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United States

Kenneth B. Clark

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Chair, Tax Litigation Group / Partner, Tax Group

Fenwick & West LLP

+1 650 335 7215

kclark@fenwick.com

www.fenwick.com

Emphasis:

Tax Controversy

Dispute Prevention

Kenneth Clark is a partner in the Tax Group of Fenwick & West and has served as Chair of its Tax Controversy Practice since its formation. Fenwick has received numerous accolades for its tax controversy practice, including recognition by International Tax Review as the top controversy practice in North America and as U.S. tax litigation firm of the year in several different years. The principal focus of Kenneth's practice is complex federal tax litigation and tax controversy work, particularly involving international matters. He regularly practices in the U.S. Tax Court and has published a number of articles relating to tax controversies. Fenwick has worked on more than 75 federal tax litigations.

Kenneth has worked on numerous high profile tax controversy matters, for clients such as Xilinx, The Limited, L Brands, Textron, Chrysler AG, G.M. Trading, Dover Corporation, Adaptec, Analog Devices, Sanofi SA, Cameco and CBS. A number of these matters have resulted in important reported decisions.

With four decades of experience, Kenneth also has managed a variety of complex tax disputes in the U.S. and in a number of foreign countries. He is included in International Tax Review's World's Controversy Leaders and Euromoney's World's Leading Transfer Pricing Advisors. Litigation prevention and alternative dispute resolution have been important parts of his practice; he has served as Fenwick's ADR coordinator, been an AAA arbitrator, and been involved in numerous mediations and arbitrations.

Ken received a B.A. from the University of Redlands, where he graduated summa cum laude, and was first in his class. He received a J.D. from New York University School of Law, cum laude, and was a member of that school's Law Review. Kenneth also received an MBA from the University of California, Berkeley. He has extensive experience in teaching speaking techniques.

Kenneth is a member of the State Bars of California and New York. He is also admitted to practice in the U.S. Tax Court and numerous federal courts.

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Ward Connolly

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Principal

PwC National Tax Services

San Jose, California

+1 408 817 8234

ward.connolly@pwc.com

pwc.com

Languages: English

Bar admissions: California

Biography

Ward represents both U.S. and foreign multinational Corporations with complex tax issues. Ward has been recognized as one of the World's Leading Tax Controversy Advisers by ITR, and recognized in Legal Media Group's Expert Guides and ITR's "World Tax" for his skills in transfer pricing.

Recent matter highlights

  • Ward has resolved a substantial number of tax disputes at the IRS exam level, with IRS Appeals, through mediation, and via advance pricing agreements (APAs).

Practice areas

Cost-sharing arrangements, APAs, Audit defence, Dispute resolution, Transfer pricing

Sector specialisations

Automotive, Consumer goods and services, Media, Pharma and life sciences, Tech and telecoms

Academic qualifications

J.D., with Honors, Duke University School of Law, 1996

Ph.D. in economics, University of South Carolina, 1989

B.A., University of South Carolina, 1984

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Anthony A. Curtis

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U.S. Consumer Markets Transfer Pricing Leader at PwC

PwC

New York, New York

+1 646 471 0700

anthony.curtis@pwc.com

www.pwc.com/us/en/services/tax/transfer-pricing.html

Languages: English

Biography

Anthony Curtis is a senior economist and Principal at PwC. In his current role, Tony is U.S. Consumer Markets Transfer Pricing Sector Leader for PwC. Tony has 28 years of experience conducting economic analysis and for the last 26 years, he has specialized primarily in transfer pricing including economic analyses for examinations, appeals, APAs, and competent authority negotiations with the IRS and foreign tax authorities as well as TP planning and documentation.

As the TP Consumer Markets leader, Tony serves PwC's leading retail, luxury goods, and consumer products clients to ensure that they have access to the latest ideas and the most experienced personnel of the PwC Global Network. Over his career, Tony has functioned as the NYC Tax Controversy Practice Leader and the TP leader for PwC's NY metro transfer pricing region. In addition, he has led the practice's Globally Coordinated Documentation service offering, and was the Americas editor for PwC's transfer pricing news articles.

Practice areas

Transfer pricing, Economic modelling, APAs, MAP proceedings, Litigation support, Controversy management

Sector specialisations

Consumer goods, retail and services

Academic qualifications

MBA 1992 George Washington University, Post Graduate Taxation studies 1999 Fordham University, BBA 1990 George Washington University

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Paul DiSangro

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Partner

Mayer Brown

San Francisco

+1 650 331 2045

pdisangro@mayerbrown.com

Bar admissions: California

Biography

Paul DiSangro is a trusted advisor to CFOs and tax directors in San Francisco and Silicon Valley. He has 20 years of broad experience across a range of industries including software, technology, financial services (including fintech), insurance, energy, media, pharma, biotech and retail.

Recent matter highlights

  • Transfer pricing, cost sharing and the movement and licensing of intangible property.

  • Maximizing foreign-derived intangible income (FDII) and R&D credits.

  • Minimizing global intangible low-tax income (GILTI).

  • Independent contractor structuring.

  • Dispute resolution with government agencies (IRS, FTB, BOE, EDD, CUIAB, CA Secretary of State, etc.).

Practice areas

Cost-sharing arrangements, Technology, Cryptocurrency, Dispute resolution, Litigation, Transfer pricing

Sector specialisations

Banking, Consumer goods and services, Financial services, Pharma and life sciences, Tech and telecoms

Association memberships

U.S. Tax Court

U.S. Court of Federal Claims

Academic qualifications

LLM Taxation, Georgetown University

JD, University of Miami

BA, Georgetown University

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David L. Forst

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Partner, Tax Group

Fenwick & West LLP

+1 650 335 7254

dforst@fenwick.com

Emphasis:

International Corporate and Partnership Taxation

David Forst focuses on international corporate taxation. David is included in Euromoney's Tax Advisors Expert Guides (World's Leading Tax Advisors, World's Leading Transfer Pricing Advisors and was named one of the Top 30 U.S. Tax Advisors). He is also in the Legal 500 Hall of Fame and Law and Business Research's International Who's Who of Corporate and Tax Lawyers (for the past seven years). David is listed in Chambers USA America's Leading Lawyers for Business, and has been named a Northern California Super Lawyer in Tax by San Francisco Magazine.

