Taxation of Financial Instruments Conference

Mr. Rebhun is a Partner at PricewaterhouseCoopers, based in New York City. He is PwC's U.S. Asset & Wealth Management tax leader. He holds a Juris Doctor from Yeshiva University's Benjamin N. Cardozo School of Law and a Bachelor of Science in Business Administration with a concentration in Accounting from Monmouth University.

Andre Brijadadder is a Director at PwC US Tax LLP. He has more than 12 years of professional experience. Andre holds significant experience in providing state tax compliance and consulting services to a variety of asset management clients. He provides a wide range of services to clients, including tax structuring, tax due diligence, tax compliance, and other general tax consulting services. He focuses on coordinating the year-round compliance process, which includes the allocation and apportionment of income, investor reporting, and the tax return process. Andre has experience in streamlining the state tax compliance process and managing real-time data for state tax planning, modeling, and forecasting. He also Has served as a subject matter professional in the state and local tax, and federal wealth and asset management tax industries for both hedge fund and private equity client. Andre graduated from Fox School of Business: Temple University with a Bachelor of Arts in Accounting and Finance, and from the Zicklin School of Business: Baruch College with a Master’s in Taxation.

Lauren Weronick is a partner with over 15 years of experience in international tax consulting and compliance. She is based out of the firm’s Melville office. Lauren is experienced in providing international tax compliance and consulting services to multi-national large middle-market businesses and high-net worth individuals. She specializes in U.S. income inclusion calculations and modeling and advises on international compliance requirements. She is also a leader for ITS initiatives relating to FATCA and pre-immigration planning, among others. Lauren has extensive expertise leading education within the international tax practice for her team and the firm, and is involved in presenting internal and external tax education opportunities. She continues to create and implement international tax calculations and models. Previously, Lauren was an international tax managing director at a large public accounting firm in New York.

Brian Waller is a manager with over 7 years of experience in international tax consulting and compliance. He is based out of the firm’s Philadelphia office. Brian’s experience is in providing international tax compliance and consulting services to multi-national large middle-market businesses and high-net worth individuals. He specializes in U.S. income inclusion calculations, foreign tax credit calculations, and cross-border tax structuring. Brian has led education within the international tax practice for his team and the firm, and is involved in presenting internal and external tax education opportunities.. Previously, Brian was a senior associate with a large public accounting firm.

Jason Schwartz is a tax partner and co-heads the firm's Digital Assets and Blockchain Practice. He specializes in tax issues relating to financial products, securitizations, funds, treaties, lending, and digital assets. Jason has been recognized as an "Up and Coming" lawyer in Tax by Chambers USA and as a "Next Generation Partner" by Legal 500 US in Tax: Financial Products each year from 2017 to 2022. Jason is the author of numerous tax articles and a Bloomberg BNA Tax Management Portfolio regarding the taxation of CLOs. He is frequently asked to speak on a wide range of topics related to tax and digital assets, including at conferences hosted by the NYSBA and the ABA and at Korea Blockchain Week. Jason is committed to pro bono work and community service. He oversees Fried Frank’s 501Foundry, a pro bono program that incorporates and obtains tax-exempt status for non-profit organizations. Prior to joining Fried Frank, Jason was a partner at a large international law firm.

Erin Stidham is a tax associate at Fried, Frank, Harris, Shriver & Jacobson LLP. Her practice focuses on financial products, digital assets, and funds. She holds a J.D. From Rutgers Law School and a B.S. in History and Religion from Duke University. Admitted to Practice New York

Iqbal is a director in FORVIS’ New York City office. He has more than 12 years of experience providing tax preparation and consulting services to a variety of clients. He specializes in asset management and has been an advisor to many kinds of alternative investment funds, including, private equity funds, hedge funds, and fund of funds. His responsibilities involve consulting clients on tax planning strategies, fund structuring, and tax implications of securities transactions. Iqbal is apart of FORVIS’ asset management training committee. He also is a member of the American Institute of CPAs and the New Jersey Society of CPAs. Iqbal is a graduate of the University of Madras, Chennai, India, with a M.B.A. degree in finance and from Fair Leigh Dickinson University, Morris County, New Jersey, with a M.S. degree in taxation.

