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Andy Immerman, Conference Co-Chair…
Andy is a member of the Federal Income Tax Group and the International Tax Group. He concentrates on federal income tax matters, including domestic and international tax planning and transactional work for joint ventures, partnerships, limited liability companies, and corporations. Andy has helped structure many sophisticated partnership and limited liability company transactions. He has represented the target or the acquirer in numerous corporate mergers and acquisitions. He has also worked on many tax-free exchanges. Andy is a frequent author and speaker on domestic and international income tax topics. He is the author or co-author of articles that have appeared in Corporate Taxation, Insurance Tax Review, International Tax Review, Journal of Taxation, Journal of Taxation of Financial Institutions, Journal of Taxation of Financial Products, Journal of Taxation of Global Transactions, Labor Lawyer, Limited Liability Company Reporter, Mergers and Acquisitions, National Law Journal, Practical Tax Lawyer, Practical US/Domestic Tax Strategies, Practising Law Institute Course Handbook, Tax Notes, Tax Notes International, and Worldwide Tax Daily. He is also the co-author of Chapter 24 of Practical Guide to U.S. Transfer Pricing (2d ed. 2001), and a co-author of Georgia Limited Liability Company Forms and Practice Manual (2d ed. 1999, and annual supplements). He was co-chair of the 2006 Southeast Tax Institute, and has spoken at numerous seminars, including programs sponsored by the American Bar Association, the Institute of Continuing Legal Education in Georgia, Lorman Education Services, Data Trace Publishing Company, Tax Executives Institute (Atlanta Chapter), National Business Institute, Society of Louisiana CPAs, and Georgia Society of CPAs. He is Chair of the Taxation Committee of the American Bar Association, Section of Business Law; Vice Chair of the Partnerships and LLCs Committee of the State Bar of Georgia, Business Law Section; and a Fellow of the American Bar Foundation. He is also a member of the American Bar Association, Section on Taxation, Partnership Committee; the State Bar of Georgia, Taxation Law Section; the Atlanta Bar Association, Taxation Section; and the Atlanta Tax Forum. Mr. Immerman was listed in the 2004, 2005, and 2006 Georgia Super Lawyers. Mr. Immerman received his J.D. degree from the Yale Law School in 1982. In 1982-83, Andy was Law Clerk to The Honorable Judge Arlin M. Adams, U.S. Court of Appeals for the Third Circuit, Philadelphia, PA. He received advanced degrees from Princeton University (Ph.D., 1978; M.A., 1976) and the University of Minnesota (M.A., 1976), and an undergraduate degree from Carleton College (B.A., 1973, magna cum laude, Phi Beta Kappa). Andy is admitted to the State Bar of Georgia and the State Bar of Pennsylvania.
John Simon, Conference Co-Chair……
John is a Principal in KPMG’s Mergers & Acquisitions - Tax group, where he advises U.S. and multinational corporations on the tax implications of complex business transactions, including mergers and acquisitions, corporate reorganizations, spin-offs, joint ventures, and debt and equity investments. John is the Southeast area tax leader for KPMG’s Private Equity Group, which helps private investment funds manage tax and financial risks and create efficient investment returns. Additionally, he is the Southeast area leader for KPMG’s Bankruptcy Reorganization Group, which helps financially troubled companies evaluate the tax consequences of debt restructurings, business reorganizations, and bankruptcy proceedings.
John received an LL.M. (in Taxation) from New York University, where he was a Graduate Editor of the Tax Law Review, and a J.D. (with distinction) from Emory University, where he was an Associate Editor of the Emory Law Journal. Prior to joining KPMG, John practiced with the law firms of Alston & Bird and Jones, Day, Reavis & Pogue in Atlanta and New York. He also serves as an Adjunct Professor at the Emory University School of Law where he teaches corporate taxation and partnership taxation courses and is a guest lecturer in the Masters in Taxation program at the Georgia State University School of Accountancy.
