Tax in the City®: San Francisco

Parisa M. Griess focuses her practice on representing taxpayers in complex tax disputes against US and foreign tax authorities. Her diverse experience includes audit defense, administrative appeals, tax litigation, competent authority matters, and criminal tax investigations primarily for technology, media, and manufacturing companies, as well as high-net-worth individuals. She also frequently advises clients on audit risk and audit readiness. Parisa’s technical expertise includes transfer pricing, Subpart F, section 956, permanent establishments and other treaty matters, business deductions, executive compensation and employee benefits, withholding taxes, information reporting, summons enforcement, and penalties.

Beyond her tax practice, Parisa also has an active pro bono practice that has included representing individuals who have been unlawfully detained. She has also worked with the nonprofit Public International Law & Policy Group to provide pro bono legal and policy advice on drafting a post-conflict constitution for the Republic of Yemen and the creation and operation of a tribunal in Africa to prosecute piracy.

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.

Dominika Korytek focuses her practice on international tax planning, with an emphasis on technology companies. She advises clients on tax strategies for international expansion, domestic and international acquisitions, reorganizations and dispositions.

Dominika also advises clients related to international tax planning in mergers and acquisitions, dual consolidated loss issues, permanent establishment risk analysis, withholding tax and indirect (VAT/GST) tax planning. She also works closely with policy teams to obtain tax rulings and exemptions outside of the US.

She is a frequent author and speaker on topics pertaining to international taxation.

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.

Mary Kay McCalla Martire focuses her practice on a wide variety state and local tax issues. She advises clients on matters related to sales tax, with an emphasis on the sale of digital products. In addition, she advises business clients on income tax apportionment and remote employee withholding obligations. Mary Kay counsels individual clients on residency and income sourcing questions, and frequently advises captives and their insureds on direct procurement tax issues. She also has experience with state and local utility and telecommunications tax matters.

Mary Kay has an extensive litigation background in state and federal court, as well as administrative tribunals. She has particular experience in the defense of qui tam (whistleblower) claims filed in the state tax arena and has won the dismissal of many Illinois False Claims Act cases. Mary Kay played a key role in many of the reported decisions issued by the Illinois appellate court in this area. She also has experience defending clients against class action and consumer fraud claims.

Mary Kay also has represented clients in a number of state insurance tax litigation matters, including serving as the principal trial attorney for a group of insurance companies that successfully challenged the constitutionality of the Illinois Privilege Tax (Milwaukee Safeguard Ins. Co. v. Selky, 179 Ill.2d 94 (1997)).

Mary Kay serves as Co-Chair of the Chicago Office Pro Bono Committee. She is actively engaged in a number of pro bono matters, including the representation of not for profits seeking sales and property tax exemptions, and serving as a guardian ad litem in child custody disputes. In 2014, Mary Kay was awarded one of McDermott’s Chicago Office pro bono service awards. In addition, she is an editor of the Firm’s State Tax Blog, InsideSALT.com.

Advises on international tax matters relating to acquisitions, dispositions, and reorganizations

Guides clients through internal reorganizations, post-acquisition integrations, and inbounding transactions

Advises on the implications of international tax developments on intangible holding companies, finance company structures, and cash repatriation strategies

Helps clients navigate issues relating to NCTI, FDDEI, expense allocation and apportionment, and foreign tax credits

Advises on US income tax treaty qualification and treaty benefits

Guides taxpayers through tax controversy, including serving as lead technical counsel on a US Tax Court case where the taxpayer won on all issues

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.