West Coast Tax Roundtable: California & Beyond: The Impact of State, Federal and International Tax Developments on Golden State Taxpayers

Steven Hadjilogiou focuses his practice on tax optimization of business operations and investments with a specific emphasis in the areas of international tax and real estate. Steven provides advice on international inbound and outbound tax planning for multinational companies, family offices, private equity and ultra-high net worth individuals. He also advises funds, family offices and ultra-high net worth individuals in connection with complex real estate structuring and investment issues, including in the areas of opportunity zone funds, 1031 transactions and qualified small business stock.

Steven has represented various Fortune 500 companies and major privately held businesses in their tax planning and supply chain projects, and also has substantial experience advising on transfer pricing, tax-related intellectual property matters, Subpart F, GILTI, foreign investment in US real property and outbound investment in real property. Steven also advises clients on pre-immigration planning and cross-border wealth succession. Steven has also worked on the taxation of partnerships and corporations, mergers & acquisitions and international corporate reorganizations.

Since 2013, Steven has been an adjunct professor of International Inbound Taxation at the University of Miami Graduate Tax Program. He is the co-chair of the annual Florida Bar/FICPA International Tax Conference. Steven has written numerous articles and presented on topics related to tax. He was a primary drafter of the amicus curiae brief submitted to the US Supreme Court on behalf of the Florida Bar Tax Section in Knight v. Commissioner in 2008.

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.

Marcy Jo Mandel focuses her practice on state and local tax (SALT) controversies, in addition to advising clients of federal tax controversies, corporate mergers and acquisitions, and provides state tax strategies for clients on a full range of state tax issues.

Before returning to private practice in January 2015, Marcy Jo served as Deputy State Controller, Taxation, representing the California State Controller, a statewide elected constitutional officer, on the State Board of Equalization and the Franchise Tax Board. Additionally, she represented the Controller on the California Streamlined Sales Tax Project Board of Governance. Marcy Jo represented the Controller on the California Commission on Tax Policy in the New Economy during its two-year existence, and also represented the Controller on other boards and commissions, including specifically the California Tax Credit Allocation Committee and the State Lands Commission, on an as needed basis. In her role, Marcy Jo occupied the highest appointed tax position in California and served three consecutive State Controllers. As senior advisor to the Controller, she testified before the IRS Oversight Board. She also testified before California legislative committees on tax matters.

Marcy Jo previously was a tax litigator involved in federal, state and local tax for more than 15 years. She was a law clerk for the late Honorable Francis D. Murnaghan, Jr., of the US Court of Appeals for the Fourth Circuit and was an adjunct professor at Loyola Law School for five years and is a former Chair of the California State Bar Taxation Section.

Charles (Chuck) Moll focuses his practice on state and local tax (SALT), primarily concentrating on the resolution of tax controversies. He regularly appears before the various California tax authorities—including the State Board of Equalization, the California Franchise Tax Board, the California Department of Tax and Fee Administration, and the Office of Tax Appeals—as well as local authorities such as assessors and assessment appeals boards. He has litigated at all levels of California's courts, the US Tax Court, and the US Supreme Court.

Chuck’s practice includes tax matters in other states, as well as federal tax controversies, including representation of clients in federal courts and at appellate hearings before the Internal Revenue Service.

Troy Van Dongen focuses his practice on the resolution of state and local tax (SALT) controversies through negotiation and litigation. He advises clients across the country in a variety of state and local tax matters, including income, franchise, sales, and use taxes, and he has a particularly strong background in property taxation.

Troy’s experience includes a wide range of industries, including: manufacturing and software; banking and finance; biotechnology; hospital management; non-profit organizations; commercial office leasing; solar and geothermal power production; lodging; education; security services; oil and gas; telecommunications; paper manufacturing; and sports and entertainment. He also counsels clients on the tax consequences of new forms of communications technology and the unique tax challenges in the telecommunications industry.

He is also a member of our legal cannabis industry group. Our Cannabis Industry group is a multidisciplinary team of lawyers providing clients with regulatory, litigation, intellectual property, trade and tax services with respect to their investments and participation in the cannabis industry, all subject to the Firm’s obligations under federal and state laws and bar licensure rules.