McDermott Will & Schulte, a global law firm

Michael Silva focuses his practice on international tax law, with an emphasis on US investment structures, cross-border transactions, tax treaty planning and US activities of foreign banks. He has significant experience forming investment funds and advising family offices. Michael currently serves as head of the Miami Tax practice and co-head of the Latin America practice.

Michael also advises Brazilian and Asian investors on investments in US real estate projects, and assists multinational corporations on establishing a business presence in the United States.

Maintaining an active private client practice, Michael regularly advises families on trusts and private trusts companies and other techniques to transfer wealth and business assets. Michael advises foreign clients on the US income, estate and gift tax consequences of alternative inbound investment structures while utilizing income, estate and gift tax treaties to minimize tax and regulatory burdens. He coordinates the formation of foreign trusts, corporations and advises clients the US reporting requirements imposed on foreign trusts with US beneficiaries. Michael also assists international banks and trustees on dealing with US clients.

Michael represents financial institutions, insurers, broker-dealers, custodians, funds, fund advisers and managers, trust companies and other financial intermediaries in connection with the requisite protocols and procedures to validate compliance with FATCA requirements.

Michael is board-certified by the Florida Bar in Tax Law and in International Law, and is a Certified Public Accountant. Michael previously served as adjunct professor of Law in the University of Miami Law School Graduate Tax Program.

John T. Lutz advises clients on the tax aspects of investment funds, structured finance, derivatives and structured products. He also counsels clients on matters related to insurance products, investment tax credits, conventional US and cross-border securities offerings, and corporate mergers and acquisitions. John represents a number of tax-exempt organizations in connection with their investment activities and incentive compensation arrangements.

John handles all aspects of tax-advantaged financings and investments for financial institutions, investment fund managers, high net worth individuals, and investors. He represents banks and investment managers in connection with asset backed securities including collateralized loan obligations, structured notes, and repackagings.

John is a recognized leader in the tax aspects of municipal derivatives and tax-exempt bond securitizations. He provides tax advice to derivative products dealers in the domestic and cross-border contexts, advising on US and international tax issues related to insurance products, equity swaps, repurchase agreements, structured notes, and offshore structured finance vehicles.

Stephen (Steve) P. Kranz is a tax lawyer who solves tax problems differently. Over the course of his extensive career, Steve has acquired specific skills and developed a unique approach that helps clients develop and implement holistic solutions to all varieties of tax problems. He combines strategic thinking with effective skills for the courtroom, the statehouse and the conference room.

Steve helps clients prevent and resolve tax problems throughout their life cycle, starting with tax planning, compliance, financial statement implication analysis, audit defense and litigation, legislative monitoring and advocacy, and the formation and leadership of taxpayer coalitions. Steve developed many of these techniques as a litigator for the US Department of Justice, Tax Division, as chief counsel for the District of Columbia's Office of Tax and Revenue, and further refined them during his tenure as general counsel for the Council on State Taxation (COST).

Steve practices at the forefront of state and local tax issues, including developments in the world of cloud computing, artificial intelligence such as ChatGPT and digital goods and services. He helps clients understand tax threats and opportunities, and develop holistic solutions, no matter the tax issues or jurisdiction. He also brings this same skill set to the highly challenging world of unclaimed property.

Steve represents Fortune 100 companies in litigation while working to address the larger tax policy questions through state legislatures, the US Congress, the National Conference of State Legislatures, the National Governors Association, the Multistate Tax Commission and the Streamlined Sales Tax Governing Board. His background has taught him that standalone litigation is not always the most efficient manner of solving a tax problem or preventing its spread - thus, he often works to address problems by taking advantage of tax policy points of entry offered by state and local governments.

Steve has authored articles for professional publications, speaks at national conferences and is interviewed frequently by journalists covering state and local tax developments. He has appeared before the US House Judiciary Committee as an expert on alternative approaches to the Internet Sales Tax issues, and in a similar capacity before other government agencies. Steve serves as outside counsel on state tax and unclaimed property matters for the Entertainment Software Association, the National Retail Federation, the Retail Industry Leaders Association and CompTIA.

