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.
Before that, Desmond was in private practice at his own firm from 2012 to 2018 and practiced at Bingham McCutchen LLP and its predecessor firm McKee Nelson LLP from 2000 to 2004 and 2008 to 2012. From 2005 to 2008, he served as Tax Legislative Counsel at the U.S. Department of the Treasury, Office of Tax Policy, where he was the principal legal advisor to the Treasury Secretary and Assistant Secretary (Tax Policy) on all domestic aspects of the federal tax law other than employee benefits. Earlier in his career he served as a trial attorney in the Tax Division of the U.S. Department of Justice from 1995 to 2000.
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 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.
Mr. Fort began his IRS career in 1991 as a Special Agent in Baltimore, Maryland, and later served as Supervisory Special Agent in Orlando, Florida; Senior Analyst and Acting Director, Office of Special Investigative Techniques; Assistant Special Agent in Charge of the Baltimore and Washington, D.C. Field Offices; Special Agent in Charge of the Philadelphia, Pennsylvania, Field Office; and Deputy Director of Strategy, IRS-CI Headquarters.
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.
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.
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.
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.
He graduated from the Escuela Libre de Derecho, where he has served as professor for more than 30 years, and holds a Master’s in Public Administration by the National Institute of Public Administration (INAP).