Levin College of Law

Fred F. Murray

Director of the Graduate Tax Program
Professor of Law

Expertise

Tax Law  • 

About

Fred Murray is an attorney (District of Columbia, Maryland, New York, and Texas (Board Certified in Tax Law, Texas Board of Legal Specialization), and various federal courts) and C.P.A. (Maryland and Texas).

His experience includes public law and accounting practice, government service as Deputy Assistant Attorney General in the Tax Division at the Department of Justice and as a Special Counsel to the Chief Counsel for the Internal Revenue Service, where he was involved in drafting of legislation and testimony, legislative investigations, and other Congressional matters, litigation, and in regulations, revenue rulings and other agency guidance. Fred also served as Vice President for Tax Policy at the National Foreign Trade Council and General Counsel and Director of Tax Affairs at the Tax Executives Institute.

He is a former Chair of the U.S. Internal Revenue Service Advisory Council (formerly the Commissioner’s Advisory Group, 1953 – 1998); former Advisor to the International Tax Working Group of the United States Senate Finance Committee; and a former member, Commissioner’s Advisory Council, Department of Taxation and Finance, State of New York.

He is incoming Vice Chair for Continuing Legal Education, and a former Council Director, governing Council of the American Bar Association Section of Taxation; former Chair, Subcommittee on Tax Treaties and Competent Authority Matters, U.S. Activities of Foreigners & Tax Treaties Committee; former Chair, Administrative Practice Committee; and also a member, Foreign Activities of U.S. Taxpayers, Corporate Taxation, Government Relations and Government Submissions Committees, American Bar Association Tax Section. He is a member of the Steering Committee of the Federal Bar Association Tax Section (previously Chair 2012-2013 and 1998-1999), and a Fellow of the American College of Tax Counsel. He is a Life Elected Member of the American Law Institute, a member of the American Institute of Certified Public Accountants, and a member of the Bloomberg BNA International and Transfer Pricing Tax Advisory Board.

He previously taught as an adjunct member of the faculty at Georgetown University Law Center where he taught courses on international taxation and accounting for income taxes, corporate governance, securities law and other issues for corporate tax advisors. He has also lectured at the New York University School of Law. Previously, Fred Murray was also an adjunct professor at the University of Texas School of Law, Rice University Jesse H. Jones Graduate School of Management, and the University of Houston Law Center.

In addition, he is author of 6845-1 T.M., U.S. GAAP and Related Administrative Requirements for the International Tax Practitioner, BNA Tax Management Portfolio, Foreign Income Series, and an author and speaker on taxation and tax controversies, accounting and financial reporting, business and corporate governance, international and property law matters in more than 200 books, publications and programs published or conducted by various organizations in the United States and other countries. He has been cited in numerous articles in the press in the U.S. and abroad.

He serves and has served in various civic and charitable organizations and as a Catholic Charities Runner in the Marine Corps Marathon.

Education

J.D. University of Texas at Austin

B.A. Rice University

Areas of Practice

U.S. and International Taxation, including withholding taxes, foreign information reporting and examinations, including FATCA and CRS and CbC regimes; Business, Estate and Trust Planning and Structuring; Transfer Pricing and Tax Controversies, Competent Authority Proceedings, and Litigation; Tax Policy, Legislation and Congressional Investigations; Financial Accounting for Income Taxes; Corporate Governance, Internal Investigations, and Audit Committees; Sarbanes-Oxley Act (SOX) Compliance; and Corporate Risk Management.

Publications

Previous Presentations and Writing

Author and speaker on taxation, financial reporting, business and corporate governance, international and property law matters in more than 200 books, publications and programs published, sponsored, and conducted by: Aspen Institute, Berlin, Germany; U.S. Internal Revenue Service; American Law Institute; American Bar Association; Georgetown University Law Center, Washington, D.C.; Federal Bar Association; Practising Law Institute; Journal of Taxation; World Trade Institute of New York; Wall Street Journal; National Public Radio; British Broadcasting Corporation; Tax Executives Institute; International Law Institute, Washington, D.C. (Georgetown University); Association of International Petroleum Negotiators; Society of Petroleum Engineers; and various other universities, professional associations and entities.