David G. Noren focuses his practice on international tax planning for multinational companies. David advises clients on a wide range of "outbound" and "inbound" issues, with a particular focus on the subpart F anti-deferral rules, the application of bilateral income tax treaties, and the treatment of cross-border flows of services and intellectual property rights under transfer pricing and other rules.

Prior to joining the Firm, David served as legislation counsel to the Joint Committee on Taxation in the US Congress where he advised the House Ways & Means Committee, the Senate Finance Committee and other members of Congress on proposed international tax legislation. He played a major role in the development of several international tax bills, including those culminating in the American Jobs Creation Act of 2004.

David also advised the Senate Foreign Relations Committee on the review and ratification of several tax treaties and protocols, carried out the international tax aspects of special investigations and studies requested by members of Congress, and assisted in the Joint Committee staff's review of large tax refunds in the international area. Prior to working in Congress, David taught in the tax program at the New York University School of Law.

David has testified in congressional hearings on international tax issues and is a frequent writer and speaker on such topics. While in law school, David was an editor of the Harvard Law Review.

Michael J. Bruno advises multinational companies, funds, single family offices, and entrepreneurs on sophisticated US and international tax planning and transactions. He has extensive experience in advising clients in the technology, healthcare, life sciences, digital health, consumer products, FinTech and cryptocurrency, and sports and entertainment industries.

Michael regularly advises clients on mergers, acquisitions, restructurings, joint ventures, and divestitures in various business contexts. He has assisted clients with many international tax issues, including navigating anti-deferral (controlled foreign corporation (CFC) and passive foreign investment company) regimes, foreign tax credit planning, export planning, treaty planning, intellectual property migrations, tax-efficient cash repatriation strategies, and post-acquisition integration and implementation.

Michael also regularly advises entrepreneurial families on strategies for minimizing US income taxation with respect to their closely held businesses and investments, including qualified small business stock planning. Through comments and a presentation, Michael advocated on behalf of The Florida Bar Tax Section for Congress, the Internal Revenue Service, and the US Department of the Treasury to afford the Section 250 deduction to electing Section 962 shareholders that earn Global Intangible Low-Taxed Income, as well as reinstating the repeal of Section 958(b)(4) for CFC downward attribution.

He has written numerous articles on international tax planning and frequently submits comments on statutory and regulatory promulgations. As a strong proponent for pro bono legal services, Michael founded the Transactional Equal Justice Program with Legal Services of Greater Miami, which offers free legal advice to nonprofits and low-to-moderate income small business owners to help them launch a business.

Brian H. Jenn focuses his practice on US and international tax matters for US and foreign multinationals and other clients. As former Deputy International Tax Counsel (DITC) for the US Department of Treasury, Brian has extensive experience and insight on the Tax Cuts and Jobs Act (TCJA), having been deeply involved in the process of issuing proposed and final regulations and other guidance implementing the TCJA. Brian also has significant insights on taxation of the digital economy, transfer pricing and US taxation of foreign currencies.

Prior to joining McDermott, Brian spent several years at the US Department of Treasury where he was an attorney advisor, and most recently DITC. While at Treasury, he served as co-chair of the Organisation for Economic Co-operation and Development’s (OECD) Task Force on Digital Economy and as US delegate to the Committee on Fiscal Affairs. In this capacity, Brian led Treasury’s engagement at the OECD on digital tax issues, playing a central role in discussing tax challenges associated with the digitalization of the economy, as well as the development of new international norms for allocating tax rights among countries.

Brian also advises clients with international operations on transfer pricing issues, such as supply chain structuring and intellectual property planning. As US delegate to the OECD’s Working Party 6 throughout the G20-OECD Base Erosion and Profit Shifting (BEPS) project, Brian negotiated major changes to international transfer pricing standards, including changes to the OECD Transfer Pricing Guidelines chapters on intangibles, cost contributions arrangements, risk and recharacterization, and low-value added services.

