Hope P. Krebs
Partner

Duane Morris LLP
30 South 17th Street
Philadelphia, PA 19103-4196
USA

Phone: +1 215 979 1964
Fax: +1 215 689 2902
Email: HPKrebs@duanemorris.com

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Hope P. Krebs

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Hope P. Krebs is an international tax partner and the co-chair of the firm's International Practice Group. Prior to joining Duane Morris, Ms. Krebs was a senior manager of International Tax Services for Ernst & Young LLP and, prior to that, was associated with the New York office of another major national law firm.

Ms. Krebs is the co-author of a Bureau of National Affairs, Inc. Tax Management Portfolio titled 915-1 T.M. U.S. Income Tax Withholding - Foreign Persons and the author of numerous tax articles. She is a frequent speaker on international tax topics at tax conferences across the country.

Ms. Krebs recently completed her term as President of the British-American Business Council and continues to serve as a Board member of the organization. She is a member of the Executive Council of Multilaw, The Multinational Association of Law Firms, and is a member of the Executive Committee and Planning Board for the annual Philadelphia Tax Conference.

Ms. Krebs is admitted to practice law in New York and Pennsylvania and before the U.S. Tax Court. She is listed in Who's Who in American Law, Who's Who of American Women and Who's Who in Finance and Industry.

Ms. Krebs is a 1992 graduate of New York University School of Law (LL.M., taxation), a 1987 graduate of Villanova University School of Law (J.D.) and a graduate of Drexel University (B.S., Business Administration).

Representative Matters

  • Represented TÜV SÜD in its strategic acquisition of RCI Consultants Inc., located in Houston, Texas.
  • Represented Balchem Corporation in a $450 million syndicated credit facility led by Bank of America.
  • Represented a private investment company focused on casino operators and suppliers in (i) rolling up its various gaming equipment finance businesses, (ii) completing a reverse takeover of a Canadian public shell company, and (iii) completing a public offering of $10 million of common stock and $10 million of secured convertible debentures.
  • Represented a Chicago-based private equity fund in the sale of a Michigan headquartered benefits payments processing services company to an Ohio-based private equity firm.
  • Represented a manufacturer of boilers, generators and heaters in its sale to a private equity company.
  • Represented Iroko Pharmaceuticals, a global specialty pharmaceutical company dedicated to advancing the science of responsible pain management, in securing $75 million in debt financing to support general business operations and the commercialization of Iroko's FDA-approved ZORVOLEX™ (diclofenac), a drug that uses iCeutica Inc.’s proprietary SoluMatrix Fine Particle Technology™ to both reduce the dosage of active ingredients ingested by the patient and accelerate the dissolution of the drug in the patient.
  • Represented a French CAC 40 company in connection with the sale of its wind-to-energy subsidiary for $81 million.
  • Represented a major French CAC 40 company as lender and guarantor in connection with a $230 million project syndicated loan to a wind energy project.
  • Represented the lender in obtaining a $55 million secured financing, consisting of U.S. and Dutch credit facilities, provided to a global transportation company.
  • Minimizing worldwide income and withholding taxes and maximizing the use of foreign tax credits. Proposed and implemented alternative structures to accomplish numerous clients' goals of minimizing worldwide effective tax rates, while achieving business and economic objectives. Depending upon the particular foreign country involved, the type of U.S. taxpayer involved and the U.S. taxpayer's particular foreign tax credit position, worldwide tax savings have been as high as 50%.
  • Avoiding US anti-deferral tax rules, such as the controlled foreign corporation and passive foreign investment company regimes. Proposed and implemented minimally-intrusive modifications to manner in which client originally proposed to conduct business in foreign country so as to enable client to obtain US tax deferral on foreign earnings.
  • Tax advantageous structures for specific cross-border transactions and cross-border financing arrangements. Assisted foreign clients in structuring acquisitions and dispositions of US businesses to minimize US tax and reporting. Assisted U.S. clients in structuring offshore acquisitions and dispositions to maximize US tax deferral and minimize their worldwide effective tax rates by optimizing foreign tax credits and reducing foreign country taxes.
  • Tax efficient structuring for key employees transferred for business purposes from one country to another. Helped foreign business clients minimize their U.S. tax exposure despite frequent presence of employees and/or property in the United States by, among other things, slightly adjusting manner in which U.S. business was conducted and, when requested, assisted key employees in dealing with personal U.S. cross-border tax issues.
  • Utilizing related party transactions, transfer pricing, regional holding companies, tax treaties, tax havens and low-tax jurisdictions to enable clients to deploy capital around the globe in a tax-efficient manner. Assisted major foreign-owned multinationals in implementing tax efficient intellectual property holding company, resulting in savings of millions of dollars per year in worldwide taxes. Assisted clients in substantially lowering their worldwide effective tax rates by reviewing related party opportunities to maximize deductible fees paid to related foreign service providers in low-tax jurisdictions. Also, assisted client in preparing transfer pricing documentation for related party transactions, enabling client to avoid imposition of 20% and 40% transfer pricing penalties.