Selected Publications

Author and speaker on taxation, financial reporting, business and corporate governance, international and property law matters in more than 200 books, publications and programs published, sponsored, and conducted by: Aspen Institute, Berlin, Germany; U.S. Internal Revenue Service; American Law Institute; American Bar Association; Georgetown University Law Center, Washington, D.C.; Federal Bar Association; Practising Law Institute; Journal of Taxation; World Trade Institute of New York; Wall Street Journal; National Public Radio; British Broadcasting Corporation; Tax Executives Institute; International Law Institute, Washington, D.C. (Georgetown University); Association of International Petroleum Negotiators; Society of Petroleum Engineers; and various other universities, professional associations and entities.

  • Author, “Getting Ready for the New Partnership Examination Rules Enacted in the Bipartisan Budget Act of 2015,” annual multi-volume “Tax Planning for Domestic & Foreign Partnerships, LLCs, Joint Ventures & Other Strategic Alliances,” Practising Law Institute, New York, NY, 2017 programs and editions.
  • Column Article Author, Ethics & Tax Procedure Corner, Wolters Kluwer CCH Journal of Passthrough Entities, selected recent articles: “New Partnership Audit Rules Affect Oil and Gas and Other Investment Partnerships,” September – October 2016; “New Partnership Audit Rules Require Action Now in Respect to Partnership Agreements,” May-June, 2016; “Partnership Withholding in Cross-Border Transactions,” September-October, 2015; “The Need for New Approaches in Making Adjustments to the Tax Accounts and Tax Returns of Large Partnerships – TEFRA Needs to be Updated,” April – May, 2015.
  • US Branch Co-Reporter, Exchange of Information and Cross-Border Cooperation between Tax Authorities USA Branch Report, International Fiscal Association – Copenhagen Congress 2013.
  • Author, “FIN 48 — Changes Affecting Private Entities, Partnerships and Pass-throughs, Tax Exempt Organizations, and Business Combinations,” annual multi-volume “Tax Strategies for Corporate Acquisitions, Dispositions, Spin-Offs, Joint Ventures, Financings, Reorganizations & Restructurings,” Practising Law Institute, New York, NY, 2009, 2010, 2011, 2012, 2013, 2014, 2015, and 2016 programs and editions.
  • Author, 6845-1 T.M., U.S. GAAP and Related Administrative Requirements for the International Tax Practitioner, Bureau of National Affairs, Tax Management Portfolios, Foreign Income Series, 2012.
  • Author, “Uncertainties Increase for Private Equity Investment,” Bureau of National Affairs, Daily Tax Report, Washington, D.C., June 27, 2007.
  • Author, “FIN 48 – Now for Private and Public Entities,” Bureau of National Affairs, Daily Tax Report, Washington, D.C., August 31, September 1 – 4, 2009 (published in 5 parts). Also published as “FIN 48: Now for Public and Private Entities,”  Accounting Policy and Practice, Special Report, Volume 5, Number 3, Bureau of National Affairs, September 18, 2009, and in Tax Management, Accounting Series Portfolios.
  • Co-Author, “Promote Dividend Repatriation,” included in compilation Toward Tax Reform – Recommendations for President Obama’s Task Force, Tax Analysts, Washington, DC, September, 2009.
  • Editor-in-Chief, Co-Author, The NFTC Foreign Income Project: International Tax Policy for the 21st Century, National Foreign Trade Council, Inc., Washington, DC, December, 2001.
  • The Euromoney Global Tax Handbook, “Challenges facing the corporate tax department,” Euromoney Institutional Investor PLC, London, 2004 ed.
  • Co-Author, Taxation of Natural Resources – Oil, Gas, Minerals and Timber, Practising Law Institute, New York, New York, 1987.