David is a lecturer at Stanford Law School and UC Berkeley Law School where he focuses on international taxation. He is an editor of and regular contributor to the Journal of Taxation, where his publications have included articles on international joint ventures, international tax aspects of mergers and acquisitions, the dual consolidated loss regulations, and foreign currency issues. He is a regular contributor to the Journal of Passthrough Entities, where he writes a column on international issues. David is a frequent chair and speaker at tax conferences, including the NYU Tax Institute, the Tax Executives Institute, and the International Fiscal Association.

David graduated with an A.B. (cum laude) Phi Beta Kappa from Princeton University's Woodrow Wilson School of Public and International Affairs, and received his J.D., with distinction, from Stanford Law School.

David is a member of the State Bar of California.

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James P. Fuller

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Partner, Tax Group

Fenwick & West LLP

+1 650 335 7205

jpfuller@fenwick.com

www.fenwick.com

Emphasis:

International Tax, Corporate Tax, Mergers & Acquisitions, Joint Ventures, Dispute Resolution

Jim Fuller is a partner in the Tax Group at Fenwick & West LLP in Mountain View, California. Euromoney named Fuller seven times as one of the world's top 25 tax advisers.

He is the only U.S. tax adviser to receive a Chambers star performer rating (higher than first tier) in Chambers USA (2018). He also is one of the three "most highly regarded" U.S. tax practitioners according to Who's Who Legal (Law & Business Research Ltd).

Fuller is the only U.S. tax advisor in Tier 1 for both Corporate Tax and International Tax according to Chambers Global (2018). The Corporate Tax Tier 1 category has fifteen US persons; International Tax Tier 1 has six.

He also is one the US's top 30 transfer-pricing advisors, according to Euromoney (2018).

Among his other recognitions, Legal 500 has included Fuller in its Tax "Hall of Fame."

Ten Fenwick tax partners have appeared in Euromoney's World's Leading Tax Advisors, eight appear in ITR's World's Tax Controversy Leaders and five have appeared in Euromoney's World's Leading Transfer Pricing Advisors.

Fenwick has represented 6 of the Fortune Top 10 companies, over 50 of the Fortune 100 companies, and over 100 of the Fortune 500 companies in federal tax matters.

Fuller and his firm have served as counsel in over 150 large corporate IRS Appeals proceedings and over 75 large-corporate federal tax court cases. Some of these have been for Fortune Top 10 companies.

Fenwick is first tier in Tax Planning, Tax Transactional, World Tax and Transfer Pricing, according to International Tax Review published in 2017–2018. Only 4 US law firms are first tier in each of these surveys/publications.

International Tax Review named Fenwick & West "Tax Firm of the Year for the San Francisco Area" nine times in the past 12 years and "US (or Americas) Tax Litigation Firm of the Year" four times. These ITR awards were given at ITR's very well-attended black-tie awards dinners in New York City. All of the big US law and accounting firms attend these dinners.

Fenwick also was named US West Transfer Pricing Firm of the Year. Fenwick was named "Americas M&A Tax Firm of the Year" at one of these dinners, and in 2014–2018 Fenwick received a number of ITR's M&A Tax Deal of the Year awards. Most involved international M&A transactions. Fenwick also received ITR's Joint Venture of the Year award for Symphony Communications, a JV in which 13 major NY banks were involved.

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Jennifer L. Fuller

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Partner Emeritus, Tax Group

Fenwick & West LLP

+1 650 335 7284

jfuller@fenwick.com

www.fenwick.com

Emphasis:

General Taxation Advice

Jennifer Fuller is a Partner Emeritus in the Tax Group at Fenwick & West LLP in Mountain View, California. She was included for the fourth time as one of the world's top 25 women tax advisers in Euromoney's Worlds Leading Women Business Lawyers (2015), and was invited again to write an introduction to the publication.

Ms. Fuller was named "America's Best in Tax Dispute Resolution" by Euromoney at its 2014 and 2015 Americas Women in Business Law Awards Dinner. She also has been on Euromoney's Women in Business Law short list three times for the award "Best in Tax."

Ms. Fuller's work during 2015 included large-corporate tax litigation and M&A matters, including work on some of the recent and widely publicized "inversion" transactions.

Ms. Fuller has been on the Executive Leadership Committee of the International Fiscal Association, which is a highly-regarded worldwide association of leading tax advisors, and has appeared regularly in Euromoney's World's Leading Tax Lawyers.

Ms. Fuller has served as the Northern California Chair for the California State Bar International Tax Committee. She has spoken at and chaired numerous seminars on international tax subjects. Ms. Fuller's articles have appeared in Tax Notes International magazine and in Tax Notes magazine.

Whittier College awarded Ms. Fuller its Alumna Achievement Award in 2013 "for superior accomplishments in her career." Later that year, Ms. Fuller was elected to serve, and she continues to serve, on the Whittier College Board of Trustees.

Ms. Fuller has been a tax partner at Fenwick for over 20 years, and plays an instrumental role in the firm's tax practice. The firm has represented 6 of the Fortune top 10 companies, over 50 of the Fortune 100 and over 100 of the Fortune 500 companies in federal tax matters.

International Tax Review gave Fenwick & West its San Francisco Tax Firm of the Year Award nine times through 2017, and has given F&W its America's (or US's) Tax Litigation Firm of the Year award four times. F&W also has received M&A tax awards at the ITR Americas Awards dinners, including Americas M&A Tax Firm of the Year.

Ms. Fuller also has been included in Euromoney's Guide to the World's Leading Tax Advisors, Law and Business Research's International Who's Who of Corporate Tax Lawyers, ITR's Leading Lawyers in the Western U.S., Euromoney's Guide to the Leading U.S. Tax Lawyers, and International Tax Review's Best Tax Advisers in North America.

Jennifer is a member of the State Bar of California.

