International Tax Forum

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.

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.

Damon M. Lyon focuses his practice on cross-border mergers and acquisitions, global planning and international controversies for multinational companies. He advises clients on a broad range of tax issues, including tax-efficient structuring of acquisitions, dispositions, financings, internal reorganizations and joint ventures. Damon also provides advice concerning multi-jurisdictional business structures, such as intangible holding companies and finance company structures.

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.