Katherine Amos, Senior Director, Transfer Pricing, Tyco International
Bio: Katherine Amos is the global head of transfer pricing for Tyco International. Tyco International is a Swiss-based diversified multinational operating in a variety of industrial and commercial markets. Previously, Katherine was a managing director with PricewaterhouseCoopers LLP in its New York and New Jersey offices, specializing in the transfer pricing issues surrounding the life sciences industries (primarily pharmaceutical, medical device, and biotech companies). She began her career in 1992 when she joined Ernst & Young’s New York transfer pricing practice.
Jeremy Cape, Partner, SNR Denton US LLP
Bio: Jeremy advises on a wide range of tax issues, including finance, restructuring and insolvency, funds, outsourcing and M&A. He works on both domestic and international matters, with a particular emphasis on emerging markets and Africa, advising both governments and taxpayers.He can regularly be seen as a tax pundit on CNBC and writes for numerous publications on a variety of subjects.
Scott Clark, Partner, SNR Denton US LLP
Bio: Scott Brian Clark is a member of SNR Denton's Taxation practice. Scott leads the firm's U.S. (state and local) tax practice and focuses on tax planning, audit and litigation issues, particularly those impacting communications, e-commerce, technology and utility companies. With more than 20 years of tax and legal experience, he is well-versed in the intricacies of state tax planning and tax controversy issues. Through the years, Scott worked extensively with many tax and industry groups, including the Multistate Tax Commission and The Federation of Tax Administrators, to resolve substantial U.S. national tax issues. Additionally, he has served as board member, officer or chair of numerous key tax, legal and business organizations throughout the country, including the Tax Executives' Institute, the Council on State Taxation, the American Corporate Counsel Association and the United States Communications Association, among many others. For many years, he served on the Executive Committee of the Tax Section of the Connecticut Bar Association and the New York State Taxpayer's Advisory Commission. Scott also served as General Counsel and CFO for an e-commerce web portal site, and was senior advisor to The Roosevelt Group, an organization devoted to CEO "thought leadership" as well as advisor and counsel to Centerprise Advisors, previously one of the world's largest national professional services organizations. Prior to joining SNR Denton, Scott was a partner at Thelen Reid Brown Raysman and Steiner LLP. Before entering private practice, Scott was a partner and co-leader of PricewaterhouseCoopers' national multistate tax and legal services communications practice, where he served as the lead state tax advisor to many significant communications, e-commerce, electronic, and technology companies throughout the United States. Prior to that, he was the associate tax counsel at GTE (now Verizon), where he acted as chief legal advisor on all state tax audit, protest and litigation matters.
Jim Ditkoff, Senior V.P. - Finance & Tax, Danaher Corporation
Bio: Jim Ditkoff is Senior V.P. – Finance & Tax – at Danaher Corporation (DHR:NYSE), a $20 billion multi-national manufacturer of medical, dental, environment, test & measurement, and industrial equipment with over 1,000 subsidiaries in 70 countries. Over the past 23 years, Danaher’s sales have increased 20-fold through acquisitions and internal growth, and its return to shareholders has exceeded 20% per annum. Jim holds a B.A. from Yale, a J.D. from Columbia Yale School, and an M.B.A. from Columbia Business School. Prior to joining Danaher in 1988, he was a partner at Ernst & Young, and V.P. – Taxes at PepsiCo, Inc. He has written articles for several tax and accounting publications and completed the New York and Marine Corps Marathons (4:06/4:10).
Sheila Geraghty, Counsel, SNR Denton US LLP
Bio: Sheila Geraghty is a member of SNR Denton’s Tax practice and focuses on providing international tax and transfer pricing advice to multinational corporations. Sheila advises clients on all aspects of cross-border transactions, acquisition planning, international corporate structuring, effective tax rate planning, foreign tax credit strategies, transfer pricing planning and documentation, advance pricing agreements and tax audit support. Prior to joining private practice, Sheila worked for more than 13 years in public accounting and seven years for multinational corporations on international tax matters.