As a frequent speaker to legal and accounting professionals, John has lectured on tax topics including mergers and acquisitions, partnership taxation, and tax planning for bankruptcy and workouts. He has also published numerous articles in publications such as The Journal of Taxation, The Journal of Corporate Taxation, Tax Notes, Practical Tax Strategies, The Journal of International Taxation, The Insurance Tax Review, Corporate Business Tax Monthly, and the Practicing Law Institute course book for the Tax Strategies for Corporate Acquisitions, Dispositions, Spin-Offs, Joint Ventures, Financings, Reorganizations & Restructurings seminar.
John is also a member of the Advisory Board of the Corporate Business Taxation Monthly (published by CCH), the co-chairman of the Tax Planning for Business Transactions seminar held annually in Atlanta, and the current Chair of the Corporate Tax Subcommittee of the Business Law Section of the American Bar Association.
Don Korb…
Former Chief Counsel for the Internal Revenue Service, Donald L. Korb joined Sullivan & Cromwell as a partner and the head of the Firm’s tax controversy practice on January 1, 2009. A practicing attorney for over 35 years, both in the public and private sectors, Mr. Korb, widely recognized as one of the country’s foremost tax lawyers, played a prominent role in increasing the effectiveness of the IRS Chief Counsel’s Office during his four-and-a-half year tenure there.
Prior to joining the IRS as Chief Counsel in 2004, Mr. Korb was a partner at Thompson Hine where he had once served as chairman of the tax group. He was primarily responsible for developing Thompson Hine’s tax controversy practice and also advised clients on major transactions and obtained rulings and other technical guidance from the IRS National Office.
In addition to almost 25 years of private practice experience, Mr. Korb also previously worked twice in the public sector, having spent more than two years as an Assistant to the Commissioner of Internal Revenue in the mid- 1980s (where he was the overall coordinator of the IRS's involvement in the legislative process that resulted in the enactment of the landmark Tax Reform Act of 1986) and, earlier in his career, four years as an Attorney Advisor in the IRS Chief Counsel’s Office.
As Chief Counsel, Mr. Korb was the chief law officer for the IRS, supervising approximately 1500 attorneys who were assigned to the IRS National Office and among the major operational divisions of the agency. He is best known for developing the litigation strategy that led to the stunning success by the Government in litigating tax shelter cases over the past four years.
Among the individual matters he was personally involved in while Chief Counsel was serving as the lead negotiator in resolving a landmark transfer pricing dispute. As part of the settlement, the taxpayer made the largest single payment ever made to the IRS to resolve a tax dispute.
During his many years of private practice experience, most of which was spent handling tax controversy matters, the clients Mr. Korb represented included a rock star, a symphony orchestra, some of the nation's largest financial institutions and brokerage firms, a major airline, a national retailer, several of the nation's largest real estate developers, large multinational manufacturing and construction corporations, tax exempt entities, and small closely held business entities in the fast food, distribution, automobile dealership and healthcare industries.
Among the matters Mr. Korb handled were a significant number of tax fraud and tax penalty cases, all of which resulted in either the elimination of the penalties or a significant reduction in the IRS's initial assessments.
