Tax Conference Speakers & Panelists

The Boundaries of Redemptions: Determining the Model for Imposing the Section 4501 Excise Tax

Marc Countryman

Marc Countryman is a partner in Ernst & Young LLP’s National Tax Department. Based in San Francisco, CA, Marc is a co-leader of the National Tax Mergers & Acquisitions Group. His practice focuses on federal corporate income tax, and consolidated return matters.

Marc served in the U.S. Department of the Treasury, Office of Tax Policy from 2006 to 2008, where he was Associate Tax Legislative Counsel. In that capacity, his principal responsibilities included, among others, developments in the taxation of corporations. Specifically, Marc was the principal reviewer on all corporate tax guidance projects, including: the final consolidated return Unified Loss Rule; final regulations regarding the transfer of assets or stock following a reorganization; proposed regulations regarding the active trade or business requirement under section 355; and proposed regulations that would allow for an election under section 336(e). He was also a frequent speaker, representing the Treasury Department at various tax conferences sponsored by the ABA, DC Bar Association, NYSBA, and PLI.

Prior to joining the Treasury Department, Marc served as a Senior Technician Reviewer at the Internal Revenue Service, Office of the Associate Chief Counsel (Corporate). Prior to joining the government he was a Senior Tax Manager at Deloitte Tax LLP in Chicago.

Marc is a graduate of the University of Minnesota (B.S. Accounting), and Loyola University Chicago School of Law (J.D.).

Karen Gilbreath Sowell

Karen Gilbreath Sowell is a principal in Ernst & Young LLP’s National Tax Department. Based in Washington, D.C., Karen is EY’s Global Transaction Advisory Leader and co-leader of the National Tax Mergers & Acquisitions Group.

Karen was the US Treasury’s Deputy Assistant Secretary for Tax Policy from July 2007 to January 2009. She worked closely with the leadership of the Treasury Department during the financial crisis. She participated in the legislative process for the Economic Stimulus Act of 2008 and the Emergency Economic Stabilization Act (EESA) of 2008, and played a leadership role in the expedited issuance of important guidance projects directed at economic stabilization. She was co-leader of the Treasury Department’s promulgation of standards for the executive compensation requirements of EESA. She received the Treasury Distinguished Service Award in recognition of her contributions.

Karen first served at the Treasury Department from 1997 to 2001, where she was Associate Tax Legislative Counsel. She was primarily responsible for matters relating to corporate taxation in a period of prolific guidance, including regulations and other guidance governing spin-off transactions, taxable transactions, and the check-the box regime.

Karen was Chair of the Executive Committee of the Tax Section of the New York State Bar Association in 2018. She is a former chair of the Corporations Committee of the Tax Section of the American Bar Association.

Jodi J. Schwartz

Jodi J. Schwartz focuses on the tax aspects of corporate transactions, including mergers and acquisitions, joint ventures, spin-offs and financial instruments. Ms. Schwartz has been the principal tax lawyer on numerous domestic and cross-border transactions in a wide range of industries. She was elected partner in 1990.

Ms. Schwartz received her B.S. in Economics magna cum laude from the University of Pennsylvania in 1981, her M.B.A. from the University of Pennsylvania (Wharton School) in 1984, her J.D. magna cum laude from the University of Pennsylvania Law School in 1984 and her LL.M. in taxation from the New York University Law School in 1987.

Ms. Schwartz is recognized as one of the world’s leading lawyers in the field of taxation, including being selected by Chambers Global Guide to the World’s Leading Lawyers, Chambers USA Guide to America’s Leading Lawyers for Business, International Who’s Who of Business Lawyers and as a tax expert by Euromoney Institutional Investor Expert Guides. In addition, she is a member of the Executive Committee and past chair of the Tax Section of the New York State Bar Association and also is a member of the American College of Tax Counsel.

Ms. Schwartz serves as an officer of both the UJA-Federation of NY and the Jewish Federations of North America, serves as a member of the board of Steep Rock Association and serves on the Board of Overseers of the University of Pennsylvania Law School. Ms. Schwartz lives in Manhattan with her husband, son and daughter.

Colin Douglas Campbell, Jr.

Colin Campbell serves as chief attorney-advisor to the Assistant Secretary for Tax Policy on Federal income tax matters regarding corporations and their shareholders, including under the consolidated return regulations. Since joining the Office of Tax Policy in 2018, Mr. Campbell has assisted in the development and drafting of regulations and other published guidance to implement the Tax Cuts and Jobs Act, the CARES Act, and the American Rescue Plan.

