Miri Abrams Forster Partner and National Tax Controversy Leader
Eisner Advisory Group LLC
With more than 20 years of IRS practice, procedure and tax controversy experience, Miri specializes in providing tax dispute resolution services to public and private corporations, partnerships and high-net- worth individuals. She represents clients before the IRS Examination and Appeals Divisions on complex domestic and international tax issues and obtains private letter rulings from the IRS National Office. Miri assists clients with voluntary disclosures of inadvertent income, international information return, withholding, and payroll tax compliance errors. She secures penalty abatements and refunds, resolves IRS account issues, and advises on a myriad of dispute resolution matters. Miri was previously a tax controversy principal at a Big Four firm and served as an Attorney-Advisor at the U.S. Tax Court.
Peter Bergren joined Empyrean in 2013. Mr. Bergren began his career in public accounting in 2004 at PriceWaterhouseCoopers, LLP, where he was employed until 2006. He joined Magnetar Capital LLC in 2006 as a Senior Product Accountant when the firm had approximately $3 billion in AUM. In 2010, when the firm had grown to $9 billion in AUM, Mr. Bergren became the Assistant Controller, reporting to the Chief Financial Officer, and managing the firm’s accounting, administration, reporting and year-end audit process for over forty multi-strategy private funds and registered products. Mr. Bergren is a Certified Public Accountant and a CFA charterholder. Mr. Bergren earned a BS in Finance & Accounting from Indiana University’s Kelley School of Business.
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 private equity funds.
Jill advises clients on all aspects of tax with a concentration in the areas of financial services. 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, private equity 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 Financial Research Associates and the Practicing Law Institute.
Memberships • American Bar Association, Tax Section, Real Estate and Partnership, Committees • National Association of Real Estate Investment Trusts • Association of the Bar of the City of New York, Committee on Taxation of Business Entities • New York State Bar Association, Tax Section
CPA, CMA, Chief Financial Officer, Treasurer and Principal
Eric Emrich CPA, CMA, Chief Financial Officer, Treasurer and Principal
Lubert-Adler Management Company, LP
Mr. Emrich, Chief Financial Officer, Treasurer and Principal, has over 35 years of experience in private equity, real estate and investment partnerships. He is responsible for all finance, accounting, tax and risk management for Independence Capital Partners, LLC.
Prior to joining ICP, Mr. Emrich was Tax Director and Controller for the CMS Companies’ private equity/hedge funds. He was also a Managing Partner for a SEC registered investment advisor in Plymouth Meeting, PA. In addition, Mr. Emrich spent 12 years in public accounting, including 7 years with KPMG, LLP in Philadelphia. For KPMG, Mr. Emrich served the Philadelphia office’s real estate, venture capital, securities partnership and investment advisor tax clients.
Mr. Emrich is a member of the American and Pennsylvania Institute of CPAs, the Delaware Society of CPAs and the Institute of Management Accountants. He is a board member of the National Association of Real Estate Companies and a board member for The Private Equity CFO Association, Philadelphia chapter. He spent five years as an Adjunct Professor in the Drexel University Master of Taxation Program, and currently serves on the Advisory Board to the Villanova Law School Master of Tax Program. Mr. Emrich graduated cum laude from the University of Delaware with a B.S. in Accounting with Economics as a second major. He received his M.S. in Taxation from Widener University.
Erica England is the Chief Financial Officer of the Wolcott organization, which includes the Wolcott Family Office and Wolcott construction firm. Erica is responsible for the organization’s accounting, finance, human resource, tax and information technology systems. Erica also oversees the investment portfolio, including asset allocation, due diligence of investment managers and tax planning.
Erica’s experience in the alternative investment space includes asset management, compliance, financial reporting, taxation, and valuations, with a focus on real estate. Erica holds a BS in Business Administration and Management from Boston University and has held her CPA license since 2003.