Admissions

  • Pennsylvania
  • New York
  • U.S. Tax Court

Education

  • New York University School of Law, LL.M. - Taxation, 1992
  • Villanova University School of Law, J.D., 1987
  • Drexel University, B.S., Business Administration, 1984

Experience

  • Duane Morris LLP, Philadelphia, Pennsylvania
    - Partner, 1998-present
    - Co-Chair, International Practice Group, 2001-present
    - Member, Recruitment and Retention Committee, 2000-2007
  • Villanova University School of Law, Graduate Tax Program, Villanova, Pennsylvania
    - Lecturer in Law, 1995-2007
  • Ernst & Young LLP, Philadelphia, Pennsylvania
    - Senior Manager, International Tax Services, 1997-1998
  • Piper Marbury LLP (now known as DLA Piper), New York, New York
    - Tax Attorney, 1995-1997
  • Varet & Fink PC (formerly Milgrim, Thomajan & Lee PC), New York, New York
    - Tax Attorney, 1990-1995
  • Gordon Hurwitz Butowsky Weitzen Shalov & Wein, New York, New York
    - Tax Attorney, 1987-1990

Professional Activities

  • Activities
  • British-American Business Council of Greater Philadelphia
    - President, 2011-December 31, 2013
    - Vice President, Membership, 2005-2011, 2014-present
    - Board of Directors, 2005-present
  • Multilaw, the Multinational Association of Independent Law Firms
    - Executive Council, 2011-present
    - Chair, Future Conferences Committee, 2012-present
    - Chair, Pro Bono Mission, 2011-present
  • Philadelphia Tax Conference
    - Planning Board and Executive Committee, 2001-present
    - Member, Executive/Advisory Committee, 2006
  • Chair, "Transfer Pricing 101," Executive Enterprise Institute, Chicago, Illinois, June 20, 2013
  • Chair, "International Tax Bootcamp," Executive Enterprise Institute, Chicago, Illinois, June 18-19, 2013
  • Chair, "International Taxation Bootcamp," Executive Enterprise Institute, New York, New York, June 22-23, 2010
  • Co-Chair, Fifth Annual Inbound Tax Conference, "Current U.S. Tax Planning Strategies for Foreign-Controlled U.S. Companies," Council for International Tax Education, New York, New York, May 13-15, 2002
  • Chair, "Advanced International Taxation - Strategic Planning," Executive Enterprise Institute, Chicago, Illinois, October 17-18, 2001; October 4-5, 2000
  • Chair, "Introduction to International Taxation - Conceptual Bootcamp," Executive Enterprise Institute, Chicago, Illinois, October 15-16, 2001; October 2-3, 2000
  • Associations
  • International Fiscal Association
  • American Bar Association
    - Section of Taxation
    -- Committee on U.S. Activities of Foreign Taxpayers
    -- Committee on Foreign Activities of U.S. Taxpayers
  • New York State Bar Association
    - Tax Section
    -- Committee on U.S. Activities of Foreign Taxpayers

Honors and Awards

  • Listed in Marquis Who's Who in American Law
  • Listed in Marquis Who's Who of American Women
  • Listed in Marquis Who's Who in Finance and Industry
  • AV® Preeminent™ Peer Review Rated by Martindale-Hubbell

