Amie Colwell Breslow practices across a broad range of U.S. federal tax matters, including cross-border mergers, acquisitions, spin-offs, and other divisive strategies and restructurings. She has extensive experience working with large multinational companies on managing and executing complex, multi-step reorganizations and divestures, developing workable policies at an industry-wide level in response to global economic policy initiatives and changes in foreign tax and corporate law, and advising clients on token offerings and entity structures. As a former in-house tax counsel and attorney at the Office of Associate Chief Counsel (Corporate), Amie blends substantive tax knowledge with an understanding of corporate objectives, and first-hand insights on the guidance and publications process.
Prior to joining Jones Day, Amie was a member of PwC's Global Structuring & Execution team and previously Senior Tax Counsel at General Electric in the Corporate Transactions group. Prior to GE, Amie served in the Office of Associate Chief Counsel (Corporate) at the IRS, where she worked on published guidance, controversy matters, technical advice memoranda, private letter rulings, and other tax policy matters concerning corporate and international tax transactions and issues.
Amie is a member of the American Bar Association Section of International Law and Tax Section (Corporate Tax Committee and Foreign Activities of U.S. Taxpayers [FAUST] Committee, vice chair). She frequently speaks on tax-related subjects, including section 245A, cross-border 304 transactions, and PTEP, BEAT, and M&A, including section 355 transactions, and repatriation, at the ABA, GW/IRS Conference, DC Bar, Federal Bar, International Tax Institute, and the Tax Executives Institute (TEI).
- October 20, 2020
The Final BEAT Regulations, International Tax Institute, Inc.
- July 2, 2020
Current Events Panel: Oh! The Places Your Attributes Will Go - Cross-Border 304s, 2020 Virtual Annual Meeting
- May 6, 2020
Revisiting the BEAT, American Bar Association
- January 30, 2020
Foreign Lawyers Forum and US Activities of Foreigners & Tax Treaties Joint Session, 2020 Midyear Tax Meeting, American Bar Association "Section 59A - BEAT Final Regulations"
- January 23, 2020
Corporate Taxation: Mergers and Acquisitions Update, 2020 Tax Legislative and Regulatory Update Conference "Cross-Border 304, PTEP, and Basis Issues"
- December 19, 2019
Panelist, Repatriation (PTI/245A)"Cross-Border 304, Section 245A, Basis, and PTEP Issues", 33rd Annual Institute on Current Issues in International Taxation, GW/IRS Conference
- October 3-4, 2019
Cross Border Partnership Theory and Panoply of Hot Topics: Section 168(k) Regulations, Where M&A and Section 245A Meet, Section 355 - No-Income-No Problem!, Cloud Regulations, and Other Current Developments!, 2019 Fall Tax Meeting, American Bar Association
- July 24, 2019
Corporate Mergers, Acquisitions, and Dispositions, TEI Federal Tax Course – Level 2: Reorganizations and Spin-Offs
Speaking Engagements Prior to Jones Day
American Bar Association, "Section 59A BEAT Proposed Regulations" January 18, 2019 New Orleans, LA
American Bar Association, Repatriation of Foreign Earnings: Real or Imagined, Voluntary or Otherwise. October 5, 2018 Fall Meeting Atlanta, GA
American Bar Association, "Mere Change": The New Final Section 368(a)(1)(F) Regulations", Mid-Year Meeting January 29, 2016 Los Angeles, CA
DC Bar "Recent Developments Concerning Section 355" Washington DC, February 12, 2013
American Bar Association, "Section 267(f) Final Regulations" May Meeting, May 2012
- American University (Certificate of Legal Studies in Anti-Corruption Law 2018); Brooklyn Law School (J.D. 1998); Syracuse University (B.S. in Accounting 1995)
- District of Columbia and New York
- Attorney-Advisor, Office of Associate Chief Counsel (Corporate), Internal Revenue Service (2009-2015)