Miri Abrams Forster Principal and Tax Controversy Co-Leader
Eisner Advisory Group
Miri Forster is a Partner and National 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.
Delina Bakalli is a Tax Managing Director in the Financial Services Group in the New York City office of BDO USA, LLP. Delina has over fourteen years of experience providing tax compliance, structuring and planning services, including 10 years of experience with BDO’s financial services practice. She has worked on over 60 investment funds in the past 10 years, ranging from startup funds with $5 million AUM to multi-billion-dollar funds. Strategies have included long-short equity, loan origination, debt funds, foreign currency contracts, complex derivatives and other alternative assets, private equity, venture capital, management companies, and fund of funds. She also has worked on a number of other financial services entities such as broker-dealers and registered investment advisors.
Peter Berard
Senior Director/National U.S. Employment Tax Practice Leader
Howard Berman Managing Director, Tax Controversy Services
Deloitte Tax
As a tax controversy specialist, Howard represents clients before the Internal Revenue Service (IRS) at all levels of tax controversies—including examinations and appeals—and utilizes a wide range of dispute resolution mechanisms and processes. He regularly interacts with IRS specialists to assist clients in navigating controversies and obtaining closing agreements and advises clients on a wide range of procedural issues, such as statute of limitations, refund claims, and penalty issues. He also has significant experience with inbound and outbound transfer pricing examinations. In addition to his national role, he is responsible for Deloitte Tax’s Northeast Tax Controversy practice.
Prior to entering client service, Howard was a senior trial attorney for the US Department of the Treasury and represented the IRS before the US Tax Court.
Howard is a frequent speaker and contributor for Deloitte. He is a planning committee member for New York University’s annual Tax Controversy Forum. He speaks on tax controversy matters at events sponsored by Institute of International Bankers, Organization for International Investment, regional and local Tax Executive Institute events, and New York University Tax Controversy Forum.
Howard holds a BA from Brandeis University and a JD from the State University of New York at Buffalo.
Richard A. Cagnetta is a Principal and has been with the firm since February of 2014. He focuses on providing tax advisory and compliance services to the firm’s asset management clients including funds, management companies, and principal individual owners. Richard has significant experience in the areas of partnership and individual taxation, corporate taxation, and the taxation of financial products, covering domestic, international, and State and Local issues. Prior to joining the firm, he spent significant time at a Big Four accounting firm and two prominent hedge funds.
He is a member of the Managed Funds Association, Wall Street Tax Association, and the New Jersey State Society of Certified Public Accountants and currently serves as Chair of the New York State Society of Certified Public Accountants' Taxation of Financial Products and Transactions Committee.
Richard received a Bachelor of Science in Finance from the State University of New York at Albany. He also received a Master of Science in Taxation and a Master of Business Administration in Professional Accounting from Fordham University’s Graduate School of Business Administration. He is a licensed CPA in New York.
Maury Cartine is a Managing Director at Prospect providing tax and related services to the Prospect team.
Prior to joining Prospect, Maury served as the Partner-in-Charge of the NYC Tax Department and the Partner-in-Charge of the Alternative Investment Group Tax Department at Marcum, LLP. Before joining Marcum, he was the Principal-in-Charge of the worldwide tax practice at Rothstein, Kass & Company, PC and a member of the executive board. Maury started his career at an Internal Revenue Agent advancing to the role of classroom instructor and reviewer of income tax audits. He completed his military service as an Officer in the United States Army Reserve and the New Jersey Army National Guard.
Maury received a BS degree from Seton Hall University and a JD degree from Seton Hall University School of Law. He is a Certified Public accountant in New Jersey and New York. Maury is a member of the New Jersey Bar
Jill E. Darrow is head of Katten's New York Transactional Tax Planning practice. She concentrates her practice in tax planning and tax law with a focus on partnership transactions, financial services, hedge funds, commodities funds and real estate. Jill advises clients on all aspects of tax with a concentration in the areas of financial services and real estate. Her practice covers the tax aspects of transactions involving partnerships, limited liability companies, carried interests, subchapter S corporations, regulated investment companies (mutual funds), recording and publishing ventures, real estate investment trusts (REITs), publicly traded partnerships, real estate limited partnerships, partnership tender offers, partnership roll-ups, securities and commodities funds (domestic and offshore), hedge funds and passive foreign investment companies.
She is a frequent lecturer and author on topics including taxation of real estate transactions, hedge funds and securities, and regularly speaks before industry groups, including the Foundation Research Associates and the Practising Law Institute.
Mark Fichtenbaum is a registered representative with Twenty-First Securities. He has written numerous articles and is a frequent speaker at conferences regarding the tax treatment afforded financial products.