Andie Kramer is widely regarded as one of the foremost authorities on the regulatory, tax, commercial, and governance matters that arise for individuals and businesses in trading environments. Andie represents multinational corporations, financial service firms, exchanges and trading platforms, hedge funds, energy companies, insurance companies, family offices, and businesses in all stages of their life-cycle. These clients are typically dealing with securities, commodities, derivatives, digital assets, energy (production and distribution), renewables, ESG (environmental, social, and governance) matters, nontraditional assets, and emerging asset classes of all types. Andie is widely respected for her multidisciplinary knowledge concerning the legal issues arising in market and all types of products that trade in them and the participants which use them. She is a trusted advisor and sought-after problem solver who provides the comprehensive advice that clients need to navigate the complexities that arise from the intersection of multiple asset classes, commercial realities, and ESG matters. Before founding ASKramer Law, Andie spent 30 years at McDermott Will & Emery, where she established and led the Financial Products, Trading, and Derivatives Group. She is the coauthor of Financial Products: Taxation, Regulation, and Design, the two-volume authoritative treatise widely used by market participants, advisors, and regulators. She has been ranked since 2009 by Chambers USA and Legal 500, the leading independent legal ranking firms. Andie was also named by the National Law Journal as one of the “50 Most Influential Women Lawyers in America” for “demonstrated power to change the legal landscape, shape public affairs, launch industries, and do big things.” The National Law Review recognized Andie as a “Go To Thought Leader” in 2022 (Crypto/Blockchain), and in 2020 (Finance Law [Virtual Currencies]); and JD Supra readers voted her a “Top Author” in cryptocurrency taxation in 2021 (Readers Choice Awards). Additionally, she is qualified by the Financial Industry Regulatory Authority (FINRA) as a tax expert witness. Andie was selected by the Chicago Daily Law Bulletin and the Chicago Lawyer as an “Inaugural Women in Law Honoree”; by Crain’s Custom Media for the “Chicago Notable Women Lawyers” list; named by Women in Law Business Guide as one of the leading tax practitioners; and honored as one of the “Most Influential Women Lawyers in Chicago” by Crain’s. Andie is also known for her longstanding work addressing and dismantling workplace gender discrimination. She served as a member of the Diversity & Inclusion Advisory Board for the Illinois Supreme Court Commission on Professionalism and was coauthor of What You Need to Know about Negotiating Compensation, a 2013 guide published by the American Bar Association. With her husband, Al Harris, she has written two award-winning books, Breaking Through Bias: Communication Techniques for Women to Succeed at Work and It’s Not You, It’s the Workplace: Women’s Conflict at Work and the Bias That Built It. Their latest book, Beyond Bias: The PATH to End Gender Inequality at Work, was published in May 2023. Andie is a Phi Beta Kappa, summa cum laude graduate of the University of Illinois, where she received the Bronze Tablet Award, and she is a cum laude graduate of Northwestern Pritzker School of Law where she served as an adjunct professor for more than 20 years. She is an editor of and contributor to Energy and Environmental Project Finance Law and Taxation (2010) and Energy and Environmental Trading (2008). Generously philanthropic and civically engaged, Andie is the recipient of the “Unsung Heroine Award” from the Cook County Board of Commissioners and the “National Public Service Award” from the American Bar Association for her public service and pro bono activities. She founded and serves on the boards of a number of nonprofits and professional associations. She is a founding board member and chair of TWTC (formerly The Women’s Treatment Center) that provides housing and healthcare support and assistance to Chicago’s most vulnerable residents. Andie is a co-founder and the chair of WLMA (the Women’s Leadership and Mentoring Alliance), and she serves on the board of the Design Museum of Chicago.