Mr. Campbell previously was a senior manager in KPMG’s Washington National Tax M&A Tax Group. He advised KPMG clients on all aspects of corporate taxation, with a particular emphasis on spin-offs, mergers and acquisitions, restructuring transactions, debt and equity offerings, and consolidated return issues. In addition, he served as an instructor for KPMG’s Tax Business School on topics relating to subchapter C.

From 2005 to 2011, Mr. Campbell served as an Assistant Counsel in the Office of the Legislative Counsel of the United States Senate. As an Assistant Counsel, Mr. Campbell drafted bills, amendments, and resolutions for introduction by Senate members and committees. Notably, he served as a lead drafting attorney for the regulation of over-the-counter swaps markets under the Dodd-Frank Wall Street Reform and Consumer Protection Act.

Mr. Campbell earned an LL.M. in Taxation from the Georgetown University Law Center, a J.D. from the Suffolk University Law School, and a B.A. in Political Science from Bates College.

Subpar F? The Role of Anti-Deferral in a Post-GILTI (and Maybe Pillar Two) World

Julie Roin

Julie Roin is currently the Seymour Logan Professor of Law at the University of Chicago Law School. Since her arrival at the Law School, she has taught classes in federal income taxation, tax policy, local government law, and state and local finance. She came to Chicago from the University of Virginia School of Law and has taught at a number of other law schools. Prior to entering academia, she practiced at Caplin & Drysdale in Washington D.C., and clerked on the D.C. Circuit Court of Appeals for the Hon. Patricia Wald. Books (Author): International Business and Economics: Law and Policy (4th ed.) (LexisNexis, 2010) (with Paul B. Stephan); International Business and Economics: Law and Policy (3rd ed.) (LexisNexis, 2004) (with Don Wallace & Paul B. Stephan); Documents for International Business and Economics: Law and Policy (1996 ed.) (Michie, 1996); International Business and Economics: Law and Policy (2nd ed.) (Michie, 1996) (with Paul B. Stephan & Don Wallace); International Business and Economics: Law and Policy, 1994 Supplement (Michie, 1994) (with Don Wallace & Paul B. Stephan); International Business and Economics: Law and Policy (Michie, 1993) (with Paul B. Stephan & Don Wallace ); Documents for International Business and Economics: Law and Policy (1993 ed.) (Michie, 1993).

Julia Skubis Weber

Julia Skubis Weber is a partner in Baker McKenzie’s Global Tax Practice Group in Chicago. She has been advising US, non-US and multinational corporate and pass-through clients on federal income tax planning matters since 2005, with emphasis on international tax planning. She routinely advises US multinational and foreign-owned clients on cross-border tax issues, including internal reorganizations, structuring of outbound and inbound investments, foreign tax credits, subpart F, GILTI, withholding and treaty analysis. In addition, she has extensive experience related to mergers and acquisitions, spin-off transactions and joint ventures. Julia received her J.D., magna cum laude, from the University of Michigan Law School and her B.A. from the University of California, Los Angeles. She has been recognized by Chambers USA and Legal 500 and is a frequent speaker on international tax topics. She has contributed to Tax Analysts, Corporate Taxation and Tax Executive Magazine and co-authors International Tax Watch, a bi-monthly column in TAXES The Tax Magazine. Julia also teaches the Controlled Foreign Corporations class as an adjunct professor in Northwestern Pritzker School of Law’s LLM in Taxation Program.

Reuven S. Avi-Yonah

Professor Reuven S. Avi-Yonah specializes in corporate and international taxation. He has served as a consultant to the U.S. Department of the Treasury and the Organisation for Economic Co-operation and Development (OECD) on tax competition, and is a member of the steering group for OECD's International Network for Tax Research.

Avi-Yonah is a member of the American Law Institute, a fellow of the American Bar Foundation and the American College of Tax Counsel, and an international research fellow at Oxford University's Centre for Business Taxation. In addition to prior teaching appointments at Harvard University (law) and Boston College (history), he has practiced law with Milbank, Tweed, Hadley & McCloy in New York; with Wachtell, Lipton, Rosen & Katz in New York; and with Ropes & Gray in Boston.

He has published more than 250 books and articles, including Advanced Introduction to International Tax Law (Elgar, 2019), Global Perspectives on Income Taxation Law (Oxford University Press, 2011), and International Tax as International Law (Cambridge University Press, 2007).