Selected More Recent Speaking Engagements

  • Moderator-Panelist, “Bankruptcy and Insolvency Effects on Examinations and Collections,” Committee on Administrative Practice, ABA Section of Taxation, New Orleans, LA, CA, January 9, 2009.
  • Moderator-Panelist, “Congress Has Changed the Rules Again – The Latest on the Newest New Return Preparer Standards and Final Regulations Just Released by Treasury,” ABA National Webinar, Washington, DC, January 14, 2009.
  • Program Co-Chair and Panelist, “Ethical Considerations in Federal Tax Controversies,” Federal Bar Association, Washington, DC, March 7, 2009.
  • Moderator-Panelist, “Update on International Enforcement and Examinations,” Committee on Administrative Practice, ABA Section of Taxation, Washington, DC, May 8, 2009.
  • Panelist, “Planning for the Audit,” NYU 1st Annual Tax Controversy Forum, New York, NY, June 12, 2009.
  • Moderator-Panelist, “Walking the Line(s) and Not Crossing Them: Parallel Civil and Criminal Examinations,” Committee on Administrative Practice, ABA Section of Taxation, Chicago, IL, September 25, 2009.
  • Program Co-Chair and Panelist, “Ethical Issues in Federal Tax Controversy Practice,” Federal Bar Association, Washington, DC, March 5, 2010.
  • Panelist, “The New IRS Corporate Tax Governance Initiative,” Committee on Administrative Practice, ABA Section of Taxation, Washington, DC, May 7, 2010.
  • Speaker, “Uncertain Tax Positions: FIN 48: the Road to a Better Tax System?” TEI Wisconsin Chapter Meeting and Conference, Milwaukee, WI, May 18, 2010.
  • Panelist, “Foreign Financial Assets and Payments to Foreign Persons: Enforcement of Reporting and Withholding Obligations,” NYU 2nd Annual Tax Controversy Forum, New York, NY, June 18, 2010.
  • Moderator-Panelist, “Future of International Enforcement in the Burgeoning Global Economy,” Committee on Administrative Practice, ABA Section of Taxation, Toronto, Ontario, Canada, September 24, 2010.
  • Panelist, “Tax Procedure, Penalties, and Practical Problems,” 45th Annual Southern Federal Tax Institute, Atlanta, GA, September 29, 2010.
  • Speaker, Practical Ethics Issues for In-House Tax Professionals, Tax Executives Institute, Philadelphia Chapter, Malvern, Pennsylvania, October 6, 2010.
  • Discussion Leader, “U.S. Tax System in a Global Economy,” Federal Bar Association 11th Biennial Conference on Tax Administration and Legislative Process, Airlie House, Virginia, November 3-4, 2010.
  • Co-Discussant, “FATCA in a Nutshell,” Subcommittee on IRS Liaison Activities, Committee on Administrative Practice, Nationwide Conference Call, December 15, 2010.
  • Panelist, “Section 7701(o) – The Newly Codified Economic Substance Doctrine,” Committee on State Taxation, Mid-Atlantic Regional Tax Seminar, Berwyn, Pennsylvania, December 21, 2010.
  • Co-Discussant, “Update on IRS LB&I Joint Audit Program,” Subcommittee on IRS Liaison Activities, Committee on Administrative Practice, Nationwide Conference Call, January 19, 2011.
  • Moderator-Panelist, “Foreign Financial Assets and Payments to Foreign Persons: Enforcement of Reporting and Withholding Obligations,” Committee on Administrative Practice, ABA Section of Taxation, Boca Raton, Florida, January 21, 2011.
  • Panelist, “Leading Government and Private Practitioners Panel Discusses IRS’ Second Special Voluntary Disclosure Initiative, BNA National Tax and Accounting Webinar, February 18, 2011.
  • Panelist, “Ethics in Tax Practice,” Tax Executive Institute Audits and Appeals Seminar: Tax Controversies in a Post-Schedule UTP World, Orlando, Florida, February 23, 2011.
  • Moderator-Panelist, “Just What Do They Know? Exchange of Information between Tax Authorities and Joint Cooperation,” Federal Bar Association Annual Tax Law Conference, Washington, DC, February 25, 2011.