Mark has been with 21st for 20 years with a short stint in between as a tax manager in the Global Wealth division at Citigroup. His duties included assisting in the structuring of products to enhance after-tax returns, reviewing new products being distributed to clients as well as reviewing tax issues with clients and developers of new financial products.
Mark began his career and became a partner at Coopers & Lybrand primarily servicing the broker-dealer community. He received his LLM in Taxation from New York University, his JD from New York Law School, and his BS from Brooklyn College and is a Certified Public Accountant. Mark was president of the Wall Street Tax Association in 2007-2008 and is currently an adjunct professor at the Lubin School of Business at Pace University
Diane has over eighteen years of experience providing tax services to clients in the hedge fund and private equity industries. She is the Director of Tax Services at Morgan Stanley Fund Services. Diane works with clients to proactively manage fund and investor level tax exposure, general partner tax planning, while overseeing the tax compliance services to the MSFS client base. Diane also focuses on developing new and enhanced proprietary tax analytical reporting. Prior to joining MS, Diane spent ten years within Ernst & Young’s asset management practice helping clients understand the tax implications of various financial products, advising on alternative investment structures in addition to providing federal, state and international compliance services to hedge funds, private equity funds, general partner and management company entities. Before joining EY, Diane serviced high net worth individual clients at Merrill Lynch. She is a CPA and holds an MS in taxation.
Phil Gross focuses on the taxation of hedge funds and private equity funds, including domestic funds, offshore funds, funds of funds, and real estate funds. Phil counsels clients on structuring (and restructuring) funds, structuring investment managers and general partners, compensating managers and employees, investing in funds, and seeding managers or being seeded. He also advises clients on insurance dedicated funds and private placement life insurance, and other international, federal, state and local fund tax issues. He has practiced at KKWC since December 1993. Phil is a frequent speaker and author on fund tax issues. Phil has been selected as a New York Super Lawyer (2014 to present).
College of William & Mary (B.B.A., 1983); Beta Gamma Sigma. Vanderbilt University School of Law (J.D., 1986). New York University School of Law (LL.M. in Taxation, 1989). Certified Public Accountant, New York 1989. New York State Bar Association (Tax Section, Committee on Taxation of Financial Instruments). Managed Funds Association (Tax Section). New York State Society of CPAs (Taxation of Financial Products Committee). New York City Bar Association (Taxation of Business Entities Committee (former chair)). New York Tax Study Group. Tax Club.
Isaac is a senior manager in KPMG’s New York State and Local Tax practice specializing in Alternative Investments. Isaac has more than nine years of experience in the State and Local tax area. Isaac oversees tax compliance engagements for a diverse client base within the asset and wealth management industry. Isaac specializes in rendering state and local tax advice with respect to the set-up of new funds, structuring and exiting of investments, state nexus analysis and compliance, and consulting on taxation considerations for various investors. Prior to joining KPMG, Isaac worked as a tax manager at PwC's Asset & Wealth Management practice. Isaac obtained an MBA from the Zicklin School of Business at Baruch College with a specialty in Finance and Investments and an accounting degree from CUNY Brooklyn College. Isaac is a licensed CPA in New York State.
David has over 20 years' experience in taxation and started at SS&C in 2020. Previously, David was a tax principal and member of the Financial Services Group at EisnerAmper LLP. He has more than 20 years of experience focusing on financial services and investment management entities, and frequently advises on all aspects of tax planning and compliance for financial services firms and their related entities. David has a J.D. from New York Law School and a B.S. in accounting from SUNY at Albany.
Josh Kaplan is Co-Chair of the Trusts & Estates Practice Group at Kleinberg Kaplan. He advises clients on a broad range of trusts and estates issues, including estate planning and administration; estate, gift and GST tax planning; business succession planning; charitable giving; and life insurance.
Josh counsels fiduciaries during all stages of estate administration, including preparation of probate documents, locating and gathering assets, and preparation of both federal and state estate tax returns. In addition, he advises trustees regarding all aspects of trust administration and other related matters. His experience includes advising clients in connection with preparation and review of federal gift tax returns and disclosure of non-gift transactions.
Josh has significant experience in cross-border estate planning. He advises non-U.S. citizens regarding U.S. transfer tax planning, the disposition of U.S. assets owned by foreign estates, and related U.S. federal and state tax reporting requirements.
In the corporate and private investment fund spaces, Josh assists principals at hedge funds and private equity funds in connection with transfers of fund interests to and from trusts, estates, family limited partnerships and other private investment vehicles. In addition, he advises institutional clients regarding fiduciary issues and corporate transactions involving trusts and estates.