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Adam S. Halpern

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Chair, Tax Group

Fenwick & West LLP

+1 650 335 7111

ahalpern@fenwick.com

www.fenwick.com

Emphasis:

International Corporate Tax

Adam Halpern is the Chair of the Tax Group at Fenwick & West LLP. His practice focuses on the U.S. federal income taxation of international transactions. He regularly advises on the taxation of cross-border operations, acquisitions, dispositions and restructurings. He has successfully represented clients in federal tax controversies at all levels.

Adam is a lecturer in law at Stanford Law School, teaching classes in international tax, and is a frequent speaker at TEI and PLI.

Adam is recognized as a leading tax lawyer by Euromoney's World's Leading Tax Advisors, International Tax Review and Chambers USA. He also appears in ITR's Tax Controversy Leaders.

The Fenwick & West Tax Group has advised over 100 Fortune 500 companies on tax matters, and has served as counsel in more than 150 large-corporate IRS Appeals proceedings and more than 75 federal court tax cases. Recent published cases include Analog Devices, Inc. v. Commissioner, 147 T.C. No. 15 (2016), CBS Corp. v. United States, 2012-1 U.S.T.C. ¶50,346 (Fed. Cl.), and the landmark Xilinx, Inc. v. Commissioner, 125 T.C. 37 (2005), aff'd, 598 F.3d 1191 (9th Cir. 2010), described by the Wall Street Journal as "the biggest tax case in the last 20 years."

Fenwick has been named San Francisco Tax Firm of the Year and U.S. Tax Litigation Firm of the Year numerous times by International Tax Review.

Adam graduated summa cum laude from the University of California, Hastings College of the Law, and has an A.B. in Philosophy from Princeton University.

He is a member of the State Bar of California and the American Bar Association Section of Taxation.

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John T. Hildy

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Partner

Mayer Brown LLP

Chicago

+1 312 701 7769

mayerbrown.com

Languages: English

Bar admissions: Illinois

Biography

John is an experienced advocate in federal tax disputes faced by multi-national corporations. He has represented clients in some of the most complex tax litigation in the country. The mainstay of John's controversy practice relates to disputes surrounding international tax matters, especially transfer pricing.

Recent matter highlights

In May 2018, a Mayer Brown team led by John completed the process of settling the Guidant/Boston Scientific transfer pricing dispute, thus averting a ten week trial. As finalized, the settlement brings a favorable conclusion a case that has been one of the largest and most complex transfer pricing matters docketed in the Tax Court. John is currently representing Hyatt Hotels Corporation in a tax case recently filed in the U.S. Tax Court.

Practice areas

Audit defence, Dispute resolution, Pre-litigation, Litigation, Transfer pricing

Sector specialisations

Consumer goods and services, Insurance, Pharma and life sciences, Tourism

Academic qualifications

JD, Northwestern University School of Law, 1996

BA, University of Illinois, 1993

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Sharon Katz-Pearlman

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Global Head and US National Principal in Charge, Tax Dispute Resolution & Controversy

KPMG LLP

New York

+1 212 872 6084

skatzpearlman@kpmg.com

home.kpmg.com/xx/en/home/services/tax/dispute-resolutioncontroversy.html

Languages: English, French

Bar admissions: New York State

Biography

Sharon represents multinationals and financial institutions before the IRS. She advises on various disputes matters with substantial experience in transfer pricing, competent authority and domestic corporate issues. An Adjunct Professor of Law at NYU Law School, she was recently appointed to the UN Tax Committee's Subcommittee on MAP, Dispute Avoidance and Resolution, which has been charged with drafting the "United Nations Handbook on Dispute Avoidance and Resolution".

Recent matter highlights

  • Represented major financial institution in IRS exam and MAP proceeding, obtaining resolution on billion dollar (USD) issue involving losses from financial crisis;

  • Representation of several foreign owned entities in voluntary disclosures on issues arising from US employment tax compliance;

  • Obtained pre-filing agreements on a variety of corporate issues, providing certainty in advance of return filing.

Practice areas

Audit defence, Dispute resolution, Pre-litigation, MAPs/ADRs, Controversy management, Voluntary disclosures; Cross border project management; transfer pricing

Sector specialisations

Banking, Consumer goods and services, Financial services, Tech and telecoms

Association memberships

American Bar Association; New York State Bar Association

Academic qualifications

LLM (Tax); New York University School of Law

JD, cum laude: Cardozo School of Law, Yeshiva University

BA, cum laude; Barnard College, Columbia University

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Andrew J. Kim

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Partner, Tax Group

Fenwick & West LLP

+1 650 335 7146

akim@fenwick.com

www.fenwick.com

Emphasis:

Domestic and International Corporate Taxation

Andrew Kim is a partner in the Tax Group of Fenwick & West LLP. His practice focuses on domestic and international corporate tax matters and tax dispute matters. Mr. Kim has significant experience in representing clients with respect to cross-border transactions, corporate restructurings, international joint ventures, transfer pricing and dispute resolution matters.

Mr. Kim served as counsel in Analog Devices, Inc. v. Commissioner in the U.S. Tax Court, and CBS Corporation v. United States in the U.S. Court of Federal Claims, and currently serves as counsel in TBL Licensing LLC v. Commissioner in the U.S. Tax Court.

Mr. Kim appears in Euromoney's World's Leading Tax Advisors, International Tax Review's Tax Controversy Leaders, Law Business Research's Who's Who Legal: Corporate Tax, The Legal 500 and Chambers USA.

Mr. Kim is a lecturer at the University of California, Berkeley, School of Law, where he teaches international taxation. He has published articles on international tax issues and developments in the Journal of Taxation, International Taxation, the Euromoney Corporate Tax Handbook and World Tax. Mr. Kim frequently speaks on international tax issues at meetings for professional tax groups, including the Tax Executives Institute and Bloomberg BNA.

Fenwick's tax practice has earned a reputation as one of the nation's leading domestic and international tax practices. Fenwick was named U.S. (or Americas) Tax Litigation Firm of the Year four separate times by ITR. Fenwick has also been recognized by ITR as first tier in both its World's Leading Tax Planning Firms and World's Leading Transactional Firms guides, and has been recognized as Americas M&A Tax Firm of the Year. Fenwick also received ITR's Joint Venture of the Year award for Symphony Communications, a JV in which 13 major NY banks were involved.