Selected Publications

  • Quoted in "Inversions May Slow, but Related Legal Work Won't," The Legal Intelligencer, September 24, 2014
  • Co-author, "House Ways and Means Committee Releases Proposal on Tax Reform," Duane Morris Alert, February 28, 2014
  • Co-author (with Duane Morris colleague, Thomas Ostrander), USA Chapter, Tax Litigation Jurisdictional Comparisons, 1st Ed 2013, Thomson Reuters- European Lawyer Reference Series
  • Quoted in "Multilaw's Mission Pro Bono," Canadian Lawyer, August 21, 2012
  • Quoted in "International Networking in Philadelphia—Kibitizing with Brits," Philadelphia Inquirer, December 15, 2011
  • Co-author, "2009 – A Year of Increased Focus on International Tax Reporting," 68 New York University Institute on Federal Taxation, Volume 1, Chapter 3 (Matthew Bender 2010)
  • Co-author, "By the Numbers Coping with International Tax Reporting for International Matters," 67 New York University Institute on Federal Taxation, Volume 1, Chapter 15 (Matthew Bender 2009)
  • Co-Author, "U.S. Accounts to Be Disclosed Under U.S.-Swiss Settlement Agreement," Practical US/International Tax Strategies, September 15, 2009
  • Quoted in "Tax Benefits For US Shareholders In Foreign Mergers" by Claire Spencer, Financier Worldwide, July 2009
  • Co-Author, "Euro Portends Unknown U.S. Tax Consequences," The National Law Journal, July 27, 1998
  • Co-author, Tax Management Portfolio, 915-1 T.M., U.S. Income Tax Withholding - Foreign Persons
  • "IRS Reverses Its Position and Decides to Penalize Withholding Agents for Understatements on Form 1042," Tax Management International Journal, 1995
  • Co-author, "Tax Consequences of Investing in the United States," Eighteen Chapters on American Law, a Primer for Taiwanese Investment in the United States, Chapter 3, 1993
  • Co-author, "Managing Bi-Coastal Artists' Taxes," Entertainment Law & Finance, 1992
  • Co-author, "Working on Both Coasts, Determining Artists' Taxes in New York, California," Entertainment Law & Finance, 1992