Caitlin Tharp's practice focuses on federal tax controversy and litigation matters, with experience in all stages of a tax dispute. Caitlin has litigated cases before the Tax Court, Court of Federal Claims, the US Court of Appeals for the District of Columbia Circuit, and federal district courts across the country. Her experience includes examining witnesses at trial and at deposition, as well as authoring scores of motions and briefs. Caitlin has advised clients in IRS Exam and advocated on behalf of clients at IRS Appeals. The subject areas of these disputes include challenges under the Administrative Procedure Act, excise taxes, alternative energy tax credits, captive insurance, penalty abatement requests, and valuation questions. Caitlin has also advised clients on issues regarding the employee retention credit and qualified opportunity zones. Caitlin is a frequent speaker and writer on the intersection of tax and new technologies, including the use of artificial intelligence and the application of existing tax rules to the metaverse.

Travis Thompson is an associate criminal tax attorney in the Tax, Criminal Defense, and Blockchain and Digital Assets practice groups. Mr. Thompson handles all aspects of taxpayer controversies against the Internal Revenue Service, the California Franchise Tax Board, the California Department of Tax and Fee Administration, and the California State Board of Equalization, including audits, administrative appeals, and both routine and complex collection matters. Mr. Thompson represents clients in litigation in the U.S. Tax Court, U.S. District Courts, U.S. Courts of Appeals, and California state courts. He has drafted petitions for Writ of Certiorari to the United States Supreme Court and represents clients in various white collar criminal defense cases. Mr. Thompson advises clients on the tax consequences of Bitcoin, cryptocurrency, or other blockchain-related technology transactions. He also consults with clients on how artificial intelligence impacts modern business strategy and domestic and international tax compliance. Additionally, Mr. Thompson advises clients in the cannabis industry on the complex federal, state, and local tax and regulatory framework burdening the industry. Prior to joining the firm, he worked in two prominent boutique tax law firms in the San Francisco Bay Area. Before law school, he worked in business development for multiple Fortune 500 companies in the automotive and technology industries. Mr. Thompson earned his undergraduate degree in philosophy from the University of California, Berkeley. In 2015, he graduated from Golden Gate University School of Law where he completed his law degree and his LL.M. in Taxation in three years. While in law school, he received the Rensch Scholarship for Business Leadership, was a Best Brief Award recipient in the ABA National Moot Court Competition, and received the Witkin Award for Excellence in Appellate Advocacy.

Melissa Wiley has over 20 years of experience in tax controversy and litigation on a wide range of civil tax matters at the federal and state level. She represents clients at all levels of administrative controversy with the IRS, including audits and cases before the IRS Office of Appeals, and has significant experience handling penalty and international information reporting matters. Her experience includes litigation in the U.S. Tax Court, Court of Federal Claims, and various federal district courts, representing clients facing government and third-party subpoenas and investigations. She also counsels on voluntary disclosures of prior tax noncompliance. An actuary by training, Melissa has practiced at a Big Four accounting firm, first as an Assistant General Counsel and later as a Senior Manager in the firm’s National Tax department; as well as in the Tax practice of an AmLaw 20 global law firm. A respected authority on tax controversy topics, Melissa frequently presents on IRS filing requirements, penalties, and enforcement, as well as on ethics and the Corporate Transparency Act. She is active in numerous professional organizations such as the AICPA and the ABA Tax Section, where she previously served as Vice Chair for Committee Operations and is currently a member of the Nominating and Appointments to the Tax Court Committees. She is also the chair of the DC Bar Tax Audits & Litigation Committee and the Regent for the Federal Circuit for the American College of Tax Counsel. Melissa’s pro bono work includes assisting local children and caretakers through the Children’s Law Center, where she served on the board for a decade and has provided pro bono services in custody and abuse/neglect matters for more than 15 years.