Mr. Kim received his J.D., cum laude, from Harvard Law School, and B.S. in Psychology with highest honors from the University of Illinois.

Mr. Kim is a member of the State Bar of California.

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Thomas Kittle-Kamp

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Partner

Mayer Brown LLP

Chicago

+1 312 701 7028

tkittlekamp@mayerbrown.com

mayerbrown.com

Biography

Tom Kittle-Kamp is the co-leader of Mayer Brown's tax controversy and transfer pricing practice. He has extensive litigation experience in major corporate taxes and maintains an active practice in advising clients on with respect to administrative matters, including IRS audits, IRS Appeals, and competent authority negotiations.

Practice areas

Cost-sharing arrangements, APAs, Corporate taxes, Litigation, Transfer pricing

Sector specialisations

Accounting, Energy, Pharma and life sciences, Tech and telecoms

Academic qualifications

Bradley University, B.A. Northwestern University Pritzker School of Law J.D.

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Brian Kittle

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Partner & Co-Leader Tax Controversy & Transfer Pricing Practice

Mayer Brown LLP

New York

+1 212 506 2187

bkittle@mayerbrown.com

www.mayerbrown.com/people/brian-w-kittle/

Languages: English

Bar admissions: New York, Illinois

Biography

Brian Kittle is co-leader of Mayer Brown's Tax Controversy & Transfer Pricing practice. Brian represents clients in every facet of tax controversy and litigation, including MAP and APA matters.

Recent matter highlights

  • Brian was integrally involved in the Eaton transfer pricing case, in which the US Tax Court ruled in Eaton's favor by holding that the IRS's cancellation of two APAs was invalid.

  • He has successfully resolved scores of taxpayers in connection with challenges to their capital structure. He also advises clients on the impacts of tax reform on their capital structure.

  • He has successfully resolved several complex sub-part F issues related to complex legal and factual matters.

Practice areas

Economic modelling, Corporate taxes, Pre-litigation, Litigation, International tax advisory

Sector specialisations

Banking, Financial services, Healthcare, Industrials, Tech and telecoms

Association memberships

ABA member

Academic qualifications

Georgetown University Law Center, LLM in Taxation, with distinction

Buffalo Law School, JD, cum laude

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Kenneth Klein

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Partner

Mayer Brown LLP

Washington, DC

+1 202 263 3377

kklein@mayerbrown.com

www.mayerbrown.com

Languages: English

Bar admissions: Washington, DC

Biography

Ken Klein concentrates his practice on international taxation, including planning, transactions, restructurings, tax controversies in IRS Examination and in IRS Appeals, public policy, and IRS rulings. Ken represents both US and nonUS based multinationals in numerous industries. He is a former senior IRS official.

Recent matter highlights

  • Successfully defended in IRS Appeals proposed IRS Examination income adjustments of hundreds of millions of dollars of transportation income.

  • Successfully defended in IRS Appeals proposed IRS Examination income adjustments of hundreds of millions of dollars of high tech intercompany sales transactions.

  • Several global restructurings resulting from the 2017 tax reform law and the OECD BEPS initiative.

  • Post-acquisition restructuring of a large transportation company.

Practice areas

Restructuring, Corporate taxes, Audit defence, US Inbound, US Outbound

Sector specialisations

Agriculture, Consumer goods and services, Government and public policy, Pharma and life sciences, Shipping, Tech and telecoms

Association memberships

American Bar Association

International Fiscal Association

Chair, Washington International Tax Study Group

President (2016-2018), Legal Aid Society of the District of Columbia

Academic qualifications

Master of Laws in Taxation, Georgetown University Law Center, 1980

Juris Doctor, University of Georgia School of Law, 1976

Bachelor of Arts, University of Delaware, 1973

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Larry Langdon

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Partner

Mayer Brown LLP

Palo Alto

+1 650 331 2075

llangdon@mayerbrown.com

mayerbrown.com

Languages: English

Bar admissions: California

Biography

Prior to Mayer Brown, Larry Langdon was IRS Commissioner, LMSB, and VP, Taxes, Licensing and Customs at Hewlett-Packard Company. Earlier, Larry held senior positions at IRS Chief Counsel's Office, Ford Motor Company General Counsel's and Vetco, Inc. Larry has a J.D. from Ohio State University and a LLM (taxation) from New York University

Recent matter highlights

Expert assistance in successful resolution of tax issues at IRS audit and Appeals. Confidential matters involved.

Practice areas

Cost-sharing arrangements, Corporate taxes, Audit defence, Audit support, Dispute resolution, Transfer pricing, State and local tax controversity advising; non-profit organization matters

Sector specialisations

Accounting, Automotive, Banking, Energy, Financial services, Government and public policy, Healthcare, Industrials, Investment management

Association memberships

California bar and ABA tax section

Academic qualifications

B. Sc. In Bus. Adm. Ohio State University 1959; J.D., Ohio State University 1961; LL.M. (Taxation), New York University, 1963

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William G. McGarrity

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Partner

Mayer Brown LLP

Chicago

+1 734 417 3601

wmcgarrity@mayerbrown.com

www.mayerbrown.com/people/william-g-mcgarrity/

Biography

Will McGarrity represents clients in all stages of tax controversies, advises clients on transfer pricing documentation, and helps clients assess and prepare for potential controversies. His work encompasses international issues related to transfer pricing, cost sharing, valuation, treatment of goodwill, debt-equity, and economic substance.