Saba Ashraf…
Saba is a partner in the Atlanta office of Troutman Sanders LLP and is a member of the firm’s Federal Income Tax group. She concentrates her practice on the structuring and effecting of complex business transactions and tax planning for corporations, partnerships and other business entities. Saba also recently served as an Adjunct Professor of Law at University of Georgia School of Law, where she taught Corporate Tax, and also recently became a Fellow of the American Bar Foundation. Saba has authored or co-authored numerous articles in professional publications, including “Tax-Free Corporate Mergers Have Been Redefined for the LLC Era,” 30:3 Corporate Taxation 3 (May/June 2003); reprinted in PLI’s Tax Strategies for Corporate Acquisitions Dispositions, Spin-Offs, Joint Ventures, Financings, Reorganizations & Restructurings, 2003, 2004 and 2005 (with Andy Immerman); “Tax-Free Mergers for Disregarded Entities” 2:11 Mergers and Acquisitions 3 (March 2002) (with Andy Immerman); “New Tax Regulations Reveal the Consequences of ‘Checking the Box’” 8:1 Limited Liability Company Reporter 00-104 (January/February 2000) (with Andy Immerman); “Virtual Taxation: State Taxation of Internet and On-Line Sales,” 24 Florida State University Law Review 605 (1997); “States’ Net Fails to Ensnare Internet Vendors: Congressional Authorization Needed,” 12 State Tax Notes 999 (March 31, 1997). She is an active member of the New York State Bar Association’s Tax Section and was a principal drafter of the Section’s Report on the Proposed Change in the Definition of Control in Section 368(c), printed in Tax Notes (July 15, 1999). She also participates actively in the American Bar Association Business Law Section's Tax Committee, and is the Vice-Chair of the Committee. She regularly speaks on subjects in her practice areas at forums including the Atlanta Tax Forum, the Tax Executives Institute and the American Bar Association. Additionally, she is a member of the board of directors of GAPABA (Georgia Asian Pacific Bar Association), a member of IndusBar of Georgia, and a member of OPEN-DC (Organization of Pakistani Entrepreneurs of North America – DC Chapter). She received her B.S. from New York University’s Stern School of Business, J.D. from Hofstra University School of Law, and LL.M. in Taxation from New York University School of Law. Upon completing law school, she served as judicial clerk to The Honorable John C. Godbold on the Eleventh Circuit Court of Appeals.
Chuck Beaudrot…
Charles R. Beaudrot, Jr. is a senior partner in the firm’s Tax Practice. Mr. Beaudrot’s areas of practice include corporate and partnership tax, transactional tax planning, state and local tax planning and tax controversy work. Mr. Beaudrot is also a partner in the real estate capital markets group and advises clients with respect to tax issues involving real estate partnerships, real estate investment trusts and their related umbrella partnerships and tax efficient strategies for corporate owned real estate.
Mr. Beaudrot is a frequent speaker on tax, partnership and corporate topics for numerous sponsors such as the Georgia Society of Certified Public Accountants, the Institute for Continuing Legal Education in Georgia and the Georgia Real Estate Tax Conference. Mr. Beaudrot has been particularly active in the area of flow-through entities in Georgia, having participated in the drafting process for Georgia’s LLC and LLP legislation. Chambers USA, America’s Leading Business Lawyers: The Client’s Guide identifies him as among the nation’s leading tax attorneys, Georgia Trend magazine has named him one of the state’s “Legal Elite,” Atlanta magazine has listed him as one of Georgia’s “Super Lawyers” in 2004 - 2008, and Atlanta Business Chronicle has listed him in its "Who’s Who in Law." Mr. Beaudrot teaches Contract Drafting at Emory University Law School’s Center for Transactional Law and Practice program and serves on the Advisory Board for the Information Management Network’s Private & Non-Traded REIT Industry Symposium.
Mary Benton…
Mary concentrates her practice on controversy and litigation matters involving property, sales/use and income taxation. She also maintains a multistate transactional practice involving all tax types. She is a member of the firm’s economic incentives team, which assists clients in obtaining both negotiated and statutory incentives throughout Georgia and the Southeast.
Mary has represented clients in property tax disputes in numerous jurisdictions, appearing before boards of equalization and arbitration panels, litigating matters in both bench and jury trials and practicing before the appellate courts. She has also managed multistate controversy and litigation matters involving sales, income and transfer taxes. Mary has significant experience in representing clients in negotiations of voluntary disclosure agreements with state revenue departments. She has been involved in numerous multistate transactions as state tax counsel, negotiating tax provisions and planning for state tax minimization.
Philip Cook…
Philip Cook specializes in federal income taxation and federal tax controversies. Mr. Cook is a nationally prominent tax litigator with broad experience representing clients in major disputes with the Internal Revenue Service. During his career, he has litigated some of the most important domestic and cross-border tax issues faced by financial institutions. Mr. Cook has also played a prominent role in litigating tax cases of first impression for the telecommunications industry and a range of other industries. He represents multi-national taxpayers in a variety of tax matters including transfer pricing disputes. He also defends employers and fiduciaries against regulatory and class action claims brought under ERISA.