Hernan Gonzalez-Moneta, Foreign Legal Consultant, SNR Denton US LLP
Bio: Hernan Gonzalez-Moneta is a member of SNR Denton's Tax practice and heads the Mexican and Latin American Tax Desk. He advises clients with respect to Mexican and international tax and corporate matters, including tax planning, all aspects of cross-border transactions, interpretation and application of tax treaties, mergers and acquisitions, corporate reorganizations, permanent establishment issues, transfer pricing, foreign tax credit planning and expatriates' tax regime, as well as research and development tax incentives. Hernan concentrates his practice on international tax planning and guides clients in the implementation of their multi-jurisdictional business structures. Hernan also assists clients with the negotiation of private letter rulings concerning international transactions, including the lobbying and prosecution of administrative matters before Mexican federal and state authorities. He has drafted tax reform proposals concerning clients' benefits, which were discussed and passed by Mexico's Congress. Likewise, he has advised Mexican federal government agencies regarding compliance given to legal and payment obligations under major media campaigns.Hernan has also determined for the Mexican operations of major international groups value-added tax (VAT)-efficient strategies for imports and exports, as well as assisting them in securing large VAT refunds. He has secured registration of foreign banks and pension funds before Mexico's Foreign Banks & Pensions and Retirement Funds Registry. In addition, Hernan has successfully handled several tax, administrative and intellectual property litigation procedures. Prior to joining SNR Denton, Hernan collaborated with DLA Piper US LLP as the Mexican Tax Desk in its New York office. He also worked in Mexico as industrial partner of Mexican law firm Sanchez-DeVanny Eseverri, S.C., in the Mexico City and Monterrey offices, and as an associate of Baker & McKenzie–Monterrey office.
John Harrington, Partner, SNR Denton US LLP
Bio: John Harrington is a member of SNR Denton's Tax practice. He advises clients on inbound and outbound transactional and compliance issues, international tax legislative, regulatory, and treaty matters, and a variety of domestic tax issues. John has extensive experience in dealing with the foreign tax credit, subpart F, cross-border activities of companies and individuals, and other international tax issues. Prior to joining SNR Denton, John served as international tax counsel for the Department of Treasury. At the Treasury Department, he worked closely with the IRS in developing regulations and other administrative guidance. He represented the Treasury Department and worked with Congressional committees and staff on tax treaties and international tax aspects of legislation. He has also played an active role in tax treaty negotiations and in drafting technical explanations and revisions to existing treaties. John worked closely with tax officials in other countries and he served as the United States representative at meetings of the OECD Committee on Fiscal Affairs and at WTO meetings on tax-related trade disputes. Before joining the Treasury Department, John was a tax counsel on the U.S. House Committee on Ways and Means. On the committee staff, John was responsible for international, pass-through entities, financial institutions and products, real estate, environment, energy, and other tax issues. John is a frequent speaker and panelist at tax conferences.
David Hryck, Partner, SNR Denton US LLP
Bio: David Hryck is the US Head of International Tax and has more than 17 years of experience as a tax and business lawyer. He advises clients on the tax and business aspects of structuring their investments for maximum profitability and has in-depth experience with cross-border investments. He has represented celebrities, entertainers, global companies, individuals and international families. David has international proficiency with corporations as well as individuals across the globe, and he is recognized for his outstanding abilities to structure their business transactions. David is a valued and trusted advisor, board member and mentor to several trusts and global charities. Currently, he serves as a trustee on various trusts of his clients. He serves on the board of directors of the Amy Winehouse Foundation, and is a board member of the Happy Hearts Fund, founded by supermodel Petra Nemcova. He is a World Fellow of the Duke of Edinburgh's Award for Excellence Fund, founded by HRH Prince Philip, Duke of Edinburgh, and travels regularly to royal occasions around the world, advising on international interaction in Third World countries. David also serves as a US member of the Duke's Business Advisory Group, headed by HRH Prince Edward, the Earl of Wessex. He is also a board member of the Lifeline Humanitarian Organization, founded by TRH Crown Prince Alexander and Crown Princess Katherine of Yugoslavia. David speaks English, Spanish, Italian and French and has a working knowledge of Mandarin.