Recent matter highlights

  • Altera Corp. v. Commissioner (Cost sharing, U. S. Tax Court and Ninth Circuit Court of Appeals)

  • Tyco International (Debt-equity characterization, 15 docketed cases in U.S. Tax Court)

  • Guidant/Boston Scientific (Transfer pricing, 6 docketed cases in U.S. Tax Court)

Practice areas

Cost-sharing arrangements, Audit defence, Litigation, Transfer pricing

Sector specialisations

Food and beverage, Government and public policy, Healthcare, Pharma and life sciences, Tech and telecoms

Academic qualifications

JD, Harvard Law School, 2010

LLM, University of Cambridge, 2009

BBA, University of Michigan, 2006

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Larissa Neumann

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Partner, Tax Group

Fenwick & West LLP

+1 650 335 7253

lneumann@fenwick.com

www.fenwick.com

Emphasis:

International Tax, Corporate Tax, Transfer Pricing

Larissa Neumann focuses her practice on U.S. tax planning and tax controversy with an emphasis on international transactions. She has broad experience advising clients on mergers and acquisitions, restructurings and has extensive transfer pricing experience.

Keen analytical skills coupled with a focus on providing clients practical solutions to complex tax issues have earned Larissa a reputation as a leading tax advisor both in the Silicon Valley and nationwide. She appears in Euromoney's World's Leading Tax Advisers and International Tax Review's World's Tax Controversy Leaders. Euromoney's Women in Business Law named Larissa America's Best Transfer Pricing Lawyer in 2017 and 2018. She also is consistently named by Euromoney as one of the World's Leading Transfer Pricing Advisors.

Larissa has successfully represented clients in federal tax controversies at the audit level and in appeals, Tax Court and other federal courts. She was counsel in the recent important taxpayer victory for Analog Devices, Inc. v. Commissioner, 147 T.C. No. 15 (2016), and the successful resolution for Sanofi in Aventis, S.A. v. United States, US Court of Federal Claims Dkt. No. 11647T. She currently is counsel for VF Corporation/Timberland in TBL Licensing LLC v. Commissioner, Tax Court Dkt. No. 21146-15.

Larissa teaches International Tax at the University of California, Berkeley, School of Law.

For Tax Notes International, Larissa coauthors a monthly column on all recent development in U.S. international tax. She is also on the executive committee of the International Fiscal Association (IFA) and serves as the Chair of the Technology Committee.

Larissa appears in Euromoney's Women in Business Law (a short list of the top women tax lawyers in the world) and ITR's Women in Tax Leaders. She has also been shortlisted for Euromoney's Women in Business Law America's Best Lawyer in Tax Dispute Resolution.

Larissa was named to the Daily Journal's 2017 list of Top Women Lawyers in California and was honored with the Women of Influence award by the Silicon Valley Business Journal in 2017.

Larissa frequently speaks at conferences for professional tax groups, including TEI, IFA, Pacific Rim Tax Institute, and the ABA. She is the ABA International Law Tax Liaison.

Fenwick has one of the World's Top Tax Planning and Transactional Practices, according to ITR, and is first tier, according to World Tax. Fenwick is consistently named the San Francisco Tax Firm of the Year by ITR and has been named U.S. Tax Litigation Firm of the Year. ITR has recognized Fenwick as the Americas M&A Tax Firm of the Year and the West Coast Transfer Pricing Firm of the Year.

Fenwick has advised over 100 Fortune 500 companies on tax matters, and has served as counsel in more than 150 large-corporate IRS Appeals proceedings and more than 75 federal court tax cases.

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Kathryn Horton O’Brien

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Principal

PwC

New York

+1 646 471 1084

kathryn.obrien@pwc.com

Languages: Engligh

Bar admissions: DC PA

Biography

Kathryn is a Principal in PwC's National Tax Transfer Pricing practice and is PwC's Global Asset Management Transfer Pricing Leader. She is assisting clients with all aspects of transfer pricing: planning, compliance, APAs and controversy. She is one of PwC's leading experts on BEPS transfer pricing and permanent establishment matters.

Recent matter highlights

Kathryn has been working, personally, with more than 25% of the Fortune 100 in their efforts to comply with BEPS Action 13.

Kathryn is also assisting with the application of the transfer pricing elements of US Tax Reform.

Practice areas

Business model optimisation, APAs, Financial services, Value chains, Controversy management, Transfer pricing

Sector specialisations

Banking, Financial services, Industrials, Investment management, Oil and gas

Academic qualifications

LLM, Georgtown University Law School, 1991

JD, George Washington Law School, 1987

BA, Finance, Michigan State University, 1984

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Shawn R. O’Brien

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Tax Controversy and Transfer Pricing Partner

Mayer Brown

Houston

7133-238-2848

sobrien@mayerbrown.com

www.mayerbrown.com/people/shawn-r-obrien/

Bar admissions: Texas and Louisiana

Biography

Shawn O'Brien represents clients in all types of tax disputes with taxing authorities on international, federal and state levels. He routinely advises clients is different industries on various tax issues during tax examinations, in administrative appeals and as an advocate in trial and appellate litigation.

Recent matter highlights

EOG Resources, Inc.; US Tax Court; $140 mm; settled successfully a very unique case involving the alternative minimum tax. Waste Management; IRS Appeals; Excise Taxes. Williams Companies; Tax Policy. SWM International; various tax matters. Number of major US refiners and terminal owners in significant refund cases involving excise taxes.

Practice areas

Audit defence, Dispute resolution, Pre-litigation, Litigation, International tax advisory, Domestic and International Transactional Tax Advice

Sector specialisations

Accounting, Aviation, Consumer goods and services, Energy, Financial services, Healthcare, Natural resources, Oil and gas, Real estate

Academic qualifications

New York University School of Law, LLM

Taxation 1998

Loyola Law School, JD 1997

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Edward Osterberg

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Partner

Mayer Brown LLP

Houston

+1 713 2382666

eosterberg@mayerbrown.com

www.mayerbrown.com

Languages: English

Bar admissions: Texas

Biography

Mr. Osterberg's practice includes all matters of U.S. federal income taxation with emphasis on partnership, corporate and international taxation. Mr. Osterberg received his B.A. and J.D. cum laude degrees from Northwestern University and an LL.M. in Taxation at Southern Methodist University. He has served in a leading role in various tax groups.

Recent matter highlights

Advised a U.S. corporation on tax aspects of debt or equity classification. Advised a U.S. corporation on the application of the contribution to capital rules. Advised a U.S. taxpayer on the tax aspects of an UpC financing transaction.

Practice areas

Transactions, Corporate taxes, Tax consulting, International tax advisory, US Outbound, U.S. federal income taxation.