Mr. Cook led the Alston & Bird team that investigated Enron’s tax transactions as part of the Examiner’s investigation. He testified before the Senate Finance Committee about this investigation.
Philip successfully represented Delta Air Lines, Inc. as a special employee benefits counsel in its Chapter 11 proceeding with respect to the contested distress termination of the Delta Pilot's Retirement Plan. He has defended major ERISA class actions in jurisdictions throughout the country.
Jasper (Jack) Cummings…
Jack Cummings is a member of Alston & Bird’s Federal Income Tax and State and Local Tax Groups. He has extensive experience in corporate merger and reorganization tax issues as well as state and local tax litigation. He has served as associate chief counsel (corporate) of the Internal Revenue Service in Washington, D.C.
Jack was chair of the Corporate Tax Committee of the American Bar Association Tax Section for 1997-1998. He serves on the advisory board of the D.C. Bar, Tax Section, Corporate Tax Committee. In addition, Jack is a frequent speaker and author on taxation topics, including authoring “Cummings’ Corporate Tax Insights,” an RIA Checkpoint electronic newsletter, and “What Were They Thinking,” a column in Tax Notes. He and Robert Hanson authored A Selective Analysis of the 2004 JOBs Act, published by Warren Gorhan & Lamont in 2005. Jack is listed in Super Lawyers magazine.
Jack received his J.D. in 1971 from Yale Law School and his A.B., summa cum laude, in 1968 from Duke University. He received the LL.M. in Taxation from New York University in 1987.
Joe Depew…
Joe practices with the Tax Group, with an emphasis in tax litigation and controversy, corporate taxation and income tax. He focuses his practice on federal tax controversy issues, including IRS procedures, dispute resolution, collection and tax litigation matters. Joe has represented hundreds of clients in their Internal Revenue Service examinations. He has also represented numerous clients before the Administrative Appeals Division of the IRS and in litigation before the United States Tax Court, United States District Courts and the United States Court of Federal Claims.
Joe’s representations of clients in federal tax controversies spans a broad range of substantive and procedural issues, from recognition of losses, family limited partnerships (validity and discounts), reasonable compensation, timing of deductions, business purpose, economic substance, research and development credits, IRS imposed penalties and statute of limitations. Joe has also represented hundreds of taxpayers before the IRS who participated in tax advantaged transactions.
He has represented clients from numerous industries including logistics, insurance, manufacturing, energy, banking and finance, healthcare, transportation, timber, real estate, marketing, retail and automotive.
Prior to joining Sutherland, Joe served as the Southeast Area Director of Tax Controversy Services for a Big Four accounting firm. Joe is a frequent speaker on tax issues and has given presentations to the Tax Executives Institute and national industry groups and provided in-house courses for clients.
Joe Dowley…
Prior to entering private practice, Mr. Dowley served as Chief Counsel
of the Committee on Ways & Means, U.S. House of Representatives for two
and one-half years (1985-1987), during the development and enactment of
the Tax Reform Act of 1986. Among other projects, he was extensively
involved in the Gramm-Rudman-Hollings Deficit Reduction Act and the
House-passed Trade Act of 1986.
Mr. Dowley served as Assistant Chief Counsel at Ways and Means from 1981
to 1984. Among the bills he participated in during that period: Economic
Recovery Tax Act of 1981, Tax Equity and Fiscal Responsibility Act of
1982, Social Security Amendments of 1983, Caribbean Basin Economic
Recovery Act of 1983, Surface Transportation Act and the Deficit
Reduction Act of 1984. Both as the Assistant and as Chief Counsel, Mr.
Dowley worked closely with the House leadership and key Senate members
as well as the White House and Executive Branch agencies.