Before joining Wolcott, Erica was the Chief Accounting Account Officer for Redwood Real Estate Administration, a fund administration firm, where she was responsible for setting accounting policies, developing the business, and mentoring a team of accounting professionals. Prior to Redwood, Erica served as the Chief Compliance Officer and Controller of JCR Capital, where she was responsible for the financial management and compliance programs for the firm’s private equity real estate funds and corporate entities. Previously, Erica was at The Carlyle Group, where she held the roles of Corporate Accounting Manager responsible for the financial management of all U.S. operating entities and Senior Accountant responsible for the accounting and investor reporting for numerous global private equity funds.
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.
Nick Heijkoop is a partner in PwC's Global Structuring - Financial Services tax practice in New York. He was a member of PwC's M&A Tax practice in the Netherlands before moving to the US. Nick has built up years of experience working on investor, fund and investment level tax structuring for financial services clients with a particular focus on private equity and distressed and special situations investing. His client base has a global investment focus and he assists them on cross-border taxation both in the U.S. and abroad.
Ali is Managing Director at Hansuke and actively advises bank boards on financial, regulatory and governance matters.
Ali brings over 25 years of financial services industry experience, after having held successive leadership roles including as Head of Tax at BlackRock and as International Partner of Deloitte UK and Middle East.
Ali is a frequent speaker at conferences and has also written on a wide range of topics including QI, AEoI (FATCA, CDOT and CRS), securities lending, sovereign fund investing, pension & asset pooling, multi‐manager investing, custodial structures, and stamp & transfer taxes.
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.
Morgan advises clients on federal and international income tax and private equity matters. Her practice includes advising on mergers, acquisitions, reorganizations, dispositions, capital markets, and restructurings. Morgan has advised private equity sponsors, as well as their portfolio companies and other strategic clients, on the tax aspects of investments, acquisitions, and divestitures. She is also involved in the formation of private equity and hedge funds.
Morgan is an adjunct tax professor at Temple University Beasley School of Law, vice chair of the Partnership Committee of the Tax Section of the American Bar Association, an elected member of the Philadelphia Bar Association’s Tax Council, and treasurer of the Philadelphia Tax Conference. Additionally, Morgan is a frequent speaker on a variety of transactional tax matters and has lectured at several major conferences and forums, including the American Bar Association Tax Conference, the Tulane Tax Institute, and the Chicago Tax Club.
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.
LEN LIPTON Managing Director and Head of Sales, Americas GlobeTax Len and his team sell to custodians and asset managers, and hedge funds. Len also engages in product development efforts so GlobeTax can continue to provide the highest levels of service to its clients in the rapidly changing global tax landscape. Prior to joining GlobeTax in 2004, Len focused on new business and relationship management with Elkins/McSherry, LLC (a State Street Company) as a Managing Director, assisting institutional investors in monitoring portfolio trading costs. His experience also includes investment consulting with Ladenburg Thalmann and Co. Len is a frequent speaker at industry seminars and withholding tax educational forums.
Colleen McHugh is partner-in-charge of Marcum’s New York City Tax Department, where she oversees tax and business services to high net worth individuals and business clients in more than two dozen industries. Ms. McHugh additionally serves as partner-in-charge of the national Tax Department of Marcum’s Alternative Investments Group, which serves the audit, tax, and consulting needs of both emerging and established fund managers.
Her practice specialization is partnership and private equity taxation. She has more than 15 years of experience advising private equity funds, their general partnerships, and management companies on complex tax matters, including international and state and local tax compliance.
Prior to joining Marcum in 2013, Colleen served in the private equity group of a “Big 4” public accounting firm. Previously, she spent two years in the Washington National Tax group of another “Big 4” firm, where she specialized in partnership taxation.
Ron G. Nardini advises a broad base of clients on domestic and international tax matters. He focuses primarily on the formation, operation, and investments of private equity, venture capital, and hedge funds, with a particular focus on credit, health care, entertainment and cross-border investments.
In particular, Ron provides tax advice regarding the structuring of investment funds formed to invest in the credit space, including loan origination, trade claims, distressed debt, nonperforming loans, rescue, bridge and debtor-in-possession financing and structured credit.