Sector specialisations

Energy, Financial services, Oil and gas, Social infrastructure

Association memberships

International Fiscal Association; American Bar Association Section of Taxation; State Bar of Texas Taxation Section; Houston Bar Association; International Tax Forum of Houston.

Academic qualifications

B.A., Northwestern University, Evanston, Illinois; J.D. cum laude, Northwestern University, Chicago, Illinois; LL.M. in Taxation, Southern Methodist University, Dallas, Texas.

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Kevin Otero

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Principal

PwC

New York

+1 646 644 4930

Languages: English, Spanish

Bar admissions: NY, DC

Biography

Kevin is an attorney who represents clients across industries in all stages of tax controversy and has experience litigating in the US Tax Court, Court of Claims and District Courts across the US. He also recently served as Director of Tax Examinations, Appeals, & Litigation for the General Electric Company. Kevin regularly advises clients on matters related to tax risk mitigation across a range of technical tax areas to ensure clients are best positioned from a technical, financial, and reputational perspective.

Recent matter highlights

Kevin consistently and successfully navigates some of the most complex multi-year tax audits for large multinational corporations. Recent matters involved Financial Products, Transactions, Transfer Pricing, Valuations, Tax Credits, Accounting Methods.

Practice areas

Corporate Tax, Audit Defence, Dispute Resolution, Controversy Management, Tax Consulting

Sector specialisations

Energy, Financial services, Healthcare, Industrials, Technology

Academic qualifications

BA, Yale University, 2000

JD, Columbia Law School, 2004

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William A Schmalzl

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Partner

Mayer Brown LLP

Chicago

+1 312 7017225

wschmalzl@mayerbrown.com

mayerbrown.com

Languages: English

Bar admissions: State of Illinois, US District Court for the Northern District of Illinois, US Tax Court, US Court of Federal Claims, US Supreme Court, US Courts of Appeals for 7th, 8th, 9th and 10th Circuits.

Biography

William Schmalzl focuses on tax litigation and corporate tax planning. He represents clients in all stages of tax litigation including audits, administrative proceedings, United States Tax Court, federal district court, courts of appeals and Illinois state courts.

Recent matter highlights

Schmalzl represents international corporations in defending their transfer pricing structures in audits, administrative appeals and litigation. His training in economics provides a solid basis for presenting and cross examining expert witnesses.

He also has extensive experience in persuasively presenting documentary and other evidence to show companies' activities satisfy the requirements for the US research credit.

Practice areas

Corporate taxes, Audit support, Litigation, Controversy management, Transfer pricing

Sector specialisations

Financial services, Food and beverage, Healthcare, Pharma and life sciences, Tech and telecoms

Association memberships

American Bar Association

Chicago Bar Association

Academic qualifications

JD, Harvard Law School, 1977 (magna cum laude)

BA, University of Pittsburgh, 1974 (summa cum laude)

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Ronald Schrotenboer

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Tax Group

Fenwick & West LLP

+1 650 335 7207

rschrotenboer@fenwick.com

www.fenwick.com

Ronald Schrotenboer's published decisions include Xilinx, Inc. v. Commissioner, 125 T.C. 37 (2005), aff'd (9th Cir. 2010) (stock option amounts not required to be cost shared under § 482); Sun Microsystems v. Commissioner 69 T.C.M. 1884 (1995), (incentive stock option deduction qualifies for R&D credit); Appeal of Finnigan Corporation, CCH 401-797 (1990), (throwback rule is applied on a unitary basis; Appeal of Joyce overruled); and Petition of Intel Corporation, CCH 402-675 (1992), (technology transfers are not subject to California sales tax).

Ronald received his BA degree, with honours, in 1977 from Calvin College in Grand Rapids, Michigan. He received his JD degree magna cum laude from the University of Michigan in 1980. He graduated as a member of the Order of the Coif and was an editor on the Michigan Law Review for two years.

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Danielle M. Smith

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Principal

PricewaterhouseCoopers LLP

Stamford

+1 203 908 5962

danielle.smith@pwc.com

Languages: English

Bar admissions: New York

Biography

Danielle is a tax attorney practicing tax controversy and litigation for 20 years. Her practice focuses on partnering with corporate and business tax planning and operations teams throughout the entire life cycle of tax matters. Danielle advises large corporate taxpayers on innovative, proactive, strategic approaches to controversy matters.

Practice areas

Corporate taxes, Dispute resolution, Pre-litigation, Controversy management, Tax consulting

Sector specialisations

Accounting, Banking, Financial services, Industrials, Insurance

Association memberships

American Bar Association

Academic qualifications

Georgetown University Law Center, Washington, DC:

LL.M. in Taxation with Distinction (May 2002)

Certificate in Employee Benefits Law (May 2002)

University at Buffalo Law School, Buffalo, NY:

J.D., Concentration in Finance Transactions and Tax Certificate (May 1998)

North Carolina State University, Raleigh, NC:

B.A., Communication/Public Relations (May 1995)

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Scott M. Stewart

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Partner

Mayer Brown LLP

Chicago

+1 312 701 7821

sstewart@mayerbrown.com

mayerbrown.com

Languages: English

Bar admissions: Illinois U.S. Tax Court

Biography

Scott's practice focuses exclusively on tax disputes, including transfer pricing issues and intercompany debt matters. He has been recognized by Chambers USA each year from 2006 through 2018, which stated that he "frequently leads on market-defining transfer pricing disputes, often with multi-billion dollar outcomes."

Recent matter highlights

Recently Scott led the team that filed 15 Tax Court petitions concerning debt-equity issues on behalf of Tyco International and related companies. The cases, which involved $3 billion in interest expense incurred from 1998 through 2000 and implicated an additional $6.5 billion in interest expense incurred from 2001 through 2007, were settled for 5% of the amount in dispute.

