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Understanding the New Qualified Intermediary (QI) Program for Foreign Financial Institutions
Thomas Dick
Partner
DLA Piper LLP
He comes to DLA Piper from KPMG, where he was based in London as a director on the US Tax Desk.
Mr. Dick focuses his practice on business tax issues, including mergers and acquisitions, private investment funds and structured finance investments. His clients have included many multinational companies, funds and institutional investors.
Widely respected as an international tax advisor, he was profiled in the January 2009 Tax Intelligence Report. Its article “A Leader in the Tax Profession” hailed his “valuable tax expertise in both the US and UK,” commenting that it allowed him “to advise multinational clients around the world.”
Before joining KPMG, Mr. Dick practiced tax law at Baker & McKenzie and Fulbright & Jaworski.
He earned his B.A., with honors, at the University of London, King’s College, London, England in 1983; his J.D. at the University of Virginia School of Law in 1988; and his LL.M. in Taxation at Georgetown University Law Center in 1997.
Carol P. Tello
Partner
Sutherland Asbill & Brennan LLP
Carol Tello is a member of Sutherland’s Tax Practice Group and focuses primarily on international tax matters. Her practice includes a broad range of cross-border tax planning and Internal Revenue Service (IRS) controversy matters for both business entities and individuals. Much of her work has been for insurance companies in the cross-border context. She has particular 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.
Jonathan Sambur
Senior Associate
Mayer Brown, LLP
Jonathan Sambur is a senior associate in the Washington, DC office of Mayer Brown, LLP, where his practice is concentrated in the area of international tax issues of US corporations operating overseas and foreign corporations and individuals operating and investing in the United States, including planning, structuring/restructuring, tax examinations, appeals, litigation, regulations, rulings, and legislative work. His practice involves providing advice with respect to the qualified intermediary regime and US withholding tax, deferral/subpart F planning, foreign tax credits, international tax planning and business structuring, source of income, tax treaties, trade or business/permanent establishment, and other issues.
Prior to joining Mayer Brown, Jonathan was an attorney-advisor in Branch 2 of the Internal Revenue Service, Office of Associate Chief Counsel (International) where, among his other duties, he provided advice interpreting section 1441 and other qualified intermediary issues.
Marvin S. Michelman
Firm Director
Deloitte Tax LLP
Professional Experience
Mr. Michelman has over 40 years experience, and is an expert on information reporting and IRS practice and procedure. Prior to joining Deloitte Tax LLP, he worked with the Internal Revenue Service for 19 years where he served as the Senior Regional Analyst responsible for examination and information gathering projects. Mr. Michelman was the Chairman of IRPAC (Information Reporting Program Advisory Committee) of the IRS in 1997. He advises clients regarding the information reporting, withholding and employment tax impact of complex tax situations such as mergers and acquisitions. He also represents clients who have been assessed penalties by the IRS.
Professional and Civic Activities
- Past Chairperson, IRS Commissioner's Information Reporting Program Advisory Committee (IRPAC)
- American Institute of Certified Public Accountants
- New York State Society of Certified Public Accountants
- New Jersey Society of Certified Public Accountants
- Board Member – Board of Advisors of the Global Institute for Taxation, St. John’s University
- Advisory Board of Tax Hotline
Education
- BS – New York University
Understanding the New Qualified Intermediary (QI) Program for Foreign Financial Institutions
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