Jeff Korenblatt, Partner, SNR Denton US LLP
Bio: Jeffrey Korenblatt is a member of SNR Denton’s Tax practice and focuses on international tax planning. He advises a broad array of taxpayers on the tax-efficient structuring of domestic and cross-border mergers, acquisitions, reorganizations, spin-offs, redemptions and liquidations. Jeff also provides guidance to taxpayers on the use of US and foreign partnerships and other pass-through structures. Jeff concentrates his practice on international tax planning for public and private multinational companies. He advises on all aspects of cross-border transactions, post-merger rationalization of related entities and operations, and transfer pricing. Jeff also guides taxpayers in the implementation of multi-jurisdictional business structures and the use of special purpose foreign entities. He provides tax advice for maximizing the utilization of foreign tax credits and for minimizing the effects of anti-deferral regimes. Jeff also frequently helps foreign persons efficiently structure their investments in the United States. Jeffrey is an active speaker and writer with the American Bar Association Section of Taxation and the Foreign Activities of US Taxpayers (FAUST) Committee (for which he chaired the Young Lawyers of FAUST Subcommittee). He also speaks at the Federal Bar Association (for which he co-chaired the International Sessions of the 32nd and 33rd Annual Tax Law Conferences); the Alliance for Tax, Legal, and Accounting Seminars (ATLAS); and the American Institute of Certified Public Accountants (AICPA). Jeff is an active member of the International Fiscal Association.
Michael Swiader, Managing Director - Tax Counsel, Deutsche Bank AG - New York
Bio: Michael Swiader is a Managing Director and Tax Counsel in the U.S. Corporate Tax Group at Deutsche Bank, where he provides tax advice, including advice relating to tax efficiencies and optimization, and advises various DB business units, including the Real Estate, Mergers & Acquisitions, Commodities, and Distressed Products groups. He has particular experience in the areas of domestic and international corporate taxation, U.S. consolidated returns and partnership taxation. Mr. Swiader is admitted to the New York State and Ohio State bars, has his LL.M in taxation from NYU, his J.D. from Case Western Reserve University School of Law, and his BA with honors from the University at Buffalo. Prior to joining DB, Mr. Swiader was associated with Proskauer Rose LLP and prior to that, Alston and Bird.
Marc Teitlebaum, Partner, SNR Denton US LLP
Bio: Marc Teitelbaum is the chair of the Tax Department. Marc has been involved in advising public companies, underwriters and investment funds principally in the following areas: acquisition and disposition of domestic and foreign corporations whether taxable or tax-free transactions; daily ongoing tax advice to public companies, regarding general corporate and consolidated return tax issues, including the U.S. tax consequences of foreign operations and foreign joint ventures, in particular, multi-national manufacturing and sales operations; debt and equity financings; investment strategies in partnership form including tax and accounting-advantaged structured domestic and cross-border financing arrangements; taxation of regulated investment companies; partnership taxation; and investment and trading funds. Marc in recent years has provided tax advice with respect to in excess of one billion of tax advantaged cross-border corporate finance strategies and regularly advises banks concerning such matters. Marc has also been involved in advising on the formation of many private equity funds and offshore hedge funds, on tax issues that are attributable to their domestic and foreign activities, and deferred compensation arrangements for managers and their employees. He has also advised on several management company restructurings to achieve various goals and the sale of management companies.
Alex Thomas, Partner, SNR Denton US LLP
Bio: Alex is Head of Tax in the UK. He advises on a broad spectrum of corporate, commercial and real estate tax issues for a wide variety of clients across all key industry sectors (Energy, Transport and Infrastructure, Financial Institutions, Real Estate and Retail, Technology, Media and Telecoms). Alex works on mergers and acquisitions, reorganisations and restructurings, joint ventures, venture capital, fund transactions and real estate transactions (with particular emphasis on SDLT planning). Alex provides international tax planning advice to clients doing business overseas, particularly in jurisdictions where we have overseas offices. Alex is recommended in PLC's Which Lawyer? (leading lawyers worldwide). Alex is often quoted on tax issues in the national press, most recently in the Financial Times on the Lib-Con coalition's Capital Gains Tax proposals.