John Stowell

John leads the global tax, incentives and international financial reporting functions at The Walt Disney Company. He holds an LL M. Tax (with Distinction) from Georgetown University Law Center, an LL.B from the University of Canterbury Law School, and a B.Com (Accountancy and Business Administration) from the University of Canterbury.

He began his career with Deloitte in Auckland, New Zealand before transferring to Los Angeles and then International Tax and Global Tax Strategies group in Deloitte’s Washington DC National Tax Office. His corporate experience includes positions as Regional Counsel for Asia Pacific and Latin America, European Tax Counsel (based in Switzerland), Director of Tax Planning and then Vice President of Taxes at Avery Dennison Corporation, based in Pasadena, CA. Prior to joining The Walt Disney Company as head of tax in 2013, John served as Vice President and Chief Tax Officer at Delphi Automotive LLP, which subsequently became Delphi Automotive PLC following its initial public offering.

John is a CPA in California and Chartered Accountant in Australia and New Zealand and was admitted to the bar in New Zealand. He serves various boards including Chair of The Tax Council, and executive committee roles with CalChamber, CalTax, and TCPI.

Partnership Capital Shifts: Welcome to the Jungle

James Sowell

James Sowell is a principal in the Passthroughs group of the Washington National Tax practice of KPMG LLP. He focuses primarily on tax issues relating to partnerships and REITs, and he leads the Real Estate practice for Washington National Tax.

Prior to joining KPMG, Jim was with the national tax offices of other major accounting firms. Prior to that time, Jim was with the U.S. Department of Treasury (Office of Tax Policy) where he served first as an Attorney Advisor and then as an Associate Tax Legislative Counsel. While at the Treasury Department, Jim was primarily responsible for administrative guidance and legislation involving partnerships, real estate investment trusts, like-kind exchanges, and other issues. The many matters that Jim was involved in while at Treasury included the regulations relating to partnership mergers and divisions, the partnership basis adjustment regulations, the regulations relating to amortization of intangible property, and the legislation relating to taxable REIT subsidiaries. Prior to the Treasury Department, Jim was an associate at King & Spalding LLP in Atlanta, Georgia.

Jim earned an LL.M. in taxation from New York University in 1991, a law degree (with high honors) from the University of Florida in 1990, and his bachelors in business administration (also with high honors) from the University of Florida in 1986. Mr. Sowell was Chief Tax Editor of the Florida Law Review and was a Graduate Editor of New York University’s Tax Law Review.

Jim is a former Chairman of the Real Estate Committee of the American Bar Association (Tax Section) and a former Vice Chairman of the Tax Policy Advisory Committee of the Real Estate Roundtable. He is a member of the National Association of Real Estate Investment Trusts, where he is an active participant on the Government Relations Committee. Jim also is on the Board of Trustees for the Southern Federal Tax Institute.

Jim has written articles for various publications and speaks at numerous conferences.

Eric B. Sloan

Eric Sloan is a partner in the New York and Washington DC offices of Gibson, Dunn & Crutcher and a Co-Chair of the Firm’s tax practice. With more than 30 years of broad transactional and structuring experience, Mr. Sloan is a nationally recognized expert in private equity and on the use of partnerships and limited liability companies in domestic and cross-border mergers and acquisitions, financing transactions, and restructurings. He advised on the first passthrough portfolio company investments made by four of the largest U.S.-based private equity firms. Mr. Sloan has substantial experience in the formation of domestic and cross-border joint ventures and acquisitions and dispositions of businesses and interests in joint ventures, including the largest joint venture in the United States and a complex multi-billion dollar cross-border commodities joint venture. In addition, Mr. Sloan is deeply experienced in obtaining private letter rulings and closing agreements from the Internal Revenue Service on novel and difficult issues on an expedited basis.

Phillip Gall

Phillip Gall is a Principal in the Partnership Transaction Group in Ernst & Young LLP’s National Tax Department and is located in New York. He focuses on the taxation of partnerships, joint ventures, and limited liability companies. Phillip has significant experience in the formation, operation, and unwinding of these types of entities for large multinationals and for investment funds in both the international and domestic context. Phillip is an Adjunct Professor at New York University School of Law, where he has taught partnership tax courses for nearly 20 years, and is a former member of the Executive Committee of the New York State Bar Association Tax Section. Phillip has published the following articles: Phantom Tax Regulations: The Curse of Spurned Delegations (Tax Lawyer, Winter 2003), Partnership Distributions of Marketable Securities (Tax Notes, Nov. 12, 2007), The Mysterious Case of Disappearing Debt in Partnership Transactions (Taxes, March 2012), and Nothing from Something: Partnership Continuations under Section 708(a) (Taxes, March 2017).