Joseph K. Dowley has advised corporations, associations and individuals
with regard to a variety of tax, health and trade related issues since
entering private practice in 1987. His efforts have included projects in
the areas of taxation of corporations and individuals, pension policy,
medicare reimbursement, health care reform and international trade. Much
of his work involves interaction with members of Congress, their policy
and enforcement staffs and Executive Branch agency personnel, as well as
drafting and interpreting legislation and advising clients on
Congressional procedures and strategy.
In recent years, Mr. Dowley has represented numerous clients and
affiliated coalitions with reference to complex issues before Congress
and the administrative agencies. Among others, his clients have included
AFLAC with regard to the U.S./Japan Agreements on Insurance and reform
of the Japanese insurance marketplace; the United States Telecom
Association in its efforts to modify the Internet Tax Freedom Act, in
connection with Treasury Department regulations involving the treatment
of internal use software, on regulations dealing with cost of removal
accounting issues, and on proposals to accelerate depreciation of
certain telecom equipment; a coalition of four major railroads with
regard to reform and modernization of the Railroad Retirement System;
rail tax infrastructure issues for Norfolk Southern Railway; Power
Ahead, a coalition of electricity transmission and generating companies
with regard to the Bush Administration's national energy policy
legislation; Qwest, with regard to the Broadband Tax Incentive Act;
Hutchison Whampoa, a Hong Kong-based conglomerate, with regard to
Congressional concerns over leased port facilities in the Panama Canal;
and efforts to acquire U.S. telecom assets; and the iAdvance coalition
in its efforts to organize as a corporation and obtain tax-exempt
status.
Previously, Mr. Dowley has represented, among others, Prudential with
regard to the taxation of mutual life insurance and government
regulation of managed care providers; Northwestern Memorial Hospital
with regard to securing capital reimbursement regulations and
legislation; a coalition of state hospital associations with regard to
the inclusion in legislation of a regional cost-of-doing-business
standard for purposes of federal capital reimbursement; the Tribune
Corporation in connection with the tax treatment of minority entry into
broadcast ownership; and, Westinghouse Corporation on legislative
changes in combined plan pension funding limitations and legislation
dealing with customs matters.
Mr. Dowley is a graduate of Georgetown University from which he received
a Bachelor of Arts in 1968 and Juris Doctor in 1976. He is married with
three children and lives in McLean, Virginia.
Joe Ferst…
Joe is the National Leader of the Partnership Solutions practice for Deloitte Tax LLP and is based in Atlanta. He has over 25 years of experience working with a variety of domestic and international partnerships, limited liability companies, and other joint ventures. Joe was one of the original strategists in the development of the Umbrella Partnership structure for Real Estate Investment Trusts. He was also one of the lead specialists in the development of the tax structures and positions for the GNMA REMIC program. Before joining Deloitte’s National Federal Tax Services group, Joe was the firm’s Southeast Region Practice Leader for Real Estate Tax Services. He is a co-author of three editions of the Real Estate Investment Trusts Handbook and is a contributing author to The Handbook of Commercial Mortgage-Backed Securities. Joe is a member of the BNA Tax Management Real Estate Advisory Board. Joe is a magna cum laude accounting graduate of Binghamton University in New York.
Lynn Fowler…
Lynn is a partner at Kilpatrick Stockton LLP who focuses his practice on corporate and business tax law. He specializes in helping clients develop and implement tax-efficient strategies for varied business formation, financing, operations, and disposition transactions. He has been the lead tax advisor on numerous taxable and tax-free M&A transactions as well as a variety of other strategic corporate transactions. Lynn received a B.S. from the University of Alabama, a J.D. from the University of Alabama School Of Law and an LL.M. degree (in Taxation) from New York University.
Scott Harty…
Scott’s practice focuses on domestic and international tax planning, including advising clients on taxable and tax-free mergers & acquisitions, joint ventures, internal corporate restructurings and inbound and outbound tax planning. Scott’s international tax experience encompasses multiple facets of foreign investments including foreign investment in U.S. real estate, Subpart F and foreign tax credit planning, and tax consequences of international acquisitions.