Miri Forster is a Principal and Co-Leader of the Tax Controversy Practice, specializing in providing tax dispute resolution services to public and private corporations, partnerships and high net worth individuals on a wide range of technical and procedural issues. She has over 20 years of IRS practice, procedure, and tax controversy experience. Miri represents businesses and individuals before the IRS Examination and Appeals Divisions on complex domestic and international tax issues. She also obtains private letter rulings from the IRS National Office, including 9100 relief requests for missed elections. Miri assists clients with voluntary disclosures of inadvertent income, international information return, withholding, and payroll tax compliance errors, obtains penalty abatements and refunds, resolves IRS account issues, and advises on a broad range of IRS practice, procedure and dispute resolution matters. Prior to joining the firm, Miri was a Tax Controversy Principal at a Big 4 firm. Miri also previously served as an Attorney-Advisor at the United States Tax Court in Washington, D.C., and is an attorney licensed in the states of New York and New Jersey as well as Washington, D.C. Miri is a frequent speaker on IRS enforcement trends, the centralized partnership audit regime and its impact on pass-through entities and investors, voluntary disclosures of inadvertent tax compliance matters and related penalties, and other IRS practice, procedure and dispute resolution topics.

Mark H. Leeds is a Tax Transactions & Planning partner in Mayer Brown's New York office. His practice is focused on the tax consequences of a variety of capital markets, hedge fund, banking and insurance products and strategies, including over-the-counter derivative transactions, swaps, tax-exempt derivatives and strategies for efficient utilization of tax attributes—such as net operating losses. Mark regularly works on innovative insurance products and structures. Mark has extensive experience in working with businesses and individuals seeking to set up operations and relocating to Puerto Rico. Mark advises on the tax aspects of capital markets, structured finance, derivatives, financial products and insurance transactions and has extensive experience working with both buyers and sellers to develop and structure complex derivatives, including litigation finance transactions. A significant portion of his work involves the taxation of financial products and trading strategies engaged in by banks and other financial market participants. He also advises on hedge fund and other investment vehicle formation matters. Mark does extensive work with digital assets, including cryptocurrencies, non-fungible tokens and blockchain transactions. Mark is a former managing director and senior tax counselor with Deutsche Bank in New York. He also served as the general counsel of a credit derivative company and was a partner at Deloitte & Touche, where he led the capital markets tax practice. Mark is a frequent writer and speaker on tax topics affecting capital markets and digital assets.

Edward Weissman is a Tax Senior Manager in the Financial Services Group in the New York City office of BDO USA. Edward has over nine years of experience providing tax and business advisory services all with BDO’s financial services practice. His focus has been primarily with domestic and offshore hedge funds, investment partnerships, and management companies. In addition, Edward regularly assists clients with regulatory filings with the IRS, state and local authorities.

Brandon Blitzer, CPA, graduated from Long Island University, CW Post in 2010 with a Bachelor of Science in Accounting and Masters in Business Administration. In 2011 Brandon joined Marcum as a staff in the general tax department and has moved up into his current position of Senior Tax Manager in the Alternative Investment Group. Mr. Blitzer provides tax services to a wide range of clients within the alternative investment industry including hedge funds, private equity funds, management companies, broker dealers and fund of funds. In addition to working with the entities within the industry, he works with high net worth individuals who are managers of their own fund or former fund managers. Brandon is a member of American Institute of Certified Public Accountants and New York State Society of CPAs. Brandon’s choice of joining the Alternative Investment Group stems from a long term interest in Wall Street and trading in securities.

Irina Kimelfeld is a Tax Partner and a member of the Financial Services Group. With over 20 years of experience, Irina provides tax planning and compliance services to private equity funds, hedge funds, funds of funds, investment advisors, and other financial services companies. She focuses on advising clients on tax implications of fund structuring, investment structuring, management company operations, and tax treatment of various types of securities transactions. Prior to joining the firm, Irina was Managing Director at a credit investment firm, where she oversaw all tax related matters for the firm and its managed funds as well as the firm’s deferred compensation plan. She began her career at a Big 4 accounting firm where she provided tax planning and compliance services to asset management clients. Irina is an Adjunct Professor at Fordham University Gabelli School of Business, where she designed and lectures a graduate level course on taxation of financial products and transactions.