McDermott Will & Schulte, a global law firm

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.

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.

John Karasek advises public and private companies in relation to US and international tax matters. He represents clients in a range of industries, with an emphasis on life sciences, software and emerging technologies. John advises on matters such as procurement operations, manufacturing, IP planning, trading and principal companies, and distribution models.

John brings a unique, business-driven approach to tax planning, having previously been a member of the Value Chain Management consulting group at a Big Four accounting firm. John develops a comprehensive understanding of his clients’ goals, the business’ core value drivers, and industry trends, and ultimately helps clients integrate tax planning into their strategic objectives.

John has presented on tax matters at the Tax Executives Institute and the American Bar Association at regional and national meetings. While in law school, John served as an associate editor for the Washington University Global Studies Law Review.

Bradford E. LaBonte focuses his practice on US and international tax matters. He advises multinational corporations and investment funds on matters related to cross-border mergers and acquisitions, cash repatriation, controlled foreign corporation (CFC) and passive foreign investment company (PFIC) regimes, financial instrument classification, US trade or business determinations, US income tax treaty qualification and planning, and US withholding tax issues.

Bradford previously worked as a senior associate with a “Big Four” accounting firm. Prior to that, he gained experience in the Internal Revenue Service Office of Chief Counsel and in the California Department of Justice Office of the Attorney General. During law school, Bradford served as executive editor for the Berkeley Journal of Employment and Labor Law.

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.

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.

Brian Moore focuses his practice on US and international tax matters.

While in law school, Brian served as an AmeriCorps JD Veterans Legal Assistance Intern for Legal Assistance of Western New York and he was an articles editor for the Yale Law and Policy Review. Prior to attending law school, he served as a research assistant for 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 matters. Additionally, he was a research analyst for a global think tank and a research assistant at a prominent tax policy think tank.

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.

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.