International Taxation Conference Webcast

Grace provides her clients with a wide range of US tax compliance and advisory services related to high-net worth individuals with cross-border concerns. Grace has particular experience in dealing with US tax issues concerning U.S. beneficiaries of foreign trusts and estates and compliance for closely-held family business structures. Prior to joining REM in February 2020, Grace was with Frank Hirth LLC, the New York office of the London-headquartered firm providing dual US and UK tax and compliance services, for nine years.

Paul Dailey, a partner and leader of the firm's federal tax policy team, brings more than 35 years of experience to his engagements as an authority on international tax matters for corporate and individual clients. Paul specializes in tax planning, structuring, consulting, and compliance issues for large foreign-owned corporations. He has significant and extensive experience in structuring inbound entrance into the U.S. tax regime, as well as outbound IP migration. EXPERIENCE From an international standpoint, Paul’s scope includes structuring offshore tax transactions, expatriate planning, entry/exit strategies, and offshore holding company structures. Additionally, he has developed and implemented inbound/outbound tax structures utilizing tax-favored holding companies, blocker entities, and transparent entities, including check- the-box elections. His expertise also includes controlled foreign corporations, passive foreign investment companies, IC-DISC structuring and implementation, transfer pricing, earnings stripping, foreign tax credits, treaties, and withholding. In the area of business tax, Paul is proficient in handling matters for domestic corporations, closely held corporations, franchisors, and private equity funds. AFFILIATIONS Member, New York State Society of Certified Public Accountant (NYSSCPA) Co-Chair, Foundation for Accounting Education’s Small Business Taxation Conference and Chair of the International Taxation Committee, New York State Society of CPAs (NYSSCPA) Member, American Institute of Certified Public Accountants (AICPA) Member, International Franchise Association (IFA)

Mitchell Sorkin, CPA, MBA, PFS, CEA is a Tax Partner with over 45 years of expertise in wealth and business management, as well as personal financial, corporate, individual, trust, estate, partnership, investment, and international planning. His clients include high net worth individuals, import and export businesses, personal service firms, distributors, and manufacturers. Prior to joining the firm, Mitchell was a Tax Partner at Raich Ende Malter & Co. LLP (REM), a leading full-service accounting and auditing firm providing a wide variety of accounting, tax, and business advisory services to organizations of all sizes, emerging businesses, and high net worth individuals. As an active member of the American Institute of Certified Public Accountants (AICPA), Mitchell holds a Certificate in Educational Achievement in Business Evaluations, as well as the AICPA Personal Financial Specialist designation. He is the former Chair of the New York State Society of Certified Public Accountants (NYSSCPA) International Taxation Committee. Mitchell is a frequent writer and lecturer on domestic and international taxation, business management, and wealth management topics.

Tim Larson has nearly 30 years of professional experience, including public accounting and private industry, and is currently based in his firm’s New York City office. He formerly held senior partner leadership positions at a Big 4 firm as well as other national and regional accounting firms. His extensive and diverse set of skills makes him uniquely adept at understanding the cross-border issues facing complex privately-owned businesses, multinational entities and individuals and providing them with strategic international tax advisory services and creative solutions. Tim specializes in advising multinational corporations on the U.S. tax aspects of cross-border direct and indirect taxation, repatriation and foreign tax credit planning, as well restructuring, acquisition & disposition planning, intellectual property migration, supply chain planning, and transfer pricing. In addition, he assists individuals with inbound tax structuring of investments in U.S. real property and pre-immigration planning, as well as with cross-border tax issues and filings for FINCEN 114 compliance. He is a Certified Public Accountant in the states of New York, New Jersey, and Texas and is also an adjunct tax and financial accounting professor.

Chaim Kofinas has over 40 years experience in accounting and taxation specializing in state and local taxation issues. He has spent the last 35 years advising clients on income tax and sales tax matters as well as representing clients before the IRS and State on exams and on appeals. Chaim has also advised clients in the construction field as well as Not-For-Profit clients. Chaim is a frequent lecturer for this and other conference in the past and has written articles on a variety of tax issues. At Goldstein Lieberman & CO LLC Chaim is a Tax Director who advises high net worth clients as well a working small business clients regarding U. S. and state and local taxation. Chaim also works with the tax group to set tax policy for the firm. Prior to joining Goldstein Lieberman & CO LLC Chaim was a senior tax manager at WithumSmith+Brown PC, and later at Beacon CPA PC, where he advised multistate businesses and individual clients on federal and state and local tax matters including representation before the IRS and other taxing agencies. Chaim has also worked with foreign individual sand businesses making inbound investments into the US . Chaim is currently the immediate Past Chair of the New York State Society CPA New York, Multistate & Local Taxation Committee as well as being active with the New York State Society CPA International Committee. During his tenure as Chair Chaim initiated a dialogue with the NYS Commissioners office and lead a delegation to meet the Commissioner in Albany