Mark Thomas, Partner, SNR Denton US LLP
Bio: Mark Thomas is a member of SNR Denton’s Taxation practice, where he focuses on all aspects of taxation, including complex civil and criminal tax controversies and litigation, transfer pricing, and domestic and international tax planning. Mark has extensive experience in resolving a broad spectrum of domestic and international tax matters at all stages of a tax dispute, including IRS examinations, administrative appeals and litigation. Where appropriate, he has utilized collaborative dispute resolution tools such as Advance Pricing Agreements, Pre-Filing Agreements and the Compliance Assurance Program. Mark has significant experience with foreign tax authorities as well as a deep understanding of Organisation for Economic Co-operation and Development principles and treaty interpretation issues. On the transactional side, Mark also has extensive experience in the structuring of domestic and foreign mergers and acquisitions, corporate reorganizations and divestitures, venture capital and private equity transactions, business formations, cross-border financing arrangements, and complex joint venture and partnership arrangements. Prior to joining SNR Denton, Mark was senior tax counsel at Alcon Laboratories, Inc., where he was responsible for tax planning and controversies, transfer pricing, captive insurance and risk management for the entire Americas and Caribbean regions.
Theodor van Stephouudt, Economist, SNR Denton US LLP
Bio: Theodor van Stephoudt is a member of SNR Denton's Tax practice. He has extensive experience working with clients in providing assistance in the development of transfer pricing documentation, the planning of appropriate intercompany prices and the valuation of intangibles, tangible assets and entities for tax purposes. Theodor has defended clients in tax audits conducted by the US Internal Revenue Service (IRS) and tax authorities in Europe and in Asia. His clients include multinational companies with cross-border intra-group transactions. He has advised clients of all sizes, from smaller startup companies to very large, well-known global multinational corporations. Theodor has analyzed intercompany pricing and fee structures for various industry sectors, including manufacturing, high-tech and financial services, and provided analyses regarding royalty rates, including brand name royalties and related tax and transfer pricing advice. Theodor has developed management fee systems for clients in a number of industries and has assisted clients in determining the most advantageous location for intangibles/value drivers. During his five years in Switzerland, he assisted clients with the establishment of principal structures in that country. Theodor has also advised clients in obtaining advance pricing agreements on a bilateral and unilateral basis. Unilateral advance pricing agreements were established with the IRS. Theodor advised on bilateral advance pricing agreements with Switzerland, Germany, Denmark, and Norway. Theodor has valued trademarks, technologies, startup companies, other tangible and intangible assets, and entire corporations. He has assisted in due diligence processes to evaluate potential transfer pricing risks. Theodor has presented at tax and transfer pricing forums, and his articles on transfer pricing have been published in both English and German magazines. Theodor is a member of the Licensing Executives Society (United States and Canada).
Todd Welty, Partner, SNR Denton US LLP
Bio: Todd Welty is US head of Tax Controversy and Litigation for SNR Denton. He is also a fellow of the American College of Tax Counsel. Todd’s practice is both national and international in scope. Approximately 95 percent of his professional time is spent on tax controversy and litigation. He represents a broad range of clients including Fortune 100 companies, large non-US multinational companies, closely held businesses, ultra high-net-worth individuals and tax advisors—whether they be lawyers or CPAs. Todd has extensive experience in resolving civil tax matters at all stages of a tax dispute, including IRS examinations, fast-track appeals, administrative appeals, post-appeals mediation and, if necessary, litigation in the US Tax Court, the US Court of Federal Claims, and US district courts. In addition, Todd has represented numerous clients in proceedings involving IRS administrative criminal investigations, grand jury investigations, malpractice claims and indemnity claims. In many of these cases, he successfully navigated these investigations so that his clients’ exposure to penalties and criminal prosecution was eliminated or significantly reduced. The vast majority of Todd’s cases are resolved administratively and without becoming public. In fact, the best tax defense is one that eliminates or significantly reduces exposure before the IRS proposes a deficiency. Nonetheless, sometimes litigation is necessary. A seasoned trial lawyer, Todd has tried major cases to verdict. In fact, Todd has been intimately involved in the litigation of several of the largest civil and criminal tax cases ever brought in the United States. Todd frequently speaks at tax conferences, such as the American Bar Association Tax Section, the UCLA Tax Controversy Institute, the New York University Tax Controversy Forum, the National Institute on Tax Fraud, the Southern Federal Tax Institute, the Texas Tax Institute and others.