Scott also represents clients in domestic and international tax controversy matters ranging from Internal Revenue Service initiated examinations to taxpayer voluntary disclosures. Scott represents clients through the audit process and administrative appeals, including the negotiation and settlement of taxes and civil and criminal penalties.
Scott also speaks regularly on behalf of the American Bar Association’s International Tax Enforcement Subcommittee of the Committee on Civil and Criminal Tax Penalties.
Don Hensel…
Don is a partner in the tax department of King & Spalding LLP’s Atlanta Office. His practice concentrates on corporate, partnership, real estate, and international tax matters, with a particular emphasis on corporate mergers, acquisitions and restructuring transactions. Don received his J.D. degree, magna cum laude, in 1995 from the Harvard Law School, where he served as an Editor of the Harvard Law Review. After law school, Don clerked for the Honorable R. Lanier Anderson III of the U.S. Court of Appeals for the Eleventh Circuit. He is a member of the Corporate Tax Committee of the Tax Section of the American Bar Association.
Ken Jones…
Ken Jones is a Principal in KPMG's Tax Controversy Services practice. Ken has over 30 years of tax controversy experience and specializes in IRS procedural, controversy, and dispute resolution matters.
Before joining KPMG in 1991, Ken was the Large Case Program Manager for the IRS Office of Chief Counsel and was responsible for oversight, management, and coordination of that program as well as development of long-range compliance and litigation strategies for the IRS coordinated examination and industry specialization programs. For much of his government career, Ken was an IRS national office Special Trial Attorney, litigating numerous complex cases including Federal National Mortgage Association v. Commissioner (mortgage swap transactions), Estate of Hall v. Commissioner, 90 T.C. 312 ((1988) (valuation of Hallmark Cards stock), Edna Louise Dunn Trust v. Commissioner (tax consequences of AT&T divestiture), Hallmark Cards v. Commissioner (hybrid tax accounting method), Stanley Works v. Commissioner (valuation of scenic easement), and Julien v. Commissioner (commodity tax straddles). He also formerly served as the IRS National Tax Shelter Coordinator, a Technical Assistant to the Deputy Chief Counsel, and the Acting District Counsel (Foreign Operations).
Ken received a JD from the University of San Diego School of Law and a BS
from the University of Colorado. He is a frequent speaker on IRS practice,
procedure, controversy and tax litigation matters, and has appeared before
numerous industry groups, trade associations, and professional organizations,
including the Tax Executives Institute, the Financial Executives Institute, the
Investment Company Institute, the Federal Bar Association, the American Bar
Association, and the AICPA.
Ken can be reached at 703-286-8543 and kjones@kpmg.com.
Richard Litwin…
Richard C. Litwin is a solo practitioner, in Atlanta, devoting his practice to state and local tax controversies arising from sales and use tax, local county tax, corporate income tax, personal income tax, state residency and property tax matters. He has been selected as a 2008 Georgia Super Lawyer and was selected as one of Georgia Trend Magazine’s 2005 Legal Elite in Tax, Trusts & Estates. He served as Chairperson of the State Bar of Georgia Section of Taxation (2001-2002) and heads the Education Committee for the section. He has also served as Chairperson of the Atlanta Bar Association Taxation Section. He is a current member on the Georgia Department of Revenue Business Advisory Committee and has worked on projects with the Department of Revenue, in his role as a member of the Georgia Department of Revenue Liaison Committee and as a member of a special task force formed to address State consolidated return filing regulations.