He received his LL.M and J.D. from New York University School of Law and his B.A. from the University of Pennsylvania.
Mark H. Leeds is a Tax Transactions & Consulting partner in Mayer Brown's New York office. His practice is focused on the tax consequences of a variety of capital markets 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 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. 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 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.
A frequent writer and speaker on tax topics affecting the capital markets, Mark is also the editor-in-chief of the monthly publication Derivative: Financial Products Report.
Michael J. Miller has provided U.S. tax advice to domestic and international clients for more than 25 years. Working with foreign clients, he has structured inbound U.S. investments and operations to avoid the creation of a U.S. permanent establishment and developed structures designed to take advantage of U.S. income tax treaties, the withholding tax exemption for portfolio interest, and other special rules for minimizing U.S. tax. This includes consideration of various anti-abuse rules, such as earnings-stripping limitations and restrictions on the ability to engage in treaty shopping or earn income through hybrid entities. He has worked with U.S. multinationals to structure their foreign investments and operations so as to minimize the impact of certain restrictions on outbound transfers and anti-deferral rules applicable to shareholders of controlled foreign corporations and passive foreign investment companies, as well as maximize the utilization of foreign tax credits.
Michael is currently President of the International Tax Institute. He also is co-Chair of the New York University Summer Institute in Taxation: Introduction to International Taxation and Advanced International Taxation.
Michael is a former Chair of the U.S. Activities of Foreign Taxpayers Committee of the American Bar Association Tax Section and the Taxation of Business Entities Committee of the New York City Bar. Michael is designated as a leading tax professional in numerous publications, including Chambers USA, Super Lawyers, and Legal Media Group's Expert Guides: Tax Advisors.
Michael has previously served as an expert on U.S. taxation for Her Majesty’s Revenue & Customs, i.e., the U.K. tax authority.
Michael speaks and writes frequently on international tax issues. Recent presentations and articles include:
S Corporations and the International Tax Provisions of the TCJA, at the American Bar Association Tax Section Midyear Tax Meeting, Boca Raton, January 31, 2020 (with Joseph E. Tierney, III and Laura Howell-Smith).
Tax Traps and Opportunities, at the International Fiscal Association USA Branch, New York Region Fall Conference, December 13, 2019 (with Joseph Esperance, Martin T. Hamilton, and Matthew O’Halleran).
Avoiding the "Commercial Activity" Traps for Foreign Sovereigns Investing in U.S. Real Estate, Canadian Tax Journal, Vol. 67:2, June 2019.
Michael has co-authored two BNA Portfolios: Income Tax Treaties - The Limitation on Benefits Article and U.S. Taxation of International Shipping and Air Transport Activities. In addition, Michael is an editor of the International column for the Journal of Taxation, and a member of the Advisory Boards of the International Tax Journal and the BNA Tax Management International Journal.
He received a B.A. cum laude from Columbia College and his J.D. from New York University. He clerked on the U.S. Tax Court for the Honorable James S. Halpern from 1991-1993.
Amanda H. Nussbaum is a partner in the Tax Department at Proskauer and also is a member of the Private Funds Group. Her practice concentrates on planning for and the structuring of domestic and international private investment funds, including venture capital, buyout, real estate and hedge funds, as well as advising those funds on investment activities and operational issues. She also represents many types of investors, including tax-exempt and non-U.S. investors, with their investments in private investment funds.
Sajjad Qamar
Senior Director, International Tax, Financial Services
Sajjad Qamar Senior Director, International Tax, Financial Services
RSM US
As Senior Director of International Tax, Sajjad primarily focuses on inbound and outbound taxation of asset management and financial services clients. Sajjad has over 15+ years of experience working with a Big 4 firm, during which he served hedge funds, private equity groups, pension funds, sovereign wealth, mutual funds, insurance companies, and international banks. His industry focus includes both asset management and financial services.
Sajjad has worked on a variety of large tax consulting projects including issues such as onshore/offshore, master/feeder structuring, U.S. trade or business analysis, tax considerations at the level of portfolio company/investments, treaty applications, Foreign Investment in Real Property Tax Act (FIRPTA), mergers and acquisitions (M&A) transactions, earnings and profits studies, computation of foreign tax credits, global intangible low-tax income (GILTI), and Subpart F. In addition, Sajjad has extensive experience with U.S. compliance of international operations with respect to controlled foreign corporations (CFCs), passive foreign investment companies (PFICs), and foreign disregarded entities, as well as with analysis of income taxes with respect to uncertain tax positions (ASC 740) under U.S. GAAP, in addition to review of relevant financial statement disclosures.
