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Read the October Issue of Focus on Tax Strategies & Developments

By David G. Noren, Alejandro Ruiz, Timothy S. Shuman, Peter L. Faber, Kristen E. Hazel, Sandra P. McGill, Susan E. O’Banion, Kevin Spencer, Robin L. Greenhouse, Jean A. Pawlow & McDermott Will & Emery on November 1, 2017
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The October 2017 issue of Focus on Tax Strategies & Developments has been published. This issue includes five articles that provide insight into US federal and international tax developments and trends across a range of industries, as well as strategies for navigating these complex issues.

Republican Leaders Release Tax Reform Framework
By David G. Noren Alexander Lee

M&A Tax Aspects of Republican Tax Reform Framework
By Alexander Lee, Alejandro Ruiz and Timothy S. Shuman

State and Local Tax Aspects of Republican Tax Reform Framework
By Peter L. Faber

Grecian Magnesite Mining v. Commissioner: Foreign Investor Not Subject to US Tax on Sale of Partnership Interest
Kristen E. Hazel, Sandra P. McGill and Susan O’Banion

The IRS Attacks Taxpayers’ Section 199 (Computer Software) Deductions
Kevin Spencer, Robin L. Greenhouse and Jean A. Pawlow


Read the full issue of Focus on Tax Strategies & Developments. 

Photo of David G. Noren David G. Noren

David G. Noren focuses his practice on international tax planning for multinational companies. David advises clients on a wide range of “outbound” and “inbound” issues, with a particular focus on the subpart F anti-deferral rules, the application of bilateral income tax treaties, and…

David G. Noren focuses his practice on international tax planning for multinational companies. David advises clients on a wide range of “outbound” and “inbound” issues, with a particular focus on the subpart F anti-deferral rules, the application of bilateral income tax treaties, and the treatment of cross-border flows of services and intellectual property rights under transfer pricing and other rules. Read David G. Noren’s full bio.

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Photo of Alejandro Ruiz Alejandro Ruiz

Alejandro Ruiz advises his clients on the tax aspects of complex domestic and cross-border transactions. He is experienced with transactions involving partnerships, corporations, REITs and off-shore entities. Alex advises on mergers and acquisitions, buyouts, recapitalizations, securities offerings, debt and equity restructurings, joint ventures…

Alejandro Ruiz advises his clients on the tax aspects of complex domestic and cross-border transactions. He is experienced with transactions involving partnerships, corporations, REITs and off-shore entities. Alex advises on mergers and acquisitions, buyouts, recapitalizations, securities offerings, debt and equity restructurings, joint ventures and entity formations. His clients include private equity funds, private and public companies, venture capital funds, real estate investment trusts, individuals and tax-exempt organizations. Read Alex Ruiz’s full bio.

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Photo of Timothy S. Shuman Timothy S. Shuman

Timothy (Tim) S. Shuman focuses his practice on corporate and international tax matters for US and non-US multinationals, with particular emphasis on domestic and cross-border acquisitions, dispositions, restructurings and liquidations. He has extensive experience in structuring spin-offs and tax-free reorganizations involving publicly traded…

Timothy (Tim) S. Shuman focuses his practice on corporate and international tax matters for US and non-US multinationals, with particular emphasis on domestic and cross-border acquisitions, dispositions, restructurings and liquidations. He has extensive experience in structuring spin-offs and tax-free reorganizations involving publicly traded and privately held companies, and regularly represents clients in obtaining private letter rulings and other guidance from the Internal Revenue Service (IRS). He also works on tax issues involving regulated investment companies. Read Tim Shuman’s full bio.

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Photo of Peter L. Faber Peter L. Faber

Peter L. Faber focuses his practice on corporate and business tax planning and controversy work involving federal, state and local taxes. Peter’s state and local tax practice has included tax planning for corporate acquisitions, divestitures and restructurings, combined report planning, electronic commerce and…

Peter L. Faber focuses his practice on corporate and business tax planning and controversy work involving federal, state and local taxes. Peter’s state and local tax practice has included tax planning for corporate acquisitions, divestitures and restructurings, combined report planning, electronic commerce and nexus issues, cloud computing issues, residence matters, alternative apportionment issues and a variety of other matters. Read Peter Faber’s full bio.