  • Co-Chair and Moderator-Panelist, “Ethics and the Federal Tax Practice,” Federal Bar Association Annual Tax Law Conference, Washington, DC, February 25, 2011.
  • Moderator-Panelist, “IRS Initiative on Reporting Uncertain Tax Positions,” University of Virginia Tax Study Group, Charlottesville, Virginia, March 25, 2011.
  • Speaker, “U.S. Federal Audit Trends and Issues,” HOTEC Hotel and Hospitality Association, Stone Mountain, GA, May 5, 2011.
  • Moderator-Panelist, “Managing International Tax Audits For Multinational Corporations, Committee on Administrative Practice, ABA Section of Taxation, Washington, DC, May 6, 2011.
  • Moderator-Panelist, “Dealing with Conflicts of Interest in Common Practice Situations,” Committee on Standards of Tax Practice, ABA Section of Taxation, Washington, DC, May 6, 2011.
  • Panelist, “The Move Towards ‘No Fault’; The Accuracy Penalty Reconsidered,” Committee on Civil & Criminal Tax Penalties, ABA Section of Taxation, Washington, DC, May 7, 2011.
  • Speaker, “Practical Ethics Issues for In-House Tax Professionals,” Tax Executives Institute, Westchester-Fairfield Chapter, Darien, Connecticut, May 19, 2011.
  • Moderator, “LB&I and SB/SE Compliance and Enforcement Programs Update,” NYU 3rd Annual Tax Controversy Forum, New York, NY, June 10, 2011.
  • Discussant, “Update on IRS LB&I Issue Practice Groups,” Subcommittee on IRS Liaison Activities, Committee on Administrative Practice, Nationwide Conference Call, June 15, 2011.
  • Speaker, “FATCA and Its Application to Investment Entities,” Grant Thornton LLP Client Webcast, Washington, DC, August 2, 2011.
  • Moderator-Panelist, “I Knew my Taxes Were Complicated – But an Engineer and a Computer Specialist?”, Committee on Administrative Practice, ABA Section of Taxation, Denver, CO, October 21, 2011.
  • Moderator-Panelist, “FATCA – Not Just for Banks: Application of FATCA to Investment and Real Estate Funds,” Committee on U.S. Activities of Foreigners and Tax Treaties, ABA Tax Section, Denver, CO, October 21, 2011.
  • Moderator-Panelist, “The Limits of the Attorney-Client Privilege and the Work Product Doctrine,” The Clearing House’s First Annual Business Meeting & Conference, The Clearing House Association LLC, New York, NY, November 9, 2011.
  • Discussant, “Update on IRS LB&I Issue Practice Groups and Management of Schedule UTP in Examinations,” Subcommittee on IRS Liaison Activities, Committee on Administrative Practice, Nationwide Conference Call, November 16, 2011.
  • Panelist, “Economic Substance Doctrine: The Brave New World,” ABA 28th Annual National Institute on Criminal Tax Fraud and the First National Institute on Tax Controversy, Las Vegas, NV, December 1-2, 2011.
  • Moderator – Panelist, The New Proposed Foreign Account Tax Compliance Act (“FATCA”) Regulations, Committee on US Activities of Foreigners and Tax Treaties, ABA Tax Section, San Diego, CA, February 17, 2012.
  • Moderator – Panelist, Enforcement and Criminal Tax Symposium, IRS Investigation Stage and DOJ and Litigation Stage Panels, Federal Bar Association Annual Tax Law Conference, Washington DC, March 2, 2012.
  • Moderator – Panelist, Ethics and the Federal Tax Practice, Federal Bar Association Annual Tax Law Conference, Washington DC, March 2, 2012.
  • Moderator – Panelist, Tips and Traps in Transfer Pricing Examinations, Committee on Administrative Practice, ABA Tax Section, Washington, DC, May 11, 2012.
  • Moderator – Panelist, Losing the Forest Through the Trees: Has “Legending” of E-mails and Other Communications Caused Practitioners to Lose Sight of the Underlying Ethical Rules?  Risk Management Issues for Practitioners, Committee on Standards of Tax Practice, ABA Tax Section, Washington, DC, May 11, 2012.
  • Moderator – Panelist, IRS Enforcement Priorities: What’s Happening Now? A Conversation with Senior IRS Executives, 4th Annual NYU Tax Controversy Forum, New York, NY, June 15, 2012.
