Levin College of Law

Mindy Herzfeld

Professor of Practice

About

Mindy has a background in international taxation and cross-border M&A from her years in practice and in tax policy from her work as a contributing editor at Tax Notes International. She has taught International Tax I and II, and Tax Policy, to both JD and LLM students. She has also developed a course (the first of its kind) in Artificial Intelligence and Taxation.
Mindy is the author of International Taxation in a Nutshell (12th ed.), a popular text for new students of international taxation.

Mindy began her career as a law clerk for Judge I. Leo Glasser (E.D.N.Y.) and has worked at Weil Gotshal & Manges in New York, as tax counsel at Ford Motor Company, and in the national office of a Big4 accounting firm. She has been a contributing editor to Tax Notes International since 2014, where she has written over 250 articles on international tax policy developments and cross-border transactions, and has also written extensively on U.S. tax reform efforts.

Previously, Mindy worked at the national tax office and the New York office of a Big 4 accounting firm, where she provided transactional advice to U.S. and foreign multinational corporations, private equity funds, venture capital funds and individuals on a broad range of U.S. and cross-border tax issues. She currently is counsel to Potomac Law Group, a virtual law firm.
She holds an LL.M. in taxation from Georgetown University Law Center, with distinction, where she was a Graduate Tax Scholar, a J.D. from Yale Law school, where she served as an editor of the Yale Lew Review, and a B.A. in history from Barnard College, magna cum laude.

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

International Tax and Tax Policy

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.