Andrea Ramezan-Jackson

Andrea Ramezan-Jackson is a partner in the Washington, D.C. office of Latham & Watkins and a member of the Transactional Tax Practice. She primarily handles complex U.S. domestic and cross-border corporate and partnership taxation.

Andrea’s experience includes representing US and non-US corporations, partnerships, and limited liability companies as well as private equity and venture capital funds with respect to tax matters pertaining to domestic and international mergers and acquisitions, joint ventures, and reorganizations as well as financings, initial public offerings (including extensive expertise in Up-C and SPAC transactions), divestitures, and other restructuring transactions. She was highlighted by The Legal 500 US as a Next Generation Lawyer for her international tax work.

The U.S.’s Anti-Inversion Regime: Time to Revisit its Purpose and Utility

Scott M. Levine

Scott Levine advises on the tax aspects of corporate transactions, including international and domestic mergers and acquisitions, leveraged buyouts, spin-offs and other divestitures, restructurings, financings, and joint ventures. He also has negotiated private letter rulings with the Internal Revenue Service in the corporate, international, financial instruments, and energy credit tax areas.

Before joining Jones Day in 2006, Scott was a senior manager in KPMG's national tax office.

Scott is currently an adjunct professor of law at the Georgetown University Law Center in Washington, D.C. and the International Tax Center at Leiden University in the Netherlands, where he teaches courses on U.S. corporate and international taxation. He frequently lectures as a speaker at programs for the ABA, DC Bar, TEI, SFTI, and PLI, among others, addressing a wide range of topics in the corporate and international taxation areas.

Scott is an active member of the ABA’s Tax Section, a former Chair of the ABA Tax Section’s Corporate Committee, a current Section Counsel member, and the primary author of several ABA comment letters including the ABA’s letters on the proposed GILTI regulations, the temporary section 245A regulations, the final GILTI regulations, the proposed opportunity zone regulations as they related to corporate and consolidated issues, and the advance child tax credit. Scott was a two-term member of the D.C. Bar Tax Section's Steering Committee, a former Chair of the Tax Section's Corporate Tax Committee, and the recipient of the DC Bar’s inaugural Tax Trailblazer Award in 2022. He has been the Chair of the DC Bar’s Annual Tax Reform Conference since its inception in 2017. Scott is also a co-chair of the Law Firm Anti-racism Alliance’s Tax Working Group.

Christopher Trump

Christopher is the Co-Leader of Deloitte’s Washington National Tax - International Tax and Transfer Pricing Services group. He regularly advises clients on issues involving foreign currency, loss surrender and utilization, and the design and implementation of principal company structures. He serves multinational companies in a variety of industries specializing in mergers and acquisitions, foreign tax credit planning, financing transactions, repatriation, and the utilization of partnerships in cross-border transactions.

Prior to joining Deloitte, Mr. Trump was the Assistant to the Branch Chief, Branch 4, in the Office of the Associate Chief Counsel (International) for the Internal Revenue Service. Mr. Trump also worked in the Office of the Associate Chief Counsel (Passthroughs & Special Industries). He is a frequent speaker and is the author of numerous articles on tax planning for U.S. based multinational corporations.

Caroline H. Ngo

Caroline H. Ngo is co-leader of McDemott’s International Tax Affinity Group and is based in Washington, DC. She advises publicly traded companies on international tax planning, cross-border mergers and acquisitions, application of bilateral income tax treaties, and other international tax matters. Since the passage of the Tax Cuts and Jobs Act of 2017 (TCJA), a substantial portion of Caroline’s practice has been advising clients on the new international tax provisions, including the new foreign tax credit regime (including expense apportionment), the GILTI regime, the participation exemption under section 245A, the BEAT, and the transition tax under section 965. Caroline recently served as lead counsel in a significant litigation in the US Tax Court, and her team secured a complete victory for the client.