Selected Speaking Engagements

  • 2014
  • "Challenges of International Tax Compliance," Introduction to International Taxation, New York University Summer Institute in Taxation, New York, New York, July 22, 2014
  • "U.S. Taxation of Foreign Persons," Introduction to International Taxation, New York University Summer Institute in Taxation, New York, New York, July 21, 2014
  • "International Issues for Local Practitioners," Internal Revenue Service 2014 Eastern Pennsylvania Working Together Conference, Penn State Great Valley Conference Center, Malvern, Pennsylvania, May 22, 2014
  • "By the Numbers – Coping with US Tax Reporting for International Matters," PA Society of Tax and Accounting Professionals, Philadelphia Tri-County Chapter, Springfield, Pennsylvania, May 21, 2014
  • 2013
  • "International Tax Issues," Business Tax Planning Guide, National Business Institute, Philadelphia, Pennsylvania, December 9, 2013
  • "Passive Foreign Investment Companies," Introduction to International Taxation, New York University Summer Institute in Taxation, New York, New York, July 17, 2013
  • "U.S. Taxation of Foreign Persons," Introduction to International Taxation, New York University Summer Institute in Taxation, New York, New York, July 15, 2013
  • "Managing Passive Foreign Investment Company Exposure," International Tax Bootcamp, Executive Enterprise Institute, Chicago, Illinois, June 19, 2013
  • "U.S. Tax issues for Foreign Taxpayers," International Tax Bootcamp, Executive Enterprise Institute, Chicago, Illinois, June 18, 2013
  • 2012
  • "Passive Foreign Investment Companies," Introduction to International Taxation, New York University Summer Institute in Taxation, New York, New York, July 25, 2012
  • "U.S. Taxation of Foreign Persons," Introduction to International Taxation, New York University Summer Institute in Taxation, New York, New York, July 23, 2012
  • "International Issues for Local Practitioners," Internal Revenue Service 12th Annual Eastern Pennsylvania Working Together Conference, Penn State Great Valley Conference Center, Malvern, Pennsylvania, May 17, 2012
  • 2011
  • "International Business Issues," Sax Macy Fromm's 7th Annual Bankers Breakfast, Hanover Marriot, Whippany, NJ, September 27, 2011
  • "Passive Foreign Investment Companies," Introduction to International Taxation, New York University Summer Institute in Taxation, New York, New York, July 13, 2011
  • "U.S. Taxation of Foreign Persons," Introduction to International Taxation, New York University Summer Institute in Taxation, New York, New York, July 11, 2011
  • "International Issues and IRS Global High Wealth Industry Exam Program Panel," Internal Revenue Service 11th Annual Eastern Pennsylvania Working Together Conference, Philadelphia, Pennsylvania, May 18, 2011
  • 2010
  • "Passive Foreign Investment Companies," Introduction to International Taxation, New York University Summer Institute in Taxation, New York, New York, July 21, 2010
  • "U.S. Taxation of Foreign Persons," Introduction to International Taxation, New York University Summer Institute in Taxation, New York, New York, July 19, 2010
  • "A Primer on U.S. Taxation of Non-Residents and Foreign Corporations," International Taxation Bootcamp, Executive Enterprise Institute, New York, New York, June 23, 2010
  • "U.S. Tax Issues in Structuring Foreign Operations," Council for International Tax Education (CITE) Annual Conference Series on U.S. International Tax Reporting & Compliance, Philadelphia, April 19-20, 2010
  • "IRS Enforcement Initiatives - Planning and Coping Strategies for Accountants and their Clients with International Activities," Pennsylvania Institute of Certified Public Accountants - Greater Philadelphia Chapter, Philadelphia, PA, January 20, 2010
  • 2009
  • "By The Numbers - Coping with US Tax Reporting for International Matters," New York University 68th Institute on Federal Taxation, New York, New York, October 19, 2009
  • "Passive Foreign Investment Companies," Introduction to International Taxation, New York University Summer Institute in Taxation, New York, New York, July 15, 2009
  • "U.S. Taxation of Foreign Persons," New York University Summer Institute in Taxation, New York, New York, July 13, 2009
  • 2008
  • "By The Numbers - Coping with US Tax Reporting for International Matters," New York University 67th Institute on Federal Taxation, New York, New York, October 23, 2008
  • "Passive Foreign Investment Companies," Introduction to International Taxation, New York University Summer Institute in Taxation, New York, New York, July 16, 2008
  • "U.S. Taxation of Foreign Persons," Introduction to International Taxation, New York University Summer Institute in Taxation, New York, New York, July 14, 2008
  • "Introduction to International Tax," training program for Amper, Politziner & Mattia PC, New Brunswick, New Jersey, June 18, 2008
  • 2007
  • "Passive Foreign Investment Companies," Introduction to International Taxation, New York University Summer Institute in Taxation, New York, New York, July 18, 2007
  • "U.S. Taxation of Foreign Persons," Introduction to International Taxation, New York University Summer Institute in Taxation, New York, New York, July 16, 2007
  • "Asking for Directions: Women Navigating International Transactions," Duane Morris Women's Initiative, Philadelphia, Pennsylvania, June 7, 2007
  • 2006
  • "Case Studies for Outbound and Inbound Investment", Introduction to International Taxation, New York University Summer Institute in Taxation, New York, New York, July 12, 2006