Practice areas

APAs, Value chains, Audit defence, MAPs/ADRs, Litigation, Transfer pricing

Sector specialisations

Consumer goods and services, Food and beverage, Industrials, Pharma and life sciences, Tech and telecoms

Academic qualifications

JD, Harvard Law School, 1989

MBA, Cornell University, 1986

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David Swenson

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Global Network Leader, Tax Controversy and Dispute Resolution

PwC

Washington, DC

+1 202 414 4650

david.swenson@us.pwc.com

pwc.com/taxcontroversy

David Swenson is the global leader of PwC's tax controversy and dispute resolution (TCDR) network and is resident in the Washington, DC office. The TCDR global network includes more than 650 tax controversy professionals, located in upwards of 80 countries across the globe, who assist multinational enterprises to prevent, manage, and resolve tax audits and disputes worldwide.

Following a prominent legal career spanning 25 years, David has substantial experience in advising multinational enterprises (MNEs) on international tax matters, and assisting companies in their efforts to pursue a variety of measures aimed at proactively preventing, efficiently managing, and favourably resolving tax audits and disputes worldwide. Over the years, David has participated in more than 250 tax controversies involving audits and disputes between MNEs and the Internal Revenue Service (IRS), as well as dozens of other revenue authorities around the world.

Many of these tax disputes were resolved at the audit level or through the proactive use of administrative appeals, mediation, arbitration, APAs, or the Competent Authority/MAP process. Other controversies were docketed in a US court of law, proceeded to trial, and resulted in important decisions for MNEs, including cases involving transfer pricing (Bausch & Lomb I), the foreign tax credit (Ampex), Competent Authority matters (Yamaha), the definition of 'manufacturing' for Subpart F purposes (Bausch & Lomb II), foreign currency (Carborundum), and intellectual property rights (Exide/Exxon). David also participated in several landmark tax cases before the US Supreme Court, including the Barclays Bank, Boeing, and Goodyear cases. David has been described as "one of the top five tax controversy experts in the US", and he received recognition as a "leading attorney" in US tax litigation by Chambers US, and as one of the world's top 25 transfer pricing specialists.

In addition, David received a Meritorious Service Certificate from the Treasury Department and IRS, and has been an adjunct professor at Georgetown University Law Center, where he continuously taught courses for 25 years relating to international corporate income taxation. David received his MLT from Georgetown University Law School, and his JD, with honours, and BA, with distinction, from the University of Mississippi. David also has been admitted to practice before the US Tax Court, the US Court of Federal Claims, numerous US Federal Courts of Appeal, and the US Supreme Court.

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Gary B. Wilcox

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Partner

Mayer Brown LLP

Washington, DC

+1 202 263 3399

gwilcox@mayerbrown.com

mayerbrown.com

Languages: English

Bar admissions: District of Columbia, Pennsylvania

Biography

Gary is a member of Mayer Brown's Tax Controversy and Transfer Pricing Practice. He represents multinational corporations in IRS audit, appeals and litigation, and in tax planning. Gary is a former IRS Deputy Chief Counsel, and an author of a BNA portfolio on tax-free reorganizations.

Practice areas

Restructuring, Corporate taxes, Audit defence, Audit support, Dispute resolution, Pre-litigation, Litigation, Tax consulting, International tax advisory, US Inbound, US Outbound, Transfer pricing

Association memberships

ABA Tax Section, American College of Tax Counsel

Academic qualifications

New York University School of Law, LLM in Taxation (1986); University of Oklahoma College of Law, JD, with highest honors (1984)

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Joel V. Williamson

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Partner

Mayer Brown LLP

Chicago

+1 312 701 7229

jwilliamson@mayerbrown.com

www.mayerbrown.com

Languages: English

Bar admissions: Illinois Kentucky

Biography

Joel Williamson is one of the most experienced corporate tax litigators in the US. He has tried over sixty tax cases. Joel has been a lead trial lawyer in an unprecedented seven major transfer pricing cases: Eli Lilly, G.D. Searle, Westreco (Nestlé), Seagate Technology, National Semiconductor, UPS and Eaton Corporation.

Recent matter highlights

  • Represented Eaton Corporation along with co-counsel in a section 482 case involving the IRS' cancellation of two Advance Pricing Agreement (APA).

  • Represented Boston Scientific Corporation in defending against $3.5 billion of transfer pricing adjustments related to the companies' offshore manufacturing of medical devices.

  • Represented Tyco in the US Tax Court with respect to the deductibility of $3 billion in interest paid by Tyco entities in the US to a related finance company in Switzerland in connection with intercompany debt before the court and $6.5 billion in subsequent years.

Practice areas

APAs, Corporate taxes, Audit defence, Pre-litigation, Litigation, Transfer pricing

Sector specialisations

Banking, Financial services, Food and beverage, Healthcare, Pharma and life sciences

Association memberships

Kentucky Bar Association

Admitted in Illinois

US Supreme Court and various Circuit and District Courts

The US Court of Federal Claims and US Tax Court

Board of Trustees, Davidson College

Board of Directors, The Joffrey Ballet Company

American Club of Paris

Chicago Club

Academic qualifications

Davidson College, BA

University of Kentucky College of Law: JD, University of Kentucky Law Review; Moot Court Board; National Moot Court Team; Order of the Coif

