Tax counsel to private equity funds and hedge funds.Primary focus on fund formation, strategic planning, and tax compliance, especially with respect to international lending, inbound real estate investments, renewable energy investments, sovereign wealth funds, effectively connected income (ECI), and outbound Chapter 3 and Chapter 4 withholding taxes.Documents I typically focus on include: • Private placement memorandums • Subscription documents • Limited partnership agreements • Limited liability company agreements • Side letters • Transfer agreements (including BBA and PTP risk analysis) • Credit agreements • ISDA agreements • Administrator agreements (including AEOI obligations) • Cross-border alternative-investment-vehicle services agreements • Withholding certificates and tax forms: o IRS Form W-8BEN-E and tax treaty claims o IRS Form W-8IMY and withholding statements o IRS Form 8957, GIIN registration, and FATCA classifications o IRS Form W-8EXP and 892 claims o FIRPTA Certificates o Entity Classification Elections o Common Reporting Standard (CRS) Self-Certifications*Received 2016 "Distinguished Legal Writing Award" by the Burton Foundation, for having co-authored one of the top U.S. legal practitioner articles of 2015, based on clarity, cogency, and persuasiveness.

I provided M&A tax due diligence and deal structuring advice to private-equity firms and hedge funds, with a focus on deals in the financial-services sector. I also consulted on the potential tax implications of corporate recapitalizations and other corporate restructurings (per IRC §§ 354, 356, and 368(a)(1)(E)) and foreign currency transactions (per IRC § 988).

I was promoted to a senior position in Deloitte's Post-Merger Integration (PMI) group, and primarily focused on the following tasks:• Incorporating and operationalizing non-U.S. legal entities as part of a corporate restructuring• Managing divestiture legal transitions involving contracts and licenses

I provided tax-planning advice to recently merged corporations, as part of Deloitte's Post-Merger Integration (PMI) group. The scope of my work included international, federal, state, and local tax issues. Some specific tasks included:• Assisting in the project management of the tax aspects of a multibillion-dollar corporate merger• Analyzing the legal and financial implications of asset allocations in Forms 8883 for IRC § 338 transactions (e.g., determining which assets could be considered ordinary versus capital, and how this might impact the buyer and seller)• Incorporating non-U.S. legal entities as part of a major international corporate restructuring• Researching the pros, cons, and common tax law pitfalls of "legal structure simplification" projects from a financial perspective (aka "legal entity rationalization" or "legal entity simplification")• Preparing a Private Letter Ruling (PLR) request for an IRC § 355 tax-free corporate spin-off, per Rev. Proc. 96-30 and Rev. Proc. 2003-48• Preparing a PLR request for an IRC § 332 tax-free subsidiary liquidation, per Rev. Proc. 90-52• Authoring and editing tax-credit applications for advanced energy projects (IRC § 48C)• Creating a training presentation on tax-free acquisitive reorganizations ("reorgs") per IRC § 368, which also addressed IRC §§ 338, 351, 382, and 1060

I wrote memos about the implications of various tax laws on major financial institutions, including banks and insurance companies. My research primarily focused on the following: • IRC §§ 41 & 174 (R&D tax credits)• IRC § 461 (timing of income tax deductions)• IRC § 61 (scope of gross income)• IRC § 1212 (capital-loss carrybacks and carryovers)• IRC § 848 (capitalization of insurance client acquisition expenses (DAC))• Treas. Reg. § 1.1502-36 (M&A consolidated return unified loss rules)*Recipient of Deloitte Applause Award (a merit-based bonus for exemplary client service)

Critically analyzed discovery information and legal arguments while defending clients in contract and tort-based disputes.

Researched legal issues and honed writing skills during fifteen-week litigation internship. Assisted in deposition preparation and execution in a $50 million insurance case.

Assisted professor in researching private-equity deals gone awry as she prepared for a panel discussion at the Tulane Corporate Law Institute, a preeminent M&A forum.