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Understanding the IRS New Contract Manufacturing Rules
LIVE webcast
Ethan Atticks
Senior Technical Reviewer of Branch 2, Office of the Associate Chief Counsel (International)
Internal Revenue Service
Ethan Atticks is the Senior Technical Reviewer of Branch 2 in the Office of the Associate Chief Counsel (International) of the Internal Revenue Service. In this position he works primarily on matters related to the subpart F and PFIC anti-deferral regimes. Prior to joining the Service in 2003, Mr. Atticks worked as an associate in the tax department of the Washington D.C. office of Dow, Lohnes & Albertson PLLC from 1999 to 2003. Mr. Atticks received his B.A. in Philosophy from the College of William and Mary in 1995, a J.D. from the University of Virginia School of Law in 1999, and an LL.M in taxation from the Georgetown University Law Center in 2003.
William P. Elliott, CPA,. ABV/CVA, J.D.,LL.M.
Partner and Firm Director of International Tax
Cherry, Bekaert & Holland, L.L.P.
Bill is a Certified Public Accountant and international tax lawyer with more than 25 years of
diversified tax planning and compliance experience. As the Firm Director of International Tax,Bill directs the specialized services and worldwide resources of the Firm to meet the international tax needs of clients firm-wide.
Based in the Firm’s Washington office, Bill provides clients with a full range of international tax and accounting services, including international and offshore taxation and planning, wealth preservation and asset protection, domestic taxation, management and business consulting, and litigation and legal advisory services.
Bill specializes in providing strategic planning and advisory services to assist clients across a wide array of industries with inbound and outbound entity transactions, foreign and domestic estate and income tax planning, transfer pricing, intangible and intellectual property valuation, asset protection planning, captive insurance arrangements, expatriate taxation, offshore e-commerce planning, and corporate and pass-through entity taxation and consulting.
Widely recognized for his expertise in tax matters, Bill writes and edits extensively for CCH’s TAXES - The Tax Magazine® as well as CCH’s S corporation publications, The Journal of International Taxation, Tax Notes International, and other leading domestic and international tax journals and publications. He has also developed international tax CPE programs, and speaks frequently at leading tax and international tax programs directed to practitioners as well as individuals and companies.
Bill graduated with honors from Millsaps College, where he received his Bachelor of Business Administration in Accounting degree. He received his Juris Doctor from the Concord Law School, and graduated summa cum laude with a Master of Law degree (LLM) in International Taxation from St. Thomas University School of Law.
Licensed to practice as a CPA in Alabama, Kentucky, Mississippi, New York, Tennessee and Virginia, Bill is a member of the American Institute of Certified Public Accountants (AICPA); the Tennessee, Georgia, and Mississippi Societies of CPAs; the International Tax Planning Association (ITPA); and the International Fiscal Association (IFA). In addition, Bill is a credentialed business valuation and appraisal professional, holding the ABV (Accredited in Business Valuation) and the CVA (Certified Valuation Analyst) designations.
Carol P. Tello
Partner,(Former 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.
H. David Rosenbloom
Member, (Former International Tax Counsel and Director, Office of International Tax Affairs, U.S. Department of Treasury)
Caplin & Drysdale
** Speaker Bio to be added soon.. **
Understanding the IRS New Contract Manufacturing Rules LIVE Webcast
Speaker Firms:
Internal Revenue Service
Sutherland Asbill & Brennan LLP
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