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David Abbott

Mayer Brown

Robert Albaral

Baker McKenzie

Michael Alter

Fried Frank

Brad Anwyll

Steptoe & Johnson

Jenny Austin

Morgan Lewis & Bockius

Summer Austin

Baker McKenzie

Howard Berman

Deloitte

Peter Blessing

KPMG

William Bonano

Pillsbury Winthrop Shaw Pittman

Thomas Borders

McDermott Will & Emery

Kim Marie Boylan

White & Case

Kevin Brown

PwC

Steven Brown

Martin Brown Sullivan Roadman & Hartnett

Michael Bryan

Deloitte

Thomas Callahan

Thompson Hine

Christopher Campbell

Deloitte

Nathaniel Carden

Skadden Arps Slate Meagher & Flom

Cabell Chinnis

Mayer Brown

Kerwin Chung

Deloitte

Kenneth Clark

Fenwick & West

George Clarke

Baker McKenzie

Jerold Cohen

Eversheds Sutherland

Erin Collins

KPMG

Ward Connolly

PwC

Jon Contreras

Deloitte

Daniel Cook

Deloitte

Andrew Crousore

Baker McKenzie

Anthony Curtis

PwC

Michael Danilack

PwC

Michael Desmond

Law Offices of Michael J Desmond

Valerie Dickerson

Deloitte

Paul DiSangro

Mayer Brown

Steven Dixon

Miller & Chevalier

Mike Dolan

KPMG

Rod Donnelly

Morgan Lewis & Bockius

Thomas Driscoll

Deloitte

Daniel Dumezich

Deloitte

Carol Dunahoo

Baker McKenzie

Michael Durney

Law Offices of Michael C Durney

Elizabeth Erickson

McDermott Will & Emery

Jeffry Erney

Dentons

David Ernick

PwC

Michelle Ferreira

Greenberg Traurig

Miriam Fisher

Latham & Watkins

Sean Foley

KPMG

David Forst

Fenwick & West

Scott Frewing

Baker McKenzie

James Fuller

Fenwick & West

Jennifer Fuller

Fenwick & West

Stephen Gardner

Cooley

George Matthew Gerachis

Vinson & Elkins

Stephen Gertzman

Miller & Chevalier

Erin Gladney

Baker McKenzie

Fred Goldberg Jr

Skadden Arps Slate Meagher & Flom

Ed Grady Jr

Deloitte

Charles Hall

Norton Rose Fulbright

Adam Halpern

Fenwick & West

George Hani

Miller & Chevalier

Rob Hanson

EY

John Hildy

Mayer Brown

Lawrence Hill

Winston & Strawn

Charles Hodges

Jones Day

Alan Horowitz

Miller & Chevalier

Cynthia Hustad

Deloitte

Kevin Johnson

Baker & Hostetler

Thomas Johnston

Shearman & Sterling

Maria O'Toole Jones

Miller & Chevalier

Richard Jones

Sullivan & Worcester

Roger Jones

McDermott Will & Emery

Joseph Judkins

Baker McKenzie

Philip Karter

Chamberlain Hrdlicka White Williams & Aughtry

Sharon Katz Pearlman

KPMG

John Keenan

Deloitte

Kevin Kenworthy

Miller & Chevalier

Andrew Kim

Fenwick & West

Brian Kittle

Mayer Brown

Thomas Kittle-Kamp

Mayer Brown

Kenneth Klein

Mayer Brown

Donald Korb

Sullivan & Cromwell

Stephen Kranz

McDermott Will & Emery

Larry Langdon

Mayer Brown

Frank Lavadera

KPMG

Gregg Lemein

Baker McKenzie

Marc Levey

Baker McKenzie

Patricia Gimbel Lewis

Caplin & Drysdale

Jerome Libin

Eversheds Sutherland

Thomas Linguanti

Morgan Lewis & Bockius

Darrin Litsky

Deloitte

Dante Lucas

KPMG

Raj Madan

Skadden Arps Slate Meagher & Flom

John Magee

Morgan Lewis & Bockius

James Mastracchio

Dentons

Jane Wells May

McDermott Will & Emery

William McGarrity

Mayer Brown

Wade McKnight

Deloitte

Victor Miesel

Mazars

Kristin Mikolaitis

Mayer Brown

Robert Morris

Norton Rose Fulbright

Christopher Murphy

Skadden Arps Slate Meagher & Flom

Joseph Myszka

Baker McKenzie

David Nagle

Sullivan & Worcester

Mark Nehoray

Deloitte

Larissa Neumann

Fenwick & West

Deborah Nolan

EY

David Noren

McDermott Will & Emery

Kathryn O'Brien

PwC

Shawn O'Brien

Mayer Brown

Mark Oates

Baker McKenzie

Joshua Odintz

Baker McKenzie

Pam Olson

PwC

Edward Osterberg Jr

Mayer Brown

Emily Parker

Thompson & Knight

Jean Pawlow

Latham & Watkins

Kimberley Peterson

Deloitte

Martin Press

Gunster

Jose Manuel Ramirez

KPMG

Keith Reams

Deloitte

Patricia Anne Rexford

Baker McKenzie

Mark Roche

Baker McKenzie

Colleen Feeney Romero

Baker McKenzie

Daniel Rosen

Baker McKenzie

David Rosenbloom

Caplin & Drysdale

Susan Ryba

Baker McKenzie

Leslie Samuels

Cleary Gottlieb Steen & Hamilton

Paul Schick

Baker McKenzie

William Schmalzl

Mayer Brown

Leslie Schneider

Ivins Phillips & Barker

Ronald Schrotenboer

Fenwick & West

Rosemary Sereti

Deloitte

William Sharp

Sharp Partners

George Soba

Deloitte

Sanford Stark

Morgan Lewis & Bockius

Scott Stewart

Mayer Brown

Douglas Stransky

Sullivan & Worcester

Patricia Sweeney

Miller & Chevalier

David Swenson

PwC

Phillip Taylor

Baker McKenzie

Jasper Taylor III

Norton Rose Fulbright

Mary Thomas

Weaver

Joseph Tobin

Deloitte

Brian Toman

Deloitte

Jack Trachtenberg

Deloitte

Brian Trauman

KPMG

Josh Ungerman

Meadows Collier Reed Cousins Crouch & Ungerman

Juan Vasquez Jr

Chamberlain Hrdlicka White Williams & Aughtry

Mario Verdolini

Davis Polk & Wardwell

Robert Walton

Baker McKenzie

James Warren

Miller & Chevalier

Duane Webber

Baker McKenzie

Jay Weill

Sideman & Bancroft

Todd Welty

McDermott Will & Emery

Gary Wilcox

Mayer Brown

John Williams Jr

Skadden Arps Slate Meagher & Flom

Joel Williamson

Mayer Brown

Robert Willmore

Crowell & Moring

Diana Wollman

Cleary Gottlieb Steen & Hamilton

Steven Wrappe

KPMG

Russell Young

Baker McKenzie

Shanwu Yuan

Baker McKenzie

Alexander Zakupowsky Jr

Miller & Chevalier

Thomas Zehnle

Law Office of Thomas E Zehnle

Thomas Zollo

KPMG

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