Prior to forming his current firm, Mr. Litwin was a partner at an Atlanta law firm. He was also an Assistant Attorney General in the Tax Section of the Georgia Attorney General’s Office, where he represented the Georgia Department of Revenue in state superior, federal and U.S. Bankruptcy Court. Prior to working at the Georgia Attorney General’s Office, Mr. Litwin worked in the tax department at the Atlanta office of a Big Six accounting firm. Mr. Litwin speaks frequently on various tax topics, both at national conferences, state bar meetings and state accounting society seminars. Mr. Litwin has also published articles on various aspects of taxation, which have appeared in a variety of recognized publications. He graduated from the University of South Carolina, with a B.S. degree, cum laude, in Economics, and was inducted into Phi Beta Kappa, and he graduated from Emory Law School, where he was a member of the Moot Court Society.
Lee Lyman…
Lee is of counsel in the firm's Real Estate practice group. Prior to joining Thompson Hine, Lee was a partner with a firm that provides outsourced General Counsel services and general corporate and technology law advice. She also was formerly of counsel with Alston & Bird LLP.
Lee's practice focuses on structuring equity financing for the acquisition and sale of multi-state real estate projects; entity formation; restructurings and joint ventures and strategic alliances. She also has extensive experience in general corporate representation, commercial and specialized contracts and mergers and acquisition work
Mark Mesler…
Mark joined Ernst & Young in 2000 after a 12-year career representing the IRS. He was a trial attorney for IRS Chief Counsel where he represented the agency before the U.S. Tax and Bankruptcy Courts. He specialized in complex litigation and bankruptcy matters. Mark was also designated a Special Assistant United States Attorney.
Mark is the Southeast Area Director of E&Y’s Tax Controversy & Risk Management Services. He represents clients before the IRS. He also advises our clients on reportable transactions, penalty abatements, collection matters, and bankruptcy issues.
Mark received his law degree from Georgia State University where he concentrated in tax law and litigation. He is also a graduate of the National Institute of Trial Advocacy’s Tax Litigation course.
Mark is a frequent speaker at legal and accounting seminars on IRS practice, tax litigation, and bankruptcy tax issues. He is also the author of several papers on these subjects.
Carrie Parker…
Carrie has a broad range of experience in providing tax consulting advice to public and private companies in various industries, including transaction structuring considerations and due diligence investigations. She has participated in numerous M&A transactions, including acquisitions, dispositions, spin-offs, tax-free reorganizations and corporate restructurings, strategies for preservation and utilization of net operating losses and other tax attributes, and debt restructurings.
Carrie joined the firm in 1996, after receiving a Masters of Tax Accounting from the University of Alabama. Carrie received her Bachelor of Professional Accountancy from Mississippi State University in 1995. She is a licensed CPA in the state of Georgia and holds memberships in both the AICPA and Georgia Society of CPAs.
Carrie completed a secondment with the M&A Tax practice of the firm’s Washington National Tax Services office in 2005. She is a frequent speaker on M&A tax issues at the firm’s national training courses and in the Atlanta tax community.
Carrie serves as Secretary and Treasurer for The Healing Place Charity Championship. She also is a member of the Corporate Leadership Council at Fernbank Museum of Natural History. Carrie has volunteered in numerous capacities over the past several years with the East Lake Foundation, most recently as a HOSTS math mentor at Drew Charter School in the East Lake Community.
Tina Stark…
Tina L. Stark is a Professor in the Practice of Law and the Executive Director of Emory’s Center for Transactional Law and Practice. The Center was established in 2007 to focus on the business and legal aspects of transactional law and skills.
Professor Stark is an internationally recognized authority on contract drafting and the teaching of transactional skills and has written extensively on these topics. She is the author of the textbook Drafting Contracts: How and Why Lawyers Do What They Do and the editor-in-chief and co-author of Negotiating and Drafting Contract Boilerplate. A noted educator of both lawyers and law students, Professor Stark has been teaching transactional law and skills since 1989.
Professor Stark speaks frequently on drafting, transactional skills, the intersection of law and business, and boilerplate in contracts. She has lectured at programs in the United States, Canada, England, Italy, China, and Poland. In addition, she has served as a consultant to an English law school in connection with its creation of a transactional and business curriculum.