In addition, Brian was one of the primary drafters of a recently issued detailed set of regulations governing US taxation of transactions involving foreign currencies.

Before joining the Treasury, Brian spent several years in private practice, where he advised clients in various sectors, including technology, pharmaceutical, financial services and consumer products. He handled aspects of international tax planning including foreign tax credits, foreign currency issues, Subpart F, intangible property transfers, transfer pricing and treaty interpretation.

Prior to law school, Brian served as a staff economist to the White House Council of Economic Advisors where he assisted the chairman and members of the council in advising the president on tax policy and other public finance issues. In addition, he served as senior economist to the Joint Economic Committee of Congress where he advised the chair regarding tax policy, including issues related to the economic implications of potential international tax reforms.

Antoine Vergnat focuses his practice on advice to French and non-French investment funds, corporate groups and entrepreneurs operating in the industrial, service and real estate sectors on a broad range of domestic and international tax matters. Antoine focuses his practice on transactional tax law, with an emphasis on matters relating to the acquisition and sale of assets, the financing and restructuring of groups, as well as the management of tax affairs and controversies before tax authorities.

Antoine also regularly provides tax advice to high-net-worth individuals on a broad range of domestic and international tax matters and has significant experience in the structuring of equity compensation schemes for management teams.

Caroline Ngo co-leads the firm’s International Tax Affinity Group. She represents publicly traded, and other large multinational corporate clients in US and international tax matters.

Caroline focuses her practice on planning, consulting, and advocacy work for US- and foreign-parented multinational companies across several industries. She also advices on matters related to acquisitions, dispositions, internal reorganizations, post-acquisition integration, inbounding transactions, intangible property holding companies, finance company structures, cash repatriation, and US income tax treaty qualification

Caroline is nationally recognized for her deep knowledge of her field and is a frequent speaker on international tax matters.

Jonathan D. Lockhart focuses his practice primarily on international tax planning and controversies. Jonathan helps clients structure international acquisitions and reorganizations in a tax-efficient manner, as well as with foreign earnings repatriation, foreign tax credit planning and intellectual property migration.

While in law school, Jonathan served as an assistant editor for the William Mitchell Law Review and was a National Tax Moot Court participant. He also served as an extern for the Internal Revenue Service (IRS) Office of the Chief Counsel in Saint Paul, Minnesota.

Steven Hadjilogiou focuses his practice on tax optimization of business operations and investments with a specific emphasis in the areas of international tax and real estate. Steven provides advice on international inbound and outbound tax planning for multinational companies, family offices, private equity and ultra-high net worth individuals. He also advises funds, family offices and ultra-high net worth individuals in connection with complex real estate structuring and investment issues, including in the areas of opportunity zone funds, 1031 transactions and qualified small business stock.

Steven has represented various Fortune 500 companies and major privately held businesses in their tax planning and supply chain projects, and also has substantial experience advising on transfer pricing, tax-related intellectual property matters, Subpart F, GILTI, foreign investment in US real property and outbound investment in real property. Steven also advises clients on pre-immigration planning and cross-border wealth succession. Steven has also worked on the taxation of partnerships and corporations, mergers & acquisitions and international corporate reorganizations.

Since 2013, Steven has been an adjunct professor of International Inbound Taxation at the University of Miami Graduate Tax Program. He is the co-chair of the annual Florida Bar/FICPA International Tax Conference. Steven has written numerous articles and presented on topics related to tax. He was a primary drafter of the amicus curiae brief submitted to the US Supreme Court on behalf of the Florida Bar Tax Section in Knight v. Commissioner in 2008.

Advises US and non-US multinationals on corporate and international tax matters

Counsels on domestic and cross-border acquisitions, dispositions, restructurings, and liquidations

Guides publicly traded and privately held companies on spin-offs Represents clients in obtaining private letter rulings and other IRS guidance