  • Co-Presenter, “Selected Developments in IRS’s Large Business & International Division,” Corporate Accountants Conference, ACS Live, Dulles, VA, October 22, 2012.
  • Moderator – Panelist, “Penalties, More and More: How to Assess and Deal with Exposures and Seek Relief,” 60th Annual Taxation Conference, University of Texas School of Law, Austin, TX, December 5, 2012.
  • Moderator – Panelist, “Ask the Experts: Top Civil Tax Practice Tips and Representation Strategies,” ABA 29th Annual National Institute on Criminal Tax Fraud and the Second National Institute on Tax Controversy, Las Vegas, NV, December 6-7, 2012.
  • Moderator-Panelist, “The Procedural Side of FATCA: Withholding Operations, Refunds and Examinations, ABA Tax Section, Orlando, Florida, January 25, 2013.
  • Program Co-Chair (w/ Mark Prater, Deputy Staff Director, Senate Finance Committee) and Discussant, Twelfth Biennial FBA Invitational Conference on Tax Legislation and Administration (f/k/a The FBA Airlie House Conference), Federal Bar Association, Cannon Caucus Room, Capitol Hill, Washington, DC, Wednesday, February 20, 2013.
  • Moderator – Panelist, Enforcement and Criminal Tax Symposium, IRS Investigation Stage and DOJ and Litigation Stage Panels, Federal Bar Association Annual Tax Law Conference, Washington DC, March 1, 2013.
  • Panelist, “Finding Hidden Treasure: How to Use the Freedom of Information Act (FOIA) and Other Tools to Uncover Valuable Evidence,” 5th Annual NYU Tax Controversy Forum, New York, NY, June 7, 2013.
  • Speaker, Tax Practice Ethics for Preparers and Advisers, Handling a Tax Controversy: Audits, Appeals, Litigation and Collections Seminar and National Webinar, American Law Institute CLE, Washington, DC, September 17, 2013.
  • Speaker, International Controversy Update Including Country Information Sharing, Tax Executives Institute, New Jersey Chapter, Randolph, NJ, November 8, 2013.
  • Moderator – Panelist, “Finding Hidden Treasure: How to Use the Freedom of Information Act (FOIA) and Other Tools to Uncover Valuable Evidence,” 61st Annual Taxation Conference, University of Texas School of Law, Austin, TX, December 4, 2013.
  • Moderator – Panelist, “Everything Is Fine Until It Isn’t – Ethical Problems in a Tax Practice,” ABA 30th Annual National Institute on Criminal Tax Fraud and the Second National Institute on Civil Tax Controversy, Las Vegas, NV, December 11-12, 2013.
  • Panelist, “Teaching Ethics: Just Whose Responsibility Is It, Anyway?” (Training in Firms and Companies and Other Institutions); Standards of Tax Practice Committee, ABA Section of Taxation Meeting, Phoenix, AZ, January 24, 2014.
  • Panelist, “Ensuring Compliance With Circular 230, Responsibilities of Firm Management,” Standards of Tax Practice Committee, ABA Section of Taxation Meeting, Phoenix, AZ, January 24, 2014.
  • Moderator-Panelist, International Tax Enforcement Issues, Enforcement & Criminal Tax Symposium, 38th Annual Tax Law Conference, Federal Bar Association, Washington, DC, February 28, 2014.
  • Moderator-Panelist (along with Drita Tonuzi – Associate Chief Counsel (Procedure & Administration, Office of Chief Counsel, IRS, “Ethics in the Federal Tax Practice,” 38th Annual Tax Law Conference, Federal Bar Association, Washington, DC, February 28, 2014.
  • Panelist, Ethical and Other Practice Problems of Inbound Controversies; U.S. Activities of Foreigners and Tax Treaties Committee, ABA Section of Taxation Meeting, Washington, DC, May 6, 2014.
  • Moderator-Panelist (along with Michael Danilack – Deputy Commissioner (International) and U.S. Competent Authority, LB&I Division, Internal Revenue Service), Recent International Activities and Future Focus of IRS LB&I; Administrative Practice Committee, ABA Section of Taxation Meeting, Washington, DC, May 6, 2014.