Previously, Sajjad worked for over four and half years with NASDAQ-AMEX Stock Market Group as Lead Financial Analyst focused on financial analysis and due diligence of companies who applied for initial public offerings (IPOs) and secondary listings on the stock exchange.
Laura Ross is a Tax Partner in the Financial Services Group. With over 20 years of experience, she has extensive expertise in accounting and tax issues related to hedge funds, market makers, and pass-through entities and their owners. Laura signs tax returns for some of the most complicated security partnerships on behalf of the firm.
Laura frequently speaks at seminars and webinars on hedge fund taxation issues, and has been an adjunct professor teaching tax, accounting, and investment courses at local universities.
Michael Spiro chairs the firm's Tax group where his practice focuses on providing federal and state tax advice in connection with domestic and international transactions, including hedge and private equity fund formations, mergers and acquisitions, and debt and equity financings and restructurings.
Mr. Spiro holds a J.D. from the University of Pennsylvania Law School, where he was a Senior Editor of the Journal of International Economic Law; an LL.M. in Taxation from Temple University Beasley School of Law, where he was the recipient of the Faculty Award in Taxation; and a B.A., magna cum laude from Brandeis University.
Mr. Spiro is admitted to practice in the States of Connecticut and New Jersey and in the Commonwealth of Pennsylvania. He is a member of the Executive Committee of the Tax Section of the Connecticut Bar Association. Mr. Spiro also serves as an Adjunct Professor of Taxation at the Fairfield University Dolan School of Business.
Andy Swanson has extensive experience providing tax consulting services to closely held companies and their owners. Having practiced public accounting since 2000, Andy’s primary focus is on various sectors of the service and consumer products manufacturing industries. In his current role at RSM US LLP, Andy leads the business owner tax practice with a focus on closely held businesses and their owners, providing proactive tax and business advice to help them reach their goals.
George Teixeira, CPA, is a tax partner at Anchin. He is a Co-Practice Leader of the Firm’s Private Equity Group, Tax Leader of the Firm’s Financial Services Practice and a member of its Private Client Group. George is experienced in servicing the alternative investment, private equity and financial services industries. His expertise includes tax planning for high net worth individuals, investment partnerships, investment advisors, broker-dealers, venture capital companies, hedge funds (and their investors), investment partnership management companies and general partner entities. He specializes in the taxation of securities transactions and financial services companies, in addition to offering tax compliance and consulting services for a diversity of entities and individuals.
James is based out of the New York City office of Ernst & Young LLP and serves as the EY Americas Financial Services Office Indirect Tax, State and Local Tax Leader.
As a partner with more than 20 years of experience, James is responsible for a team of tax professionals dedicated to the financial services industry. He fully integrates with EY professionals as they provide assistance with and throughout the regulatory and compliance cycles, including planning opportunities, driving tax technology efficiencies and workflows.
He enjoys mentoring tomorrow’s leaders in the accounting and professional services industries and being an active participant in the local community. He teams and creates exceptional value with EY professionals in the United States, India, Buenos Aires, and in other countries.
James has lectured on and taught several topics, including pass-through compliance and withholding, New York sourcing rules and combinations, and the treatment of foreign-source income at the state levels. He has also authored several white papers and articles on state tax.
A graduate of Morehouse College, James earned his postgraduate degree from Washington and Lee University School of Law. He is also a certified public accountant licensed in New York.
Joshua Tompkins Managing Director - Washington National Tax
KPMG
Josh Tompkins is a Managing Director in the Financial Institutions and Products group of the KPMG Washington National Tax practice. In this capacity, he works with leading financial institutions and other capital markets participants on tax issues arising from derivatives transactions, issuances or purchases of debt, securitizations, debt restructurings, equity investments, and other capital markets transactions. Josh is also highly involved in the cryptocurrency industry and regularly advises cryptocurrency developers, miners, investors, and intermediaries.
Josh is the co-editor-in-chief of the Journal of Taxation of Financial Products, co-author of the Interest Expense Deductions Bloomberg BNA Portfolio, a contributor to the Taxation of Financial Institutions Treatise, and the author of a number of comment letters and articles on financial products issues. Articles focused on cryptocurrency include: (i) Proof of Stake – What’s Really at Stake on the Tax Front?; (ii) Cryptocurrencies and the Definition of a Security for Code Sec. 1091; (iii) Wrapped Bitcoin – Two Sides of the Same (Bit)coin?; and (iv) Cryptocurrency Loans – Taxable or Not? (each published in the Journal of Taxation of Financial Products).
