Webinar: Foreign Tax Credits

Join the FBA Tax Section and Eversheds Sutherland for an in-depth discussion of the impact of the recent proposed and final Foreign Tax Credit regulations. Panelists will discuss both the proposed and final regulations, how they impact taxpayers, and how the government addressed comments made in response to the original proposed regulations.

Registration is now closed

About the Presenters

Martin Milner, Principal, Ernst & Young LLP
Martin Milner is a principal in Ernst & Young LLP’s International Tax Services practice and is part of the National Tax Department. He is based in Washington, D.C., and advises clients on all aspects of US international taxation, particularly cross-border acquisitions, dispositions and restructurings.

Prior to joining Ernst & Young LLP, Martin was a partner at a major international law firm where he represented multinational corporations and high net worth individuals on international tax matters and cross-border acquisitions.

Martin is a former Chair of the Federal Bar Association Section of Taxation and was an adjunct professor at Georgetown University Law Center where he taught Advanced International Taxation.

Martin received a Masters of Law (LLM) in Taxation at New York University Law School and a juris doctor at Emory University School of Law. Prior to law school, Martin received a BA from Washington and Lee University. He is a member of District of Columbia Bar Association, the Georgia Bar Association, the Louisiana Bar Association and the Mississippi Bar Association. Martin is a frequent contributor to tax publications and he often speaks at Tax seminars on various international tax topics.

Aaron Payne, Partner, Eversheds Sutherland
Aaron Payne represents publicly traded global corporations in the area of federal corporate taxation with respect to domestic and international planning, transactions and compliance. Aaron analyzes global issues and then structures deals accordingly in the context of acquisitions, dispositions and reorganizations. He advises clients regarding repatriation techniques, currency transactions, principal and finance company arrangements and financial instruments with cross-border facets. Aaron works with clients to manage the international taxation implications of their M&A endeavors by crafting deals to create transaction and legal entity structures that optimize the company’s tax outcomes.

On the internal planning side, Aaron advises on repatriation structures to help clients efficiently meet their cash-flow needs as well as how to organize their international legal entities such that they are efficiently postured for U.S. tax purposes. In the area of corporate tax planning, Aaron advises multinational Fortune 100 clients in all aspects of their cross-border transactions. This activity includes subpart F planning, as well as tax compliance and tax information reporting.

Carol Tello, Partner, Eversheds Sutherland
With a career that spans both government and private practice, Carol Tello helps multinational companies and individuals navigate the complex and rigorous realm of international taxation. Her practice includes a broad range of cross-border tax planning and Internal Revenue Service (IRS) controversy matters, including compliance with the Foreign Account Tax Compliance Act (FATCA). Balancing the concurrent goals of minimizing tax consequences and complying with the law, Carol brings experience in cross-border restructuring transactions, inbound corporate transactions, withholding matters and treaty interpretation issues, as well as cross-border taxation of corporate executives and the U.S. taxation of non-U.S. citizens. She also advises clients on tax issues involving intellectual property transactions.

Before joining Eversheds Sutherland (US), Carol worked in the IRS Office of Associate Chief Counsel (International) and as a Special Assistant to the Assistant Commissioner (International). She participated in a number of income tax treaty negotiations, was the IRS National Office adviser in several U.S. Tax Court cases, and worked on various regulations and other guidance, including significant participation in developing regulations concerning the taxation of software transactions.

Registration

Registration will close 24 hours prior to event start

Registration Fees

• FBA Member: $0
• Nonmember: $75

How to Register

Registration is now closed

Cancellation Policy

No refunds will be made for cancellations received after the close of business on Wednesday, April 15, 2020. No-shows will be billed. Substitutions may be made at any time upon notification. Please contact Laura Mulhern at lmulhern@fedbar.org with cancellation and/or substitution requests.

CLE

CLE Credits provided by Eversheds Sutherland

If you have any questions regarding this program, please contact Laura Mulhern, Sections and Divisions Manager.