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Photo of Kristen E. Hazel Kristen E. Hazel

Kristen E. Hazel has extensive experience representing clients in US and international aspects of federal tax matters, including international acquisitions and divestitures, international joint ventures, and capital plan design and implementation. Her work includes both inbound and outbound transactions. Kristen is the co-chair…

Kristen E. Hazel has extensive experience representing clients in US and international aspects of federal tax matters, including international acquisitions and divestitures, international joint ventures, and capital plan design and implementation. Her work includes both inbound and outbound transactions. Kristen is the co-chair of the Firm’s Captive Insurance Affinity Group. She regularly counsels clients with respect to the tax aspects of organizing, operating and defending captive insurance companies. Read Kristen Hazel’s full bio.

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Photo of Sandra P. McGill Sandra P. McGill

Sandra McGill focuses her practice on international tax planning. Sandra works with US and non-US multinational companies, public and private as well as high net worth individuals and family businesses. Sandra has extensive experience advising clients on a broad range of cross-border tax…

Sandra McGill focuses her practice on international tax planning. Sandra works with US and non-US multinational companies, public and private as well as high net worth individuals and family businesses. Sandra has extensive experience advising clients on a broad range of cross-border tax issues. Read Sandra McGill’s full bio.

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Photo of Susan E. O’Banion Susan E. O’Banion

Susan E. O’Banion focuses her practice on tax matters.

Susan previously worked at a Big Four accounting firm, where she focused on international tax. While in law school, Susan served as comment editor for the Journal of Criminal Law and Criminology. Read …

Susan E. O’Banion focuses her practice on tax matters.

Susan previously worked at a Big Four accounting firm, where she focused on international tax. While in law school, Susan served as comment editor for the Journal of Criminal Law and Criminology. Read Susan O’Banion’s full bio. 

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Photo of Kevin Spencer Kevin Spencer

Kevin Spencer focuses his practice on tax controversy issues. Kevin represents clients in complicated tax disputes in court and before the Internal Revenue Service (IRS) at the IRS Appeals and Examination divisions. In addition to his tax controversy practice, Kevin has broad experience…

Kevin Spencer focuses his practice on tax controversy issues. Kevin represents clients in complicated tax disputes in court and before the Internal Revenue Service (IRS) at the IRS Appeals and Examination divisions. In addition to his tax controversy practice, Kevin has broad experience advising clients on various tax issues, including tax accounting, employment and reasonable compensation, civil and criminal tax penalties, IRS procedures, reportable transactions and tax shelters, renewable energy, state and local tax, and private client matters. After earning his Master of Tax degree, Kevin had the privilege to clerk for the Honorable Robert P. Ruwe on the US Tax Court. Read Kevin Spencer’s full bio.

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Photo of Robin L. Greenhouse Robin L. Greenhouse

Robin L. Greenhouse represents businesses and individuals in resolving complex, large-dollar federal tax controversies. Robin is adept at using dispute resolution techniques, including fast track mediation, pre-filing agreements, Internal Revenue Service (IRS) appeals and post-appeals mediation, and has been the lead lawyer in…

Robin L. Greenhouse represents businesses and individuals in resolving complex, large-dollar federal tax controversies. Robin is adept at using dispute resolution techniques, including fast track mediation, pre-filing agreements, Internal Revenue Service (IRS) appeals and post-appeals mediation, and has been the lead lawyer in significant litigation. Over her 30-year career as a government and private practice tax litigator, she has argued more than 100 cases in federal courts at every level. Read Robin Greenhouse’s full bio.

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  • Posted in:
    Tax
  • Blog:
    Tax Controversy 360
  • Organization:
    McDermott Will & Emery
  • Article: View Original Source

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