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The New FATCA Regulatory Guidance: Understanding Its Scope and How It Applies
LIVE Webcast
Michael H. Plowgian
Attorney-Advisor, Office of the International Tax Counsel
U.S. Department of the Treasury
Michael Plowgian is an Attorney-Advisor in the Office of the International Tax Counsel at the Department of the Treasury. Previously, he was an attorney in the tax group at King & Spalding LLP, where his practice focused on a wide range of domestic and international tax planning matters.
Michael received his J.D. from Harvard Law School, a M.A.L.D. from the Fletcher School of Law and Diplomacy, and a B.A. from Denison University.
Carol Tello
Partner (Former Associate Chief Counsel (International) and Special Assistant to the Assistant Commissioner (International), Internal Revenue Service)
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.
Her prior experience includes service in the IRS Office of Associate Chief Counsel (International) and as a Special Assistant to the Assistant Commissioner (International). While at the IRS, she participated in a number of income tax treaty negotiations, was the IRS National Office adviser in several Tax Court cases, and worked on various regulations and other guidance, including significant participation in developing regulations concerning the taxation of software transactions.
Alan Winston Granwell
Partner
DLA Piper
Alan Winston Granwell is an international tax partner resident in DLA Piper's Washington, DC office. Mr. Granwell’s practice encompasses representing multinational corporations on cross-border planning, to include acquisitions, dispositions and business restructurings, IP migrations, services arrangements, repatriation planning, international transportation, cross-border leasing, transfer pricing and the use of bilateral tax treaties. He also advises high-net-worth individuals on cross-border tax planning and structuring.
Recently, Mr. Granwell has become active in advising investors from emerging countries engaged in cross-border transactions involving the United States and Europe and in advising financial institutions and their clients on international tax enforcement initiatives. He conducts an active administrative practice, regularly representing clients before the Internal Revenue Service and the US Treasury Department (including negotiating advance pricing agreements, conducting competent authority proceedings, advising taxpayers on voluntary disclosures, assisting clients in obtaining regulatory changes and tax rulings and advising clients on tax legislation matters).
Philip Garlett
Partner
Burt, Staples & Maner, LLP
Philip Garlett is a partner in Burt, Staples & Maner, , LLP, Washington, D.C. He specializes in international tax matters.
Prior to joining the firm, Mr. Garlett was the Special Counsel to the Deputy Associate Chief Counsel (Strategic International Programs) and the Deputy Associate Chief Counsel (International Field Service and Litigation) within the Office of Associate Chief Counsel (International). He served as the office's international tax shelter coordinator and as a national office contact for IRS field counsel attorneys. From 2001 to 2005, Mr. Garlett was the Head of the Harmful Tax Practices Unit at the Organisation for Economic Co-operation and Development (OECD) in Paris, France. Before joining the OECD, Mr. Garlett was a Senior Technical Reviewer in the IRS's Office of Associate Chief Counsel (International) where he had primary responsibility for the IRS's efforts to improve non-resident withholding and information reporting on cross-border payments. Mr. Garlett was the primary drafter of many portions of the withholding and information reporting regulations as well as the Qualified Intermediary Agreement. He received the IRS Office of Chief Counsel's National Award for Technical Guidance in 2000.
Mr. Garlett received his J.D. and LL.M. (Taxation) from the New York University School of Law and a Bachelor of Arts degree from The Johns Hopkins University.
Patricia Ann Fisher
Director
PricewaterhouseCoopers
Ann Fisher is a Director on PwC's IRS Service Team where she assists clients in all aspects of domestic and international tax withholding, reporting, documentation, compliance, and remediation, including the impact of major legislative and regulatory changes. Prior to joining PwC, Ann had extensive experience at a large multinational bank where she advised various business areas globally to ensure the accuracy of U.S. tax benefits claimed under the Internal Revenue Code and treaties, including both current rules and anticipated legislative, regulatory, and other changes. Before joining the private sector, Ann served as an Attorney-Advisor for Tax Legislation in the Office of International Tax Counsel within the Office of Tax Policy of the U.S. Treasury Department. Prior to her Treasury experience, she served as an Attorney-Advisor and later as a senior Technical Reviewer in the Office of the Associate Chief Counsel (International) within the IRS Office of Chief Counsel.
Candace B. Ewell
Director
PricewaterhouseCoopers
Candace Ewell is a Director in PricewaterhouseCoopers’ IRS Service Team. Since she joined the Firm in June 2007, Candace has worked with clients to ensure information reporting compliance and to remediate compliance failures as part of the IRS Service Team’s global information reporting and withholding tax practice (e.g., Forms 1099 and backup withholding and Forms 1042/1042-S with respect to payments to nonresident foreign persons). Candace has been a key service provider in assisting our clients with the new cost basis reporting (CBR) requirements. In addition to information reporting and withholding, Candace has experience with Foreign Bank Account Reporting (FBAR).
Specifically, Candace has worked with global financial institutions to remediate documentation compliance gaps. She has reviewed bank's reporting data to identify reportable payments and the proper information return the payment should be reported upon. Candace has conducted interviews with bank operational personnel to ascertain the present state of operations and to identify any operational gaps related to domestic and international information reporting. Candace has worked with client's staff to validate Forms W-8 and W-9. Candace has been the primary technical resource to clients as they develop CBR systems and procedures. She has assisted clients with FBAR compliance.
She is a current member of the IRS' Information Reporting Program Advisory Committee (IRPAC). Prior to joining PwC, Candace spent two years as Assistant Chief Counsel for tax matters at the U.S. Small Business Administration Office of Advocacy (SBA). While at SBA, Candace was responsible for reviewing and analyzing tax regulations and legislation to identify the affect on small businesses. Candace worked extensively with IRS and Treasury personnel, trade associations, and congressional staff to ensure that the views of small businesses where considered in the regulatory and legislative process. In addition, she developed policy positions and proposals to advocate change in tax and pension policies benefiting small businesses.
Prior to joining the SBA, Candace spent four years as an Attorney Advisor in the IRS Office of Associate Chief Counsel (Corporate). During her tenure with the IRS, Candace drafted formal legal opinions on corporate reorganizations, liquidations, redemptions, and consolidated returns. In addition, she researched matters under subchapter C of the Internal Revenue Code proposed legislation, and procedural items.
The New FATCA Regulatory Guidance: Understanding Its Scope and How It Applies
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U.S. Department of the Treasury
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