Ron also advises on the formation of investment managers, the structuring of seed investments, real estate investments, as well as partnership tax matters, mergers and acquisitions, international tax matters and restructurings matters.
Ron has broad understanding of the tax issues attributable to investments by sovereign wealth funds in the U.S. equity and debt markets. In addition, Ron works closely with purchasers and investment funds regarding fund secondary transactions. Finally, Ron works with creditors of financially troubled companies on a variety of tax issues attributable to their investment, including utilization of net operating losses.
Ron is recognized byChambers USA(2022) where reviewers praise his “nuanced understanding of issues” and his ability to “weave many complex issues into a well-thought solution.”
Tim focuses his practice in the state and local tax area. His work primarily involves New York State and New York City tax litigation and controversy. Over the past 23 years, he has handled more than 2,000 personal income tax, sales tax, corporate tax, or other New York tax audits. Tim also has handled about 100 cases in New York’s Division of Tax Appeals. Tim leads the firm’s Tax Residency Practice and he is one of the leading practitioners in this area of the law. He has handled some of the most high-profile residency cases in New York over the past decade, including a 2014 win in the Gaied case, one of the first New York residency cases to ever reach New York’s highest court. He is often quoted by media outlets, including The Wall Street Journal, The New York Times and Forbes, on residency and other state tax issues. And under his direction, the Tax Residency Practice authored What to Expect in a Residency Audit, a detailed guide to residency rules and audits in New York and other states. As the “Noonan” in “Noonan’s Notes,” a monthly column in Tax Notes State, Tim is a nationally recognized author and speaker on state tax issues. He has also written more than 250 articles in state and local tax publications around the country over the past several years.
Janicelynn Asamoto Park is a partner in the Tax Department and a member of the Private Funds Group. She counsels fund sponsors and their investors as to the tax and economic considerations relating to forming, operating, and investing in private investment funds, co-investment vehicles, and other investment partnerships across asset classes. Janicelynn also regularly advises investors and sponsors in buy-side and sell-side secondary transactions (including in connection with GP-led fund restructurings).
She currently serves on the board of Reach Out and Read of Greater New York, a not-for-profit organization that partners with physicians to promote early literacy in low-income communities.
Before joining Proskauer, Janicelynn served as a law clerk for the Honorable Denny Chin of the U.S. Court of Appeals for the Second Circuit, and was a youth development volunteer in Honduras with the U.S. Peace Corps.
John joined NGP in 2007. Responsibilities include the oversight of tax planning and preparation of tax information for NGP and affiliates. He is involved in tax planning and structuring for acquisitions, dispositions and reorganizations of NGP portfolio companies.
Victoria has been a part of RSM’s New York international tax practice since 2015. Victoria provides tax compliance and consultation services to US entities with foreign activities, including preparation of foreign filings for the IRS, controlled foreign corporation income inclusions, interest charge domestic international sales corporations, and international tax provisions. Victoria also has experience assisting clients in various international M&A duties, include buy-side and sell-side due diligence. Victoria is the international tax compliance subject matter lead for RSM’s Northeast region and is the subject matter lead for Schedules K-2 and K-3.
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.
Partner and Tax Leader of Financial Services Practice
George Teixeira Partner and Tax Leader of Financial Services Practice
George Teixeira, CPA, MS, is a Tax Partner at Anchin. He is the Tax Leader of the Firm’s Financial Services Practice and Leader of the Firm’s Private Equity Group, as well as a member of Anchin Private Client.
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.
George works closely with clients to develop effective planning structures and strategies. He advises high-net-worth individuals on estate planning, trust planning, charitable contributions and investment strategy and planning. His specific knowledge of straddles, swaps, options, wash sales and mark to market investments has led to his involvement with some of the largest investment partnerships in the country and the expansion of investment firms’ funds offshore.
