TEI Central Texas Tax Seminar

Catherine (Cate) A. Battin is the head of McDermott Will & Schulte’s State & Local Tax Practice Group and has practiced at the firm for more than 20 years.

Cate represents clients in all aspects of state and local tax matters, including controversies at the audit, administrative, and judicial levels across several jurisdictions. She advises on national state tax strategies involving a broad range of issues, such as income tax apportionment, sourcing, nexus, transfer pricing, combination and sales tax characterization of products and services, and other local excise tax issues. She has a particular focus on state and local tax controversies and has litigated cases throughout the United States, successfully arguing cases before state appellate and supreme courts.

Cate regularly speaks on state and local tax issues and has presented before organizations such as the Tax Executives Institute, the Council on State Taxation, the Taxpayers’ Federation of Illinois, and The Chicago Tax Club.

Prior to joining McDermott, Cate worked at a major international accounting and consulting firm, where she focused exclusively on state and local taxes.

Richard C. Call focuses his practice on a broad range of state and local tax matters, including litigation, advisory, and transactional work. He represents clients in proceedings before administrative bodies, trial courts, and appellate courts across multiple jurisdictions.

Corporate Income Tax Litigation and Transactions: Richard has significant experience with all major areas of corporate income tax, advising clients on complex issues such as nexus, apportionment, addbacks, transfer pricing, and combination . He represents clients on transfer pricing and alternative apportionment issues in various states, including Alabama, Louisiana, and South Carolina. He also regularly works with clients to evaluate and efficiently structure state income and franchise tax related to mergers, acquisitions, and other strategic transactions.

Sales Taxes and Company Business Models: Richard advises clients on sales tax issues that are affecting their overall business models, helping companies structure transactions to mitigate sales tax exposure, which often results in significant savings. As states increasingly expand the taxation of software, digital products, and services, he assists companies in identifying and managing their exposure to such taxes, particularly in advance of mergers, acquisitions, and other liquidity events.

Personal Income Tax Residency: Richard routinely advises clients on residency for various states, including New York, Massachusetts, California, and Illinois

Speeches and Publications: Richard frequently speaks on state and local tax issues and has presented before organizations such as the NYU SPS Annual Institute on State and Local Taxation, the Council On State Taxation, the Tax Executives Institute, and the Practising Law Institute. He also publishes frequently on state and local tax topics, with articles appearing in several publications, including Tax Notes State, Bloomberg BNA Weekly State Tax Report, Bloomberg BNA Multistate Tax Report, Tax Executive, Journal of State Taxation, Boston Business Journal, and NYU SPS Annual Institute on State and Local Taxation.

Edward L. Froelich represents domestic and foreign public corporations, privately held companies, partnerships, trusts and individuals across the spectrum of federal tax controversies, including audits, trials and appeals. Ed’s clients include businesses, business owners and investors with operations and interests in the financial services, technology, real estate, healthcare and other industries.

A former trial attorney for the Tax Division of the US Department of Justice, Ed draws on his Justice experience to provide effective advocacy in Internal Revenue Service examination and appeals and in litigation before federal courts. Among other issues, Ed has successfully represented clients in disputes involving transfer pricing, worthless stock deductions, cross-border transactions, tax credits, income tax accounting, insurance, employment tax, accounting method issues and a variety of penalty assessments.

Ed also advises concerning privilege and work product questions and reporting obligations, including the obligation to file information returns such as those relating to the Form 1099 series, Form 1098, FinCEN 114, FATCA and employment taxes.

Ed is the author of the United States chapters of The Tax Disputes and Litigation Review and The Transfer Pricing Review, published by Law Business Research. He is a co-author of BNA’s Privilege in Tax and Accounting Matters (T.M. 635) and The Section 7525 Tax Practitioner-Taxpayer Privilege and Related Issues (Accounting Policy and Practice Series No. 5511).

After earning his law degree, Ed served as a law clerk for the Honorable John P. Wiese of the US Court of Federal Claims.

Parisa M. Griess represents taxpayers in complex, high-stakes federal tax controversy matters and tax litigation. She primarily represents US multinational corporations and high-net-worth individuals. She defends clients in Internal Revenue Service (IRS) examinations, IRS Appeals, alternative dispute resolution proceedings, litigation before the US Tax Court and other federal courts, and competent authority matters. She also frequently advises clients on audit risk and readiness.

In her pro bono practice, Parisa has litigated cases in the US District Court for the District of Columbia and the US Court of Appeals for the District of Columbia Circuit, defending individuals unlawfully detained by the US government.

During law school, Parisa served as a judicial intern for the Honorable Ricardo M. Urbina of the US District Court for the District of Columbia. Prior to law school, she worked at the US Department of the Treasury’s Office of Tax Policy, where she served as a financial economist and a Stanley S. Surrey Fellow.