John J. Merrick

John Merrick is a Senior Level Counsel to the Associate Chief Counsel (International) in the Office of Chief Counsel. Prior to joining Chief Counsel, Mr. Merrick practiced international tax in the national offices of two accounting firms in Washington. He also practiced international and corporate tax in Chicago with an accounting firm and a law firm. Mr. Merrick holds a Bachelors in Business Administration in accounting from Loyola University Chicago, summa cum laude, where he also earned his J.D., cum laude, and was a member of the Loyola Law Journal. He obtained an LL.M. in Taxation from the De Paul College of Law. He also passed the Certified Public Accountant exam.

M&A and Partnerships

Mike Carew

Mike Carew is a tax partner in the Chicago office of Kirkland & Ellis LLP. He focuses his practice on the tax aspects of mergers, acquisitions, buyouts and private equity investing, with a special emphasis on cross-border and international transactions. He also advises clients on the tax aspects of securities issuances, recapitalizations, joint ventures, and debt and equity restructurings.

Mike has worked on numerous private equity and M&A transactions for clients including: Ares Management LLC, Bain Capital, CVC Capital Partners, Softbank Investment Advisors, Summit Partners, TDR Capital, GTCR, and Apax Partners.

Mike was listed as a leading lawyer for tax in the 2020–2022 editions of Chambers USA, and in the 2016–2022 editions of The Legal 500 U.S. Mike was also recognized in 2015 as a “Rising Star” by Law360 for Tax Law.

Mike serves as an adjunct professor at Northwestern Pritzker School of Law, where he teaches “Tax Aspects of Private Equity Transactions.” Mike is also a lecturer at the University of Chicago Law School, where he teaches “Structuring Venture Capital, Private Equity, and Entrepreneurial Transactions.”

Tim Devetski

Tim Devetski is a principal in the International Tax & Transaction Services group of EY LLP, where he counsels clients on the tax aspects of mergers, acquisitions, joint ventures and financings. He has significant experience advising private equity funds on the tax aspects of portfolio company acquisitions, dispositions, joint ventures, financings and initial public offerings. Prior to joining EY LLP in 2017, Tim was a partner with a multinational law firm, where he had also served as one of the managing partners of that firm’s Houston office. Tim received his LL.M. (in Taxation) from New York University School of Law, his J.D. from Northwestern University (now Pritzker) School of Law and his B.A. from the University of Houston. He has previously served as an adjunct professor at the University of Houston Law Center, teaching separate courses on Advance Corporate Taxation and the Taxation of Sales and Exchanges. He is a member of the Tax Sections of the American Bar Association and the New York State Bar Association and is admitted to practice law in Texas.

Pamela Lawrence Endreny

Pamela Lawrence Endreny is a partner in the New York office of Gibson, Dunn & Crutcher. Ms. Endreny represents clients in a broad range of tax matters. Her experience includes mergers and acquisitions, spin-offs, joint ventures, financings and restructurings for both public company and private equity clients. She has obtained private letter rulings from the Internal Revenue Service on tax-free spin-offs and other transactions. She has been repeatedly selected for inclusion in Chambers USA: America’s Leading Lawyers for Business.

Ms. Endreny is a member of the Executive Committee of the New York State Bar Association Tax Section. She is also a member of the Tax Forum and Private Investment Fund Tax Forum.

Ms. Endreny earned her Juris Doctor in 1994 from Columbia University School of Law. She received her undergraduate degree, magna cum laude, from Brown University in 1986.

Craig Gerson

Craig Gerson is a Principal in the Mergers and Acquisitions group of PwC’s Washington National Tax Services practice. At PwC, Craig advises clients on the use of partnerships in a wide array of domestic and cross-border transactions. Craig previously served in the Office of Tax Legislative Counsel at the U.S. Department of the Treasury as an Attorney-Advisor specializing in partnership taxation issues. While at the Treasury Department, Craig had primary responsibility for the development and publication of guidance on partnership tax topics, including regulations relating to: distributions under section 751(b); basis adjustments under the Jobs Act of 2004; varying interests under section 706; qualifying income under section 7704(d)(1)(E) for publicly traded partnerships; disguised payments for services under section 707(a); partnership transactions involving partner stock under section 337(d); and allocations of partnership liabilities under section 752. Craig also has prior experience as an Attorney-Advisor in the Passthroughs Division of Chief Counsel.

