 |
 |
 |
 |
 |
 |
 |
FY2010 Budget Greenbook Proposes Sweeping Changes to the International Tax Provisions of the Internal Revenue Code
Marc J. Gerson
Member
Miller & Chevalier
Marc Gerson specializes in federal tax policy, providing strategic advice and representation to clients before Congress, the U.S. Department of the Treasury and the Internal Revenue Service. He also maintains a sophisticated domestic and international tax planning and controversy practice.
Prior to rejoining Miller & Chevalier, Mr. Gerson served as Majority Tax Counsel to the U.S. House of Representatives Committee on Ways & Means. He provided policy and technical analysis with respect to the development and evaluation of tax legislation. He counseled the Committee on issues related to international taxation, corporate taxation, tax shelters, financial services taxation, taxation of passthrough entities, tax-exempt bond financing, and tax accounting methods.
Mr. Gerson acted as the staff liaison to Committee members, the Senate Finance Committee, the Joint Committee on Taxation and the U.S. Department of the Treasury. He served as counsel on all major tax legislation enacted in the 109th Congress, including the Gulf Opportunity Zone Act of 2005, the Tax Increase Prevention and Reconciliation Act of 2005, and the Tax Relief and Health Care Act of 2006.
Prior to joining the Committee staff, Mr. Gerson worked as Segment Tax Counsel for Textron, Inc., a Fortune 200 multi-industry company, where he was responsible for all tax functions of its fastener and industrial product business segments. He also practiced law with a number of major law firms, including Miller & Chevalier.
Mr. Gerson is a frequent author and lecturer. He currently serves as a member of the District of Columbia Bar Taxation Section Steering Committee and the CCH International Tax Journal Advisory Board.
Education
The Georgetown University Law Center; 1998, LL.M. (Taxation), with distinction The George Washington Law School, 1993, J.D., with highest honors Emory University, 1990, B.B.A. (Accounting), with high distinction
Leonard Schneidman
Of Counsel
Pepper Hamilton LLP
Leonard Schneidman is of counsel with Pepper Hamilton LLP, resident
in the Boston office. Mr. Schneidman focuses his practice on U.S. and
international tax planning and the tax aspects of corporate transactions.
He is a Fellow of the American College of Tax Counsel.
Mr. Schneidman’s practice includes:
- assisting U.S. companies in the tax-efficient structuring of their activities abroad, principally in Western Europe
- counseling foreign clients on the tax-efficient structuring of their investments in the United States
- counseling domestic and foreign clients on U.S. federal income tax planning for their intellectual property assets
- advising with regard to U.S. state and local tax planning for intellectual property assets
- advising with regard to federal income tax planning for domestic and cross-border mergers and acquisitions.
Mr. Schneidman is the author of the book, U.S. Taxation of Foreign Portfolio Investors: A Practical Guide
to Taxation in the U.S. Capital Markets (Boulder Publishers, Inc., 2006).
Mr. Schneidman is listed in The Best Lawyers in America, Euromoney’s Guide to the Leading U.S. Tax
Lawyers and The International Who’s Who of Business Lawyers (Corporate Tax).
Mr. Schneidman served for two years as attorney-advisor to Judge Gradon G. Withey of the U.S.
Tax Court. Before joining Pepper in 2006, he was a partner with Foley Hoag LLP, where he had
been chair of that firm’s Tax Department.
Mr. Schneidman received his B.A., cum laude, from Hobart College in 1962, his LL.B. from Harvard
Law School in 1965, and an LL.M. in taxation from New York University School of Law in 1966.
He is a member of the Massachusetts and New York bars.
Chad Koebnick
Managing Director, International Tax Services
RSM McGladrey
Chad Koebnick is the executive managing director for the international tax services economic unit of RSM McGladrey. As executive managing director, he is responsible for development of firm client service offerings, technical leadership in the industry, and alignment of the International Tax economic unit within the broader tax service line of the firm.
Chad is also responsible for recruiting and placement of individuals to continue the position of RSM International Tax as a premier provider of choice for client needs.
Chad is a frequent speaker on international tax topics and their application to various industries. Speaking engagements have included several organizations throughout the Country.
Chad is currently responsible for the RSM McGladrey tax initiative to address the convergence of GAAP and IFRS for tax purposes. In addition, he is also responsible for the initiative to address the Obama multinational tax proposals.
He has been an income tax specialist throughout his career. Since the beginning of his career, he has assisted clients in finding solutions to their domestic and international income tax issues.
Chad began his career in the Bloomington Minnesota office of McGladrey & Pullen LLP and has been located in the Minneapolis office since 1996. Chad was promoted to Partner with the firm in 2001.
Chad has devoted much of his time to assisting clients with problem solving and addressing tax issues affecting international businesses. Areas of specialty include: maximization of export incentives; global tax supply chain analysis; worldwide effective tax rate planning; cross-boarder merger and acquisition transactions; efficient foreign investment planning.
Cynthia K. Hustad
Director, Tax Controversy Services
Deloitte Tax LLP
Cindy is the Director of the Northern California/Pacific Northwest Tax Controversy Services practice for Deloitte and represents corporate clients before the IRS. During her ten-year tenure at Deloitte, Cindy has successfully represented many large and small clients, both at the examination and appeals levels. Prior to joining Deloitte, Cindy was an attorney with the IRS Chief Counsel’s Office for 12 years where she represented the IRS in U.S. Tax Court in over 50 litigated cases. During her period at the IRS, Cindy also advised large case agents, international examiners, and appeals officers in some of the largest examinations undertaken by the IRS involving a wide range of complex international and domestic corporate issues. Cindy also has represented the government in litigating several large corporate tax and transfer pricing cases, including DHL v. Commissioner.
FY2010 Budget Greenbook Proposes Sweeping Changes to the International Tax Provisions of the Internal Revenue Code
Speaker Firms:
Upcoming events.