After graduating from Brown University with honors, Professor Stark was a commercial banker at Irving Trust Company. She then attended New York University School of Law where she was a contributing editor to the Journal of International Law & Politics. Professor Stark clerked for Judge Jacob D. Fuchsberg of the New York State Court of Appeals from 1980 to 1982.
Following her clerkship, Professor Stark was an associate at Barrett Smith Schapiro Simon & Armstrong. She was a corporate partner at Chadbourne & Parke LLP from 1988 until 1993. While there, she had a broad-based transactional practice, including acquisitions, dispositions, recapitalizations, and financings. In addition, she developed and implemented the firm’s corporate training program.
Professor Stark was appointed as a member of the Professional Education Project by Chief Judge Judith S. Kaye of the New York State Court of Appeals. The PEJ studied the legal education curriculum in New York State and recommended, among other things, that continuing legal education become mandatory in New York. Currently, Professor Stark is co-chair of the Business Law Education Committee of the Business Law Section of the American Bar Association.
Before joining the Emory faculty, Professor Stark was an Adjunct Professor at Fordham Law School for fourteen years. She taught courses on drafting, transactional skills, and business. In addition, through her business, she taught continuing legal education courses at the major law firms in North America, Europe, and Asia.
Matthew Stevens…
Matthew Stevens, a partner in the International Tax Group, advises clients on a wide range of tax-related issues. He handles planning and controversy matters regarding the U.S. federal income tax consequences of transactions, specializing in the design, structuring and implementation of domestic and international financial transactions, including structures involving preferred stock financing transactions, swaps, options, all types of debt instruments (including hybrid debt and bond-hedge transactions), forward contracts, and Tier One capital financing transactions. Matthew also has substantial experience in international tax issues involving foreign tax credits, Subpart F and PFICs, withholding taxes, dual consolidated losses, hybrid and reverse hybrid entities and tax treaties.
From 2002 to 2004, Matthew served as special counsel to the Chief Counsel for the Internal Revenue Service. He advised the Chief Counsel regarding published guidance, including regulations, revenue rulings and notices involving contingent convertible debt instruments, prepaid forward contracts, debt-forward contract units, partnership options, and notional principal contracts.
Matthew serves as Chair of the Practising Law Institute program “Taxation of Financial Products and Transactions” which is held semi-annually in both New York City and San Francisco. He co-teaches the Georgetown University Law Center class entitled United States Taxation of International Income – II. He has published a number of articles dealing with international aspects of U.S. income tax and with the taxation of financial products and transactions.
Matthew received his J.D. from Harvard University and his B.A. from the University of Kansas.
Gerald V. Thomas, II...
Gerald Thomas is a partner in the firm’s Federal Income Tax group. Mr. Thomas concentrates his practice on the structuring and effecting of complex business transactions, with a particular emphasis on mergers and acquisitions, reorganizations, joint ventures, private equity funds, REITs, tenancy-in-common (TIC) offerings, and corporate and partnership tax planning. Mr. Thomas is a member of Tenant-In-Common Association (TICA), the National Association of Real Estate Investment Trusts, the American Bar Association, Section on Taxation (including the Corporate and Partnership Tax Committees), and the Atlanta Bar Association, Taxation Section.
Mr. Thomas is a member of the Firm’s Associates Committee and Diversity Committee and is active in the Firm’s mentoring and recruiting programs.
Mr. Thomas is a frequent lecturer on the topics of corporate tax, partnership tax, and tax issues related to REITs. He has spoken to numerous professional organizations, including the American Bar Association’s Tax Section, Lorman Education Services, Corporate Tax Congress, IMN's Third Annual East Coast Non-Traded Private REIT Industry Symposium and Tax Executives Institute, having given speeches in cities across the country and in London, England.
Mr. Thomas received his B.S. in accounting and international business, magna cum laude, in 1994 from New York University’s Stern School of Business. He received his J.D. degree in 1997 and his LL.M. degree in Taxation in 1998 from New York University School of Law, where he was a graduate editor on the Tax Law Review. Mr. Thomas is admitted to practice in New York, Georgia, and Illinois.
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