistant Division Counsel (International)

    CAROLYN A. 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, Carolyn 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), Carolyn been assigned to this for the last 12 years as counsel to the Service’s Offshore Compliance Initiatives. Carolyn 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.

    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.

    Armando Gomez

    Partner, Skadden

    Mr. Gomez represents clients in federal and state tax controversy matters, including in connection with examinations, administrative appeals and special programs designed to reach expedited results, and in litigation before the United States Tax Court and other federal courts. He has advised clients in summons enforcement matters and in criminal tax investigations, and also has acted as special tax counsel in connection with internal investigations on tax-related matters.
    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

    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.

    Carlos C. Lopez EA, MDE

    Executive Director of Latino Tax Professionals Association(International)

    Carlos C. Lopez is the founder and President of Lopez Tax Service and Latino Tax Professionals Association, the largest Hispanic tax association in the U.S., located in Salinas, California. He holds a B.A. degree from Pacific Union College and a Certificate of Management Development for Entrepreneurs from UCLA Anderson School of Management. He has been active in tax preparation and representation before the IRS for 33+ years.

    His extensive experience includes developing qualifying continuing education and training programs for the California Tax Education Council and for the IRS Enrolled Agent CE program.

    Antonio Martinez

    Co-Founder & CEO of Negozee

    Anotnio Martinez is the Co-Founder & CEO of Negozee, a platform specialized in providing bilingual training for small businesses in the Hispanic community across the U.S. Tony graduated from the Engineering School of the University of California, Berkeley on a full-ride scholarship.

    Tony was the former VP of Business Development of Latino Tax Pro, the largest Hispanic tax association in the U.S. Within this role, he led the exponential growth of the organization and organized various events throughout the country. Tony is also an Enrolled Agent and has focused his tax credential to represent immigrant taxpayers before the IRS. More recently,

    Tony launched Negozee, a digital platform focused on providing education and resources to immigrant small business owners.

    Laura Nava, CPA

    Mrs. Nava graduated Magna Cum Laude from the University of San Francisco, becoming one of the youngest CPAs in the State of California. She is a Certified Public Accountant (CPA) and also holds the accreditation of being a Certified Tax Coach (CTC) and QuickBooks ProAdvisor.

    Mrs. Nava’s specialty is not only to maintain adequate books and records of each business client, but also works with business owners in Tax Planning Strategies and Tax Preparation.

    Mrs. Nava has focused the majority of her career in assisting and helping taxpayers within the Hispanic community.

    Antonio Nava EA NTPI Fellow

    Fellow of STANFORD SLEI-Ed

    Mr. Nava is a recognized tax professional within the Hispanic community with most than 20 years of experience. As a first-generation immigrant, Mr. Nava has focused his tax career to assist members of the Hispanic community across the U.S. He holds a Certificate of Achievement in Accounting from Orange Coast College in California. Mr. Nava is an Enrolled Agent licensed to represent individuals and businesses before the Internal Revenue Service in all 50 States. Additionally, he is a Fellow of the Stanford Latino Entrepreneurship Initiative-Education Program from the Stanford Graduate School of Business (GSB). He also is a recognized fellow of the National Tax Practice Institute from the National Association of Enrolled Agents for Taxpayer Representation and Practice before the Internal Revenue Service.

    He is a frequent speaker in multiple forums and he is a member of the National Association of Enrolled Agents, the National Association of Tax Professionals, Nthe ational Society of Accountants, the California Society of Enrolled Agents and the American Society of Tax Problem Solvers.

    Brad McCormack

    Internal Revenue Service, Associate Chief Counsel (International)

    Brad is an attorney in the office of Associate Chief Counsel (International) where he specializes in transfer pricing and related regimes. He drafted recent TCJA Regulations concerning the Base Erosion and Anti-Abuse Tax (BEAT) of section 59A, inventory sourcing, and the section 250 deduction for Foreign-Derived Intangible Income (FDII). He also advises on transfer pricing aspects of major Tax Court cases and other controversies.

    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).

    Education:
    J.D., University of Notre Dame

    Fernando Juarez

    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 & 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.

    Sean Foley

    Global Head of Transfer Pricing Dispute Resolution Services | KPMG

    Mr. Foley is the Global Head of Transfer Pricing Dispute Resolution Services at KPMG. He has more than twenty years of experience working with major organizations and multinational corporations to analyze their intercompany transactions and develop practical transfer pricing strategies. Sean’s primary areas of focus include Advance Pricing Agreements, Competent Authority matters and transfer pricing risk management.

    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.

    Mr. Calderón’s main areas of practice are: Corporate Tax; Tax Aspects of Cross-border Transactions; International Tax Planning; Consultation and Litigation, including Transfer Pricing and Advance Pricing Agreements; Tax Controversy; and Competent Authority Proceedings.
    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.

    Professor Christopher Hanna

    Professor at Southern Methodist University Law School

    Christopher H. Hanna is the Alan D. Feld Endowed Professor of Law and the Altshuler Distinguished Teaching Professor at Southern Methodist University. Professor Hanna has been a visiting professor at the University of Texas School of Law, the University of Florida College of Law, the University of Tokyo School of Law and a visiting scholar at the Harvard Law School and the Japanese Ministry of Finance. In 1998, Professor Hanna served as a consultant in residence to the Organisation for Economic Co-operation and Development (OECD) in Paris.

    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.

    Geoff T. Burnham

    Associate Attorney

    Geoff T. Burnham joined the Law Offices of A. Lavar Taylor in 2021 and has been working on civil and criminal tax controversy matters. Geoff is a former Special Agent for the Internal Revenue Service (IRS), Criminal Investigation Division and successfully led a variety of complex domestic and international financial criminal investigations focusing on tax evasion, the filing of false tax returns, money laundering, bank fraud, and various other financial related crimes.

    He has significant experience in the criminal tax arena as his prior work as a Special Agent at IRS and focused on criminal tax matters. In addition, Geoff’s international investigations which included voluntary disclosures, offshore financial accounts, and asset forfeiture, provide added expertise when dealing with international tax issues and assets.

    Jason B. Freeman

    Founding Member of Freeman Law, PLLC

    Mr. Freeman is the founding member of Freeman Law, PLLC. He is a dual-credentialed attorney-CPA, author, law professor, and trial attorney.

    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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