  • Panelist, Planning for Disaster: Making Sure the Flood, Fire, Hurricane or Tornado Isn’t a Disaster for Your Practice; Tax Practice Management Committee, ABA Section of Taxation Meeting, Washington, DC, May 7, 2014.
  • Moderator-Panelist (along with Rosemary J. Sereti, Industry Director, Financial Services, LB&I Division, Internal Revenue Service), Tax Enforcement: Coming Attractions – IRS Large Business and International Division Update; 6th Annual NYU Tax Controversy Forum, New York, NY, June 20, 2014.
  • Instructor, ASC 740 U.S. Foreign Tax Provision and Local Country Considerations, Corptax ASC 740 Accounting for Income Taxes, Dallas, Texas, July 31-August 1, 2014.
  • Panelist, Everything Is Fine Until It Isn’t: Ethical Problems in a Tax Practice, ABA Tax Section National Webinar, August 12, 2014.
  • Panelist, Kicking it Upstairs – How to Elevate Issues Within the IRS; Administrative Practice Committee, ABA Section of Taxation Meeting, Denver, CO, September 19, 2014.
  • Panelist, Information Gathering Audits: IDRs, Summonses, and Third-Party Information, Handling a Tax Controversy: Audits, Appeals, Litigation and Collections Seminar and National Webinar, American Law Institute CLE, Washington, DC, October 16-17, 2014.
  • Panelist, Summonses, Subpoenas, IDRs: What the Changing Landscape Really Means, ABA 31st Annual National Institute on Criminal Tax Fraud and the Second National Institute on Civil Tax Controversy, Las Vegas, NV, December 12, 2014.
  • Panelist, Kicking it Upstairs – How to Elevate Issues Within the IRS, ABA Tax Section National Webinar, January 14, 2015.
  • Panelist, Breaking Up Is Hard to Do: Protecting Divorcing Spouses From the IRS and Each Other; Individual & Family Taxation Committee, ABA Section of Taxation Meeting, Houston, TX, January 29-31, 2015.
  • Panelist (with IRS Chief of Appeals), Resolving Cases at Today’s Appeals, Tax Practice & Procedure Symposium, 39th Annual Tax Law Conference, Federal Bar Association, Washington, DC, March 6, 2015.
  • Moderator-Panelist, International Tax Enforcement Issues, Enforcement & Criminal Tax Symposium, 39th Annual Tax Law Conference, Federal Bar Association, Washington, DC, March 6, 2015.
  • Moderator-Panelist (along with Drita Tonuzi – Associate Chief Counsel (Procedure & Administration, Office of Chief Counsel, IRS, “Ethics in the Federal Tax Practice,” 39th Annual Tax Law Conference, Federal Bar Association, Washington, DC, March 6, 2015.
  • Discussant, “OECD Country-by-Country Reporting,” Subcommittee on IRS Liaison Activities, Committee on Administrative Practice, Nationwide Conference Call, April 15, 2015.
  • Moderator-Panelist (along with Heather Maloy – Commissioner, LB&I Division, and Kirsten Wielobob, Chief, Appeals Office, Internal Revenue Service), The New Way Forward: LB&I Examinations and Appeals; Administrative Practice Committee, ABA Section of Taxation Meeting, Washington, DC, May 8, 2015.
  • Instructor, ASC 740 U.S. Foreign Tax Provision and Local Country Considerations, Corptax ASC 740 Accounting for Income Taxes, Dallas, Texas, May 28-29, 2015.
  • Moderator-Panelist, Non-Traditional Tax Advocacy; 7th Annual NYU Tax Controversy Forum, New York, NY, June 5, 2015.
  • Panelist, Ethical Considerations in Tax Controversy: What You Need to Consider in Representing Your Client or Company, National Webinar, Federal Bar Association, June 25, 2015.
  • Speaker, Treasury Proposes New U.S. Model Treaty Provisions, Houston International Tax Forum, Houston, TX, July 2, 2015.
  • Panelist, Circular 230, Penalties and the Office of Professional Responsibility, Internal Televised Training for Examiners, Internal Revenue Service, New Carrollton, MD, August 20, 2015.
  • Instructor, ASC 740 U.S. Foreign Tax Provision and Local Country Considerations, Corptax ASC 740 Accounting for Income Taxes, Dallas, Texas, September 28-29, 2015.