George frequently lectures for the Financial Research Associates (FRA) and the New York State Society of CPAs (NYSSCPA) on issues such as tax allocation methodologies, partnership contributions and distributions as well as tax planning and structuring. Prior to joining Anchin, George was a partner in a national firm where he was the financial services tax practice leader.
George is a member of the New York State Society of Certified Public Accountants (NYSSCPA) and the American Institute of Certified Public Accountants (AICPA). He is also a member of the Wall Street Tax Association (WSTA), the Managed Funds Association (MFA) and the Association for Corporate Growth (ACG). In addition to English, George is fluent in Portuguese.
Randy is experienced in multistate tax appeals, representing taxpayers at both the administrative and judicial levels. His substantive experience in commercial litigation adds value to his state and local tax controversy work. Randy has obtained substantial relief for taxpayers at the audit, administrative, and judicial levels in the areas of corporate income tax, sales and use tax, gross receipts tax, property tax, business privilege tax, utility tax, personal income tax, and various other taxes.
In addition, Randy provides compliance, tax planning, and audit advice to businesses of all sizes. Randy helps clients lessen their state and local tax burden through effective planning and, if necessary, litigation. He has advised clients in many industries, including pharmaceuticals, financial services, manufacturing, software development, entertainment, hospitality, big box retail, and automotive, among others.
Randy’s experience also includes providing valuable multistate state and local tax review and due diligence support for transactions. This careful review and planning during the negotiation stage of deals is essential to avoid negative state and local tax impacts.
Recently, Randy spent two years as a senior deputy attorney general in the Tax Litigation Section of the Pennsylvania Office of Attorney General.
Randy is a frequent speaker and author on state and local tax topics. He has presented at conferences sponsored by the Institute for Professionals in Taxation, the Council on State Taxation, the Pennsylvania Chamber of Business and Industry, the Tax Executives Institute, the Pennsylvania Bar Institute, the Assessors Association of Pennsylvania, the Pennsylvania State Mayors’ Association, the Maryland Association of CPAs, among others.
A resource for both clients and colleagues, Rob knows the complex and unique technical tax needs of the investment industry inside and out. So when a client asks him “what do you think of …” or “have you ever seen …” he can knowledgeably answer those questions and give a practical assessment of how it might impact the client’s situation.
With several years of prior experience in the tax department of a Big 4 firm, Rob provides tax compliance and consulting services to a diverse client base of open- and closed-end mutual funds, hedge funds, exchange-traded funds, private equity funds, family limited partnerships and the advisers to these funds. He oversees the tax services provided to the firm's investment company clients and serves as a technical resource on a variety of related issues, including structuring and start-up concerns, mergers and reorganizations, taxation of various debt and derivative instruments, and foreign investments. In addition, Rob has developed a specialized team that provides tax and accounting services to master limited partnership (MLP)-focused investment funds.
Rob focuses his practice on representing entities and individuals in complex tax matters. Specifically, he advises clients on matters related to federal and state tax laws and how to minimize the impact of taxes on transactions and transfers. He advocates on behalf of clients before the Internal Revenue Service and state departments of revenue, including audits and appeals from audit determinations, compliance, collections, and U.S. Tax Court matters.
In addition, Rob advises individual clients with estate and tax planning matters, including succession issues for closely held businesses and preparation of estate planning and succession documents. He also counsels clients on issues related to tax-exemptions and represents businesses and individuals in business dealings, including structuring, acquisitions, and entity selection matters. Rob regularly advises tax-exempt organizations on questions of policies and procedures, corporate governance, private inurement, fundraising, and development.
Rob is a frequent lecturer on topics related to taxation and corporate governance and serves as an Adjunct Professor of Law at Wake Forest University School of Law.
For more than 25 years, Robert Welzel has been advising various types of international Financial Services clients in cross-border tax and regulatory law, esp. from the asset management sector, such as fund companies, administrators and software vendors on business development, process optimization, digitalization, tax compliance and cross-border structuring of investments. His work includes providing support to investment banks and funds vehicles for structuring investment products in line with German tax and supervisory regulation as well as structured finance solutions.