  • "Passive Foreign Investment Companies", Introduction to International Taxation, New York University Summer Institute in Taxation, New York, New York, July 12, 2006
  • "U.S. Taxation of Foreign Persons", Introduction to International Taxation, New York University Summer Institute in Taxation, New York, New York, July 10, 2006
  • "Foreign Earned Income, Transfer Pricing TIPRA etc.", Presentation to Asher and Company Ltd., Philadelphia, Pennsylvania, June 28, 2006
  • "International Taxation", Presentation to Temple University Graduate Students enrolled in Advising the Multinational Company on Global Legal Issues, Philadelphia, Pennsylvania, June 26, 2006
  • "U.S. Anti-Deferral Regimes", Presentation to Asher and Company Ltd., Philadelphia, Pennsylvania, January 18, 2006
  • 2005
  • "The U.S. Foreign Tax Credit", Presentation to Asher and Company Ltd., Philadelphia, Pennsylvania, December 13, 2005
  • "Introduction to International Tax", Presentation to Asher and Company Ltd., Philadelphia, Pennsylvania, November 29, 2005
  • "Passive Foreign Investment Companies," New York University Summer Institute in Taxation, New York, New York, July 20, 2005
  • "U.S. Taxation of Foreign Persons," Introduction to International Taxation, New York University Summer Institute in Taxation, New York, New York, July 18, 2005
  • "Understanding the U.S. Withholding Tax Regime and Filing Requirements for Withholding Agents ," Annual Council for International Tax Education Conference on U.S. Inbound and Withholding Tax Update, New York, New York, June 13-14, 2005
  • "Strategies for Trade & Investment in Mexico," Atlas Legal Conference, co-sponsored by Duane Morris LLP, New York, New York, March 21-22, 2005
  • 2004
  • "Avoiding U.S. Tax Traps Associated with Foreign Affiliate Guarantees & Pledges," DM Reorganization & Finance Practice Group, Philadelphia, Pennyslvania, December 14, 2004
  • "Don't Inadvertently Impair Your Client's Security - Avoiding U.S. Tax Traps Associated with Foreign Affiliate Guarantees & Pledges," DM Commercial Finance Practice Group, Philadelphia, Pennsylvania, October 6, 2004
  • "Passive Foreign Investment Companies and Foreign Personal Holding Companies," Introduction to International Taxation, New York University Summer Institute in Taxation, New York, New York, July 23, 2004
  • "U.S. Taxation of Nonresidents and Foreign Corporations," Introduction to International Taxation, New York University Summer Institute in Taxation, New York, New York, July 21, 2004
  • "Legal Secrets to Winning the International Sales Game," International Visitors Council, Philadelphia, Pennsylvania, June 7, 2004
  • "International Taxation," Financial Reporting and Control of International Operations, sponsored by Executive Enterprise Institute, New York, New York, May 17-18, 2004
  • 2003
  • "Section 956 Investment of Earnings in U.S. Property," Tax Planning for CFCs Under Subpart F, Alliance for Tax, Legal and Accounting Seminars, Philadelphia, Pennsylvania, December 11-12, 2003
  • "International Taxation," Financial Reporting and Control for International Operations, Executive Enterprise Institute, New York, New York, December 1, 2003
  • "Selected Tax Traps in International Tax Planning," Advanced International Taxation - Strategic Planning, Executive Enterprise Institute, New York, New York, November 5, 2003
  • "Reorganizations Involving Inbound and Outbound Transactions" and "Taxation of Nonresidents and Foreign Corporations," Introduction to International Taxation - Conceptual Bootcamp, Executive Enterprise Institute, New York, New York, November 4, 2003
  • "Doing Business in the U.S. and Common Tax Traps for Foreign Persons," Annual Conference of Russell Bedford International (RBI), Boston, Massachusetts, October 17, 2003
  • "Passive Foreign Investment Companies and Foreign Personal Holding Companies," Introduction to International Taxation, New York University Summer Institute in Taxation, New York, New York, July 23, 2003
  • "Source of Income," Introduction to International Taxation, New York University Summer Institute in Taxation, New York, New York, July 21, 2003
  • "International Taxation," Financial Reporting and Control of International Operations, New York, New York, June 23-24, 2003
  • 2002
  • "U.S. Taxation of Foreign Corporations and Nonresident Aliens," Introduction to International Taxation - Conceptual Bootcamp, Executive Enterprise Institute, New York, New York, November 20, 2002
  • "International Tax Issues in E-Commerce," Advanced International Taxation, New York University Summer Institute on International Taxation, New York, New York, July 19, 2002
  • "Passive Foreign Investment Companies and Foreign Personal Holding Companies," Introduction to International Taxation, New York University Summer Institute on International Taxation, New York, New York, July 17, 2002
  • "Tax Efficient Structures for U.S. Operations," Current U.S. Tax Planning Strategies for Foreign-Controlled U.S. Companies, Council for International Tax Education, New York, New York, May 13, 2002
  • "Reducing U.S. Withholding Taxes," Current U.S. Tax Planning Strategies for Foreign-Controlled U.S. Companies, Council for International Tax Education, New York, New York, May 13, 2002
  • 2001
  • "International Taxation," International Operations: Financial Reporting & Analysis, Executive Enterprise Institute, New York, New York, December 6, 2001