As a Co-Chair of the International Taxation & Wealth Planning Practice, Christopher provides wealth management and international tax planning advice to high-net-worth clients, funds and businesses. In recognition of his dedication to developing cutting-edge tax strategies for his clients, Christopher has been named as one of the leading tax attorneys in Florida by Chambers USA. In his practice, he handles a full range of international taxation and wealth issues, including: Foreign pension planning and compliance for individuals and active companies with U.S. employees Domestic and international tax planning for partnerships (e.g., private equity and real estate funds) Domestic and international income tax planning, including Subpart F, GILTI and FDII planning, for closely-held corporations Advice regarding U.S. income and estate tax treaties Tax planning for non-resident individuals, including wealth and estate planning (e.g., trust planning), FIRPTA withholding and pre-immigration tax planning Formation of foreign grantor trusts by foreign settlors (particularly redomiciling Panama Foundations to the United States) Tax compliance and disclosure matters (e.g., submissions to the Streamlined Offshore Procedures, Delinquent FBAR Procedures, Delinquent International Information Return Procedures, etc.) Tax planning for non-resident executives of U.S. companies (e.g., how to minimize exposure to U.S. estate tax regarding their ownership of company stock and stock options as well as other U.S. situs assets such as U.S. portfolios and U.S. real estate) Cross-border employment tax planning for publicly traded corporations.

Ms. Gillespie’s law practice focuses on international tax matters and income and estate tax planning for high net worth, non-resident individuals, non-U.S. individuals working in the U.S. and U.S. citizens working abroad. She has considerable experience representing clients making voluntary disclosures to the IRS. Before establishing her legal practice, she worked for Arthur Andersen, the Goldman Sachs Family Office and Skadden, Arps, Slate, Meagher and Flom. She is Chair of the Suffolk County Bar Association Animal Law Committee; she is past Chair of the New York State Society of CPA’s Digital Asset Committee as well as their International Taxation Committee. She is a member of the AICPA, the American Bar Association, and the New York State, New York City and Suffolk County Bar Associations. She is admitted to practice in New York and the Law Society of England and Wales. She is a CPA; she has received her Masters of Science degree in Taxation and her Juris Doctor and is also a certified public accountant. Ms. Gillespie has served on the NYSSCPA’s Tax Division Oversight Committee and its Virtual Currency Task Force. She is a TEP (Trust and Estate Practitioner) under the auspices of the Society of Trust and Estate Practitioners. She served as an adjunct Professor at Touro Law School. Ms. Gillespie lectures frequently and has authored a number of articles on topics including but not limited to, international taxation, virtual currency and digital assets. She is the author of the “Foreign Bank Account Reporting Compliance Guide (with FATCA coverage)” published by CCH.

Ralf Ruedenburg is a Partner at PKF O’Connor Davies with more than 20 years of professional experience having practiced in both the U.S. and Germany. His specialized practice area is international taxation. Ralf has many years of experience in providing accounting and assurance services in conformity with U.S. GAAP, German GAAP, and IFRS. For over 10 years, Ralf worked with a “Big 4” international accounting firm on its professional staff and then as an audit senior manager, developing audit programs focusing on internal controls. Over the years, Ralf developed tax expertise working with parent companies to incorporate U.S. subsidiaries or restructure existing U.S. operations with the objective of lowering the tax burden. He has also worked on transfer pricing, tax treaty, sales and use tax, and U.S. tax compliance issues. In addition, he prepares individual, corporate, gift and estate, and federal and state tax returns. Ralf is a native German-speaker and is fluent in

Chris Migliaccio is a Principal in the international tax practice. Prior to joining PKF O’Connor Davies, Chris worked at two “Big 4” accounting firms in their international tax practices. He has more than 10 years of experience providing consultation on international tax matters, including cross-border transactions, business restructurings and complex compliance issues for multinational corporations, partnerships, private equity funds and high-net-worth individuals. In addition, Chris regularly leads due diligence and structuring for M&A transactions. He also is our Employee Retention Credit (ERC) leader, having assisted clients with receiving over $25 million in credits. As one of the Firm’s most prolific thought leaders, Chris has written extensively on a wide range of tax topics. He is a co-author of treatise-length discussions on the Base Erosion and Anti-Abuse Tax (BEAT), Passive Foreign Investment Companies (PFICs) and Inversions. He has authored articles for publications such as Law360 and Checkpoint News and has been quoted in Newsday and Bloomberg News. Chris is also a frequent speaker at industry and tax-related conferences.