  • Panelist, Best Practices and Strategies for Resolving Cases at Exam, Handling a Tax Controversy: Audits, Appeals, Litigation and Collections Seminar and National Webinar, American Law Institute CLE, Washington, DC, October 8-9, 2015.
  • Moderator – Panelist, “Ethics Landmines for 2015,” 63rd Annual Taxation Conference, University of Texas School of Law, Austin, TX, December 2, 2015.
  • Panelist, Summonses, Subpoenas, IDRs: What the Changing Landscape Really Means, ABA 31st Annual National Institute on Criminal Tax Fraud and the Second National Institute on Civil Tax Controversy, Las Vegas, NV, December 12, 2014.
  • Moderator-Panelist, International Tax Enforcement Issues, Enforcement & Criminal Tax Symposium, 40th Annual Tax Law Conference, Federal Bar Association, Washington, DC, March 4, 2016.
  • Moderator-Panelist (along with Drita Tonuzi – Associate Chief Counsel (Procedure & Administration, Office of Chief Counsel, and Thomas Kane, LB&I Division Counsel, IRS), “Ethics in the Federal Tax Practice,” 40th Annual Tax Law Conference, Federal Bar Association, Washington, DC, March 4, 2016.
  • Moderator, Panelist (along with Theodore Setzer, Assistant Deputy Commissioner International, LB&I Division, and Sharon Porter, Director, Treaty and Transfer Pricing Operations Practice Area, LB&I Division, Internal Revenue Service), Managing Transfer Pricing, Double Taxation, and Other Complex Tax Matters in a Post-BEPS World, Administrative Practice Committee, ABA Section of Taxation Meeting, Washington, DC, May 6, 2016.
  • Panelist, Data Security, Client Confidences and Ethics Rules Applicable to the Protection of Client Information, Standards of Tax Practice Committee, ABA Section of Taxation Meeting, Washington, DC, May 6, 2016.
  • Panelist, Turning the Tables: The United States as a Tax Haven Destination, Civil Criminal Tax Penalties Committee, ABA Section of Taxation Meeting, Washington, DC, May 7, 2016.
  • Instructor, ASC 740 U.S. Foreign Tax Provision and Local Country Considerations, Corptax ASC 740 Accounting for Income Taxes, Dallas, Texas, May 23-24, 2016.
  • Panelist, (along with Pamela Drenthe, Director, Withholding & International Compliance Practice Area, Internal Revenue Service), Contesting Withholding Tax Liabilities and Penalties Arising From Payments to Foreign Persons , 8th Annual NYU Tax Controversy Forum, New York, NY, June 24, 2016.
  • Panelist, Turning the Tables: The United States as a Tax Haven Destination, ABA Tax Section National Webinar, July 20, 2016.
  • Panelist, Data Security, Client Confidences and Ethics Rules Applicable to the Protection of Client Information, ABA Tax Section National Webinar, August 24, 2016.
  • Presenter, Update on Enforcement of Payment Reporting and Withholding Obligations, Houston International Tax Forum, Houston, TX, October 6, 2016.
  • Panelist, International Transparency, including Country by Country Reporting, 29th Annual GW IRS Institute on Current Issues in International Taxation, Washington, DC, December 15, 2016.
  • Moderator-Panelist, International Tax Enforcement Issues, Enforcement & Criminal Tax Symposium, 41st Annual Tax Law Conference, Federal Bar Association, Washington, DC, March 3, 2017.
  • Moderator-Panelist (along with Thomas Kane, LB&I Division Counsel, IRS), “Ethics in the Federal Tax Practice,” 41st Annual Tax Law Conference, Federal Bar Association, Washington, DC, March 3, 2017.
  • Instructor, ASC 740 U.S. Foreign Tax Provision and Local Country Considerations, Corptax ASC 740 Accounting for Income Taxes, Dallas, Texas, May 25-26, 2017.
  • Moderator-Panelist, The World Is Changing on January 1, 2018: The New Partnership Audit Rules – What They Might Mean For You, 8th Annual NYU Tax Controversy Forum, New York, NY, June 16, 2017.