Levin College of Law

Mindy Herzfeld

Director, LL.M. in International Tax Program
Professor

About

Professor Mindy Herzfeld joined UF Law in 2017 as professor of tax law and director of the LL.M. in International Tax Program. Prior to joining UF Law, since 2014 Professor Herzfeld has been a contributing editor for Tax Analysts, authoring weekly columns on international tax policy developments and cross-border transactions in Tax Notes International. She continues to serve as a regular contributor to TNI, and is also of counsel at Ivins, Phillips & Barker, a specialty tax law firm based in Washington, D.C. Prior to assuming the position at Tax Analysts, Professor Herzfeld worked as an international tax advisor for Deloitte Tax LLP, based in its Washington, D.C., and New York offices. She began her career at Weil Gotshal & Manges in New York City and has also worked as tax counsel at Ford Motor Company. Professor Herzfeld received her J.D. from Yale Law School and her LL.M. in Taxation from Georgetown University Law Center. She has published over 100 articles in Tax Notes International and Tax Notes, many of which have been cited in law review articles by the leading international tax scholars, in Congressional Research Service Reports and in Treasury Department studies.

Education

LL.M., Georgetown University Law Center (with distinction)
J.D., Yale Law School (Editor, Yale Law Review)
B.A., Barnard College (magna cum laude)

Teaching and Scholarship

Adjunct Professor of Law, University of Maryland Carey School of Law, U.S. International Taxation. (Spring 2015)

Professional Activities

Ivins, Phillips & Barker: counsel with the firm’s corporate and international tax practice areas advising clients on domestic and international restructuring and transactions. (2017)

Tax Notes International: contributing editor, writing weekly column on international tax policy developments and cross-border transactions. (2014-present)

Deloitte Tax LLP: senior manager, New York International Tax Service and Washington International Tax Services (2004-2013). Provided transactional advice to U.S. and foreign multinational corporations, private equity funds, venture capital funds and wealthy individuals on a broad range of cross-border tax issues. Structured acquisitions, joint ventures and dispositions, including spin-offs. Led complex cross-border restructuring projects.

Law clerk for Judge L. Leo Glasser, U.S. District Court Eastern District of New York. (1995-1996)

Courses

U.S. International Tax I - LAW 7614
  • Tax definition of resident; distinction between domestic and foreign entities; taxation of business income and nonbusiness income of foreign persons; taxation of income of trades or business carried on by foreign persons in the U.S.; special rules on the U.S. real property interests; and branch interest taxes.
U.S. International Tax II-LLM - LAW 7615
  • The foreign tax credit; special rules on controlled foreign corporations; foreign currencies; and cross-border transfers in nonrecognition transactions.

Publications

A current listing of articles written by Professor Herzfeld for TaxNotes can be found here.

United States National Report to the 2013 IFA Annual Congress, Subject I: The taxation of foreign passive income for groups of companies (with Yariv Brauner), IFA, 98a Cahiers de Droit Fiscal International, (2013)

Debt Modifications –International Tax Considerations for U.S. Multinationals, 13 Int’l Tax J. 17 (2010) (with John Kennedy)

Stapled Stock Regulations Finalized as Proposed, 33 Intertax Issue 10, 482 (2005) (with Diane Renfroe)

Proposed Regulations Issued on Treatment of Stapled Foreign Corporations, 32 Intertax

Recent Presentations

“The Case Against Tax Coordination: Lessons from BEPS,” NYU Law School, April 5, 2017

“BEPS Implementation”, IFA USA Westchester Branch, April 6, 2017

Presenter, American Chamber of Commerce Luxembourg, US in Post-BEPS World, March, 2016

Panelist, American Chamber of Commerce Luxembourg, March, 2016

Presenter, University of Florida Levin College of Law Tax Colloquium, The Limits of Tax Coordination, February, 2016

Panelist, Global Tax Reset, Plenary at Deloitte International Tax Conference at Villanova University, November, 2015

Panelist, Base Erosion and Profit Shifting and International Tax Reform at American Tax Association Mid-Year Meeting, February, 2015

Panelist, Global Tax and Treasury Strategy Capturing, Communicating and Retaining Value in a Fast-Changing World at Deloitte International Tax Conference at Villanova University, November, 2014

Panelist, Selected BEPS Issues, University of Florida Levin College of Law International Tax Symposium, October 2014

BEPS Going Final — the OECD moves towards final deliverables on Country by Country Reporting, Hybrids, and Treaty Abuse, IFA USA Westchester Branch, May 2014

EU Exit Taxes and IP Migration, Deloitte Global Tax Roundtable, Dallas, October 2013

Update on International Tax Issues in M&A, Deloitte M&A Tax Luncheon, August 2013

Articles

A current listing of articles written by Professor Herzfeld for TaxNotes can be found here.