Alex Cheng-Yi Lee focuses his practice on US and international tax planning and transactions involving US and non-US multinational companies, private equity funds, and entrepreneurial families.

Alex has advised on numerous spinoff transactions, divestitures, public offerings, and US and cross-border mergers and acquisitions involving public and private companies. He frequently counsels on tax-free reorganizations and optimization of existing operating structures as well as international tax issues, including tax-efficient repatriation strategies, tax basis planning, supply chain planning, principal structures, and foreign tax credit planning.

Additionally, Alex regularly advises on tax structuring and strategies to optimize tax efficiency in US inbound and outbound investments. His experience spans various business contexts, including closely held business and investments of entrepreneurial families as well as cross-border investments by multinationals and private equity funds.

Elizabeth C. Lu focuses her practice on US and international tax matters.  She advises clients on international tax issues, including the subpart F anti-deferral rules, foreign tax credit planning, repatriation, and the international provisions of the Tax Cuts and Jobs Act (GILTI, FDII, BEAT, etc.).  Elizabeth has experience advising multinational corporations on global supply chain restructurings, acquisitions, dispositions, joint ventures, post-acquisition integrations, internal reorganizations, tax controversies, and intellectual property migrations.  Elizabeth also advises clients on tax treaties, cost sharing agreements, and the taxation of the digital economy.

Elizabeth regularly speaks on international tax topics, including as part of the Tax in the City® Roundtable.

While in law school, Elizabeth served as a features editor for the Yale Law Journal.  Elizabeth also worked at the University of Chicago Law School as the chief research assistant to Judge Richard A. Posner and Professor William M. Landes.

Larissa Mussi focuses her practice on US and international tax matters. Larissa provides strategic counsel to corporate and private clients, navigating complex tax matters on domestic and cross-border transactions across a variety of industries.

During law school, Larissa served as the Chief Deputy for the Federal Tax Clinic and contributed more than 200 hours of pro bono service with organizations such as the Dallas Volunteer Attorney Program (DVAP) and the Child Poverty Action Program.

Larissa also has vast tax experience in South America as a Brazilian licensed lawyer, having focused on tax controversy matters for private clients and multinational corporations, aligned with tax planning strategies.

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.

Shawn O’Brien is nationally recognized by his peers and clients as a leading tax practitioner with a focus on tax litigation and controversies involving state, federal and international tax authorities. Drawing on his 25 years of experience, Shawn represents clients in tax examinations and administrative appeals and, when necessary, serves as a forceful advocate in litigation before the US Tax Court, US district courts, the US Court of Federal Claims, state courts and federal appellate courts. Shawn is the managing partner for the firm’s Houston office.

Clients interviewed in the Chambers USA Legal Guide 2024 shared that Shawn is “a trusted adviser and his level of service is superb” and he “has been a good strategic tax partner for our company,” particularly noting his “in-depth knowledge of our industry.”

Shawn’s experience spans a broad range of tax issues that affect many different industries, including energy, renewables, financial services, life sciences, manufacturing, media and entertainment, technology and aviation. He advises domestic, foreign and multinational corporations, partnerships, master limited partnerships, real estate investment trusts and limited liability companies on tax issues in connection with foreign and domestic transactions.

He also counsels clients in disputes involving transfer pricing, debt versus equity, loss carrybacks, international withholdings, advance pricing agreements, tax shelter disallowances, research and development tax credits, changes in accounting methods, captive insurance, related-party transactions, repatriation structures, inbound distributors, foreign credit transactions and penalty abatements. Shawn has also developed a market-leading federal and state excise tax practice that advises some of the largest corporations on excise tax planning and controversies.

Susan E. Ryba focuses her practice on federal tax controversy matters and tax litigation, particularly advising clients in the technology, healthcare, and pharmaceutical sectors, as well as high-net-worth individuals and complex partnerships.

Susan has substantial experience in all stages of federal tax controversies, including audits, administrative appeals, alternative dispute resolution proceedings, and litigation. She has resolved most of her matters at the Internal Revenue Service (IRS) examination level or through the IRS Independent Office of Appeals (IRS Appeals) and other dispute resolution forums. She advises clients on a broad range of domestic and international tax issues, including transfer pricing, research credit, effectively connected income, passive activity losses, Subpart F, Section 965, economic substance and other related doctrines, worthless stock and debt deductions, foreign-derived intangible income, foreign tax credits, summons enforcement, and penalties.

Susan frequently speaks at seminars sponsored by the Tax Executives Institute and teaches trial skills for the National Institute for Trial Advocacy.