Craig has authored articles that have appeared in numerous publications, including Practising Law Institute (PLI) (Tax Planning for Domestic and Foreign Partnerships, LLCs, Joint Ventures and Other Strategic Alliances), Tax Notes, and Journal of Taxation. Craig is a regular speaker on partnership tax issues at a wide variety of tax conferences including the American Bar Association Tax Section, PLI, and Tax Executives Institute. Craig has also instructed the Taxation of Partnerships class for the LL.M. program in taxation at the Georgetown University Law Center.

Craig received his B.A. in English from Northwestern University, his J.D. from University of California - Davis, and his LL.M. from the Georgetown University Law Center. Craig is admitted to practice law in Washington D.C. and California.

Section 367(b): Where Do We Go From Here?

Gary Scanlon

Gary is a Principal in the International Tax Group within KPMG’s Washington National Tax office. Gary joined KPMG in 2019, following his tenure as an attorney-advisor in the Office of the International Tax Counsel at the U.S. Department of the Treasury.

Gary advises clients on U.S. international tax matters, including tax planning with respect to their structures, operations, and transactions. In particular, he has extensive experience advising on issues relating to disposition and acquisition planning. More recently, he has focused on helping clients navigate U.S. tax reform, in particular the regimes for Global Intangible Low-Taxed Income (GILTI) and Foreign-Derived Intangible Income (FDII). In addition to his client work at KPMG, Gary hosts Inside International Tax, a KPMG TaxRadio podcast series focusing on US international tax trends and developments.

Prior to joining KPMG, Gary served as an attorney-advisor in the Treasury Department’s Office of Tax Policy from 2016 to 2019. At Treasury, Gary developed and drafted regulations under section 385, regulations implementing the exception for qualified foreign pension funds under the Foreign Investment Real Property Act (FIRPTA), and the notice addressing “Killer B” transactions. After enactment of the Tax Cuts and Jobs Act (TCJA), Gary also developed and drafted several regulations implementing U.S. tax reform, including regulations implementing the Transition Tax, GILTI, and FDII. He also represented the United States at the OECD Forum on Harmful Tax Practices (FHTP), including defending the FDII regime at the FHTP.

Eric Sensenbrenner

Eric Sensenbrenner is a partner in the Washington, D.C. office of Skadden, Arps and is head of the Firm's Global Tax practice. Mr. Sensenbrenner represents clients on a broad range of domestic and international tax matters, including mergers, acquisitions and spin-off transactions. He has significant experience in structuring cross-border merger and acquisition transactions, and post-acquisition integration transactions, as tax-planning in connection with the formation of domestic and foreign joint ventures.

Layla J. Asali

Layla J. Asali practices in a broad range of federal income tax matters, with an emphasis on the taxation of cross-border transactions and business activities. She advises U.S.-based and foreign-based multinational clients on international tax issues, including mergers and acquisitions, intellectual property transactions, supply chain planning, and financings.

In addition to her consulting practice, Layla has experience representing clients before the Internal Revenue Service (IRS) National Office in obtaining favorable private letter rulings and resolving federal income tax controversies at the audit level and at IRS Appeals. She has also represented clients before the U.S. Department of the Treasury on regulatory and policy matters.

Layla is a frequently sought speaker on international tax matters and is an authority on the international tax provisions of the Tax Cuts and Jobs Act (TCJA), including the global intangible low-taxed income (GILTI) regime, foreign tax credits, the base erosion and anti-abuse tax (BEAT), and the deduction for foreign-derived intangible income (FDII). She has published articles in journals, including BNA Tax Management International Journal, BNA Tax Management Memorandum, the CCH International Tax Journal, and Tax Notes International. Layla is the former Chair of the DC Bar Taxation Community and she currently serves as Vice Chair of the American Bar Association's Foreign Activities of U.S. Taxpayers (FAUST) Committee. She has twice been named one of International Tax Review's Women in Tax (2016-2017).

Lindsay Kitzinger

Lindsay Kitzinger is Acting International Tax Counsel in the Office of Tax Policy at the U.S. Department of the Treasury. In that role, she is a legal adviser to the Assistant Secretary (Tax Policy) with regard to all aspects of international tax matters. Lindsay was previously a partner at Covington & Burling LLP, where she advised clients on a variety of international tax issues, in particular issues related to the U.S. foreign tax credit rules and the GILTI and subpart F regimes. From 2016 to 2019, she was an attorney-advisor in the Office of International Tax Counsel at the U.S. Department of Treasury, where she worked on the implementing regulations for the Tax Cuts and Jobs Act of 2017.