  • "International Tax Issues," Doing Business with European Companies, New Jersey Institute for Continuing Legal Education, New Brunswick, New Jersey, November 29, 2001
  • "Selected Tax Traps in International Tax Planning," Advanced International Taxation - Strategic Planning, Executive Enterprise Institute, New York, New York, November 14, 2001
  • "U.S. Taxation of Foreign Corporations and Nonresident Aliens," Introduction to International Taxation - Conceptual Bootcamp, Executive Enterprise Institute, New York, New York, November 13, 2001
  • "Understanding the New Withholding Tax Regime," Alliance for Tax, Legal and Accounting Seminars, New York, New York, November 8, 2001
  • "Selected Tax Traps in International Tax Planning," Advanced International Taxation - Strategic Planning, Executive Enterprise Institute, Chicago, Illinois, October 18, 2001
  • "U.S. Taxation of Foreign Corporations and Nonresident Aliens," Introduction to International Taxation - Conceptual Bootcamp, Executive Enterprise Institute, Chicago, Illinois, October 16, 2001
  • Keynote Address, "Overview of International Taxation," Introduction to International Taxation - Conceptual Bootcamp, Executive Enterprise Institute, Chicago, Illinois, October 15, 2001
  • "Passive Foreign Investment Companies and Foreign Personal Holding Companies," Introduction to International Taxation, New York University Summer Institute in Taxation, New York, New York, July 18, 2001
  • "International Taxation," International Operations: Financial Reporting & Analysis, Executive Enterprise Institute, New York, New York, May 7, 2001
  • "Selected Tax Traps in International Tax Planning," Advanced International Taxation - Strategic Planning, Executive Enterprise Institute, New York, New York, May 2, 2001
  • "U.S. Taxation of Foreign Corporations and Nonresident Aliens," Introduction to International Taxation - Conceptual Bootcamp, Executive Enterprise Institute, New York, New York, May 1, 2001
  • 2000
  • "International Taxation," International Operations: Financial Reporting & Analysis, Executive Enterprise Institute, New York, New York, December 4, 2000
  • "Overview of International Tax," 40th Annual Philadelphia Tax Conference, Philadelphia, Pennsylvania, November 10, 2000
  • "Uses and Abuses of 80/20 Companies," International Tax Association, New York, New York, November 6, 2000
  • "U.S. Taxation of Foreign Corporations and Nonresident Aliens," Introduction to International Taxation - Conceptual Bootcamp, Executive Enterprise Institute, New York, New York, October 18, 2000
  • "Effective Use of Tax Treaties," Introduction to U.S. International Tax, Alliance for Tax, Legal and Accounting Seminars, Philadelphia, Pennsylvania, October 12, 2000
  • "Selected Tax Traps in International Tax Planning," Advanced International Taxation - Strategic Planning, Executive Enterprise Institute, Chicago, Illinois, October 5, 2000
  • "U.S. Taxation of Foreign Corporations and Nonresident Aliens," Introduction to International Taxation - Conceptual Bootcamp, Executive Enterprise Institute, Chicago, Illinois, October 3, 2000
  • Keynote Address, "Overview of International Taxation," Introduction to International Taxation - Conceptual Bootcamp, Executive Enterprise Institute, Chicago, Illinois, October 2, 2000
  • "Passive Foreign Investment Companies and Foreign Personal Holding Companies," Introduction to International Taxation, New York University Summer Institute in Taxation, New York, New York, July 17, 2000
  • "E-Volution: Business and Legal Practices for the New Economy," Duane Morris & Heckscher LLP and PricewaterhouseCoopers LLP, New York, New York, May 18, 2000
  • 1999 & Prior
  • "U.S. International Taxation of Financial Income: Inbound," International Taxation of Financial Products, Executive Enterprise Institute and The Bank Institute, New York, New York, October 21, 1999
  • "U.S. Taxation of Foreign Corporations and Nonresident Aliens," Introduction to International Taxation - Conceptual Bootcamp, Executive Enterprise Institute, New York, New York, October 13, 1999
  • Panel Moderator, "Constructing Tax Policy for the Web," TRANSACT Tax Conference, Philadelphia Bar Association, Philadelphia, Pennsylvania, September 30, 1999
  • "Managing the Worldwide Effective Tax Rate - U.S. Tax Perspective," Tax Issues: International Mergers and Acquisitions, Executive Enterprise Institute and The World Trade Institute of Pace University, New York, New York, June 23, 1999
  • "General Introduction to International Taxable Acquisitions and Divestitures," Tax Issues: International Mergers and Acquisitions, Executive Enterprise Institute and The World Trade Institute of Pace University, New York, New York, June 22, 1999
  • The ABC's of International Tax," Pennsylvania Bar Institute Continuing Legal Education Series, Philadelphia, Pennsylvania, May 19, 1999
  • "U.S. Taxation of Foreign Corporations and Nonresident Aliens," Introduction to International Taxation, Executive Enterprise Institute and Practicing Law Institute, New York, New York, May 12, 1999
  • "U.S. Taxation of Foreign Corporations and Nonresident Aliens," Introduction to International Taxation, Executive Enterprise Institute and The World Trade Institute of Pace University, New York, New York, December 3, 1998
  • "Final Withholding Tax Regulations," International Fiscal Association - New York Chapter, New York, New York, November 1997