International Tax Forum

Kristen E. Hazel has extensive experience representing clients in US and international aspects of federal tax matters, including international acquisitions and divestitures, international joint ventures, and capital plan design and implementation, including tax planning with respect to intellectual property. Her work includes both inbound and outbound transactions.

Kristen is the co-head of the Firm’s Captive Insurance Affinity Group. She regularly counsels clients with respect to the tax aspects of organizing, operating and defending captive insurance companies. She is head of the Firm’s New Business Committee and is a member of the Firm’s Professional Responsibility Committee.

Kristen frequently speaks on captive insurance, domestic and international tax topics for various professional organizations.

Kristen is a co-founder of Tax in the City: A Tax Roundtable®, which consists of tax professionals with an interest in discussing substantive tax issues in a collegial and confidential setting.

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.

Sandra McGill focuses her practice on international tax planning. Sandra works with US and non-US multinational companies, public and private as well as high net worth individuals and family businesses. Sandra has extensive experience advising clients on a broad range of cross-border tax issues, including the following:

• Foreign tax credit planning
• Subpart F and PFIC anti-deferral rules
• Source of income and withholding tax issues and compliance, including obtaining Treaty relief
• Foreign currency recognition rules under Sections 985-989
• US trade or business or local country permanent establishment (PE) issues
• Section 367 and other subchapter C issues related to cross-border restructurings, acquisitions and financings, including issues with respect to intellectual property

Sandra works with an extensive network of non-US lawyers on developing multi-jurisdictional business structures such as centralized sales and services and finance company structures.

Sandra is a co-founder of Tax in the City®: A Tax Roundtable, which consists of tax professionals who meet regularly to discuss substantive tax issues in a confidential setting.

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.

Barry J. Quirke focuses his practice on international corporate tax matters, including planning for corporate acquisitions, dispositions, reorganizations, spin-offs, joint ventures, intercompany transactions and cross-border financings. He works extensively with multinational corporations on post-acquisition integration strategies.

Barry previously served as the chief tax officer of a NYSE-traded mobile industrial equipment manufacturer with operations in more than 160 countries. He has developed and implemented global effective tax rate planning strategies for outbound and inbound multinational companies. Barry has worked on structuring multi-jurisdictional acquisitions, post-acquisition integration, internal reorganizations and joint ventures in Europe, Latin American and the Asia/Pacific region.

Barry speaks frequently on international tax topics for various professional organizations. He previously served as an adjunct professor at the Northwestern University School of Law LLM Tax Program and is currently an adjunct professor at the University of Illinois College of Law where he teaches international taxation.