As a tax attorney in EY’s ITTS practice, I advise a diverse array of corporate and private clients regarding the US tax considerations of their cross-border operations and investments. I provide tax advisory support from project inception through exit by analyzing and structuring transactions, reviewing agreements, and modeling tax costs. Working together with the in-house tax team, I create procedures to efficiently mitigate and track tax risk, implement and monitor compliance with these procedures, and liaise with internal and external stakeholders.Financial Products and Partnership Tax: I counsel large US-based real estate, private equity, and credit funds on the US tax consequences of their investments, with a particular focus on investor-level exposures and fund-level tax and compliance costs. In this role, I provide tax analysis and recommendations to local deal teams, coordinate and manage specialists, and document advice for use in tax compliance. I also work with US and non-US sponsors to facilitate inbound investments by offering strategies to maximize the benefits available to treaty, portfolio, and sovereign investors. I have experience analyzing partnership and cancelation of debt issues arising during the acquisition, refinancing, and disposition of distressed assets, as well as analyzing the proper US tax treatment of purported debt instruments and preferred stock interests. International and Corporate Tax: I work with US and foreign corporations looking to increase intercompany tax efficiency or otherwise minimize their effective tax burden. For example, I have reviewed US multinationals’ Subpart F exposures, effectuated outbound reorganizations (by coordinating with legal advisors, consulting with foreign tax experts, and documenting US tax considerations), evaluated permanent establishment / US trade or business risk, and generally analyzed and addressed numerous Sub C issues (both in the domestic and cross-border context).

Researched various tax issues using Checkpoint and Westlaw including the applicability of certain itemized deductions, the tax treatment of dividend payments by S-corps, the potential liability of non-profits for unrelated business income, the risks faced by 501(c)(3) charities involved in political campaigns, and the structuring of tax-deferred annuities within Medicaid trusts. Drafted articles and memoranda involving estate planning, transactional taxation, and compliance.

Participated in all phases of litigation, including drafting and arguing motions, preparing and responding to discovery, and deposing witnesses. Second-chaired defense of a multiparty professional negligence trial. Conducted evidentiary hearings. Wrote legal briefs and memoranda concerning novel topics in construction law and other subjects arising in commercial litigation. Successfully negotiated settlements during and apart from mediation. Counseled clients regarding transactional issues from project inception to close-out. Drafted and reviewed construction contracts. Oversaw paralegals and junior attorneys in discovery and motion practice.

Drafted pleadings, discovery, and various documents for No-Fault / PIP Arbitrations. Worked directly with clients to develop the factual underpinnings of their claims. Performed legal research using various sources and drafted accompanying legal memoranda.