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, and certain specialized tax issues, such as blockchain and digital assets including conducting digital currency transactions and conversions, token offerings, and different investment and entity structures. 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. As a former in-house tax counsel and government attorney, 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 Senior Tax Counsel at General Electric. Prior to joining GE, she served in the Office Associate Chief Counsel (Corporate), where she worked on published guidance, controversy matters, private letter rulings, and tax policy matters concerning corporate and international tax transactions and issues.
Amie is a member of the ABA Sections of International Law and Tax (Corporate [officer] and Foreign Activities of U.S. Taxpayers [FAUST] [chair] Committees), International Fiscal Association (IFA), Women in IFA Network (WIN [Regional Co-Leader]), and Tax Coalition. She is a frequent speaker at the ABA, IFA, GW/IRS Conference, DC Bar, Federal Bar, International Tax Institute, and TEI on a multitude of transaction topics including cross-border 304 transactions, PTEP, BEAT (base erosion and anti-abuse tax), M&A, and digital currency.
The following represents experience acquired prior to joining Jones Day.
Represented General Electric Company as lead tax counsel in numerous transactions, including: the tax-free, split-off of Synchrony Financial valued at approximately $21 billion and the $1.65 billion acquisition of LM Wind Power.
Executed multiple restructurings including the carve-out of various GE Oil & Gas assets in furtherance of the joint venture with Baker Hughes and the separation of various GE Company industrial and GE Capital financial assets and subsequent disposition of certain GE Financial assets that resulted in GE Capital becoming the first financial institution to shed its designation as systemically important to the financial system and the integration of Alstom Power and Grid into GE Power.
- June 3, 2022
A Brave New Foreign Tax Credit World!, moderator, 50th Annual Conference of the USA Branch of the International Fiscal Association
- March 4, 2022
Domestic Corporate | Cross-Border M&A Developments
- February 1, 2022
Digital Assets – More than Just a Bitcoin Craze: Part I.
- January 31, 2022
Splits, Spins, Restructure or Do We Belong Together – M&A Current Developments Panel
- October 25, 2021
Current Issues and Trends in U.S. Outbound Taxation — Transactional Issues in an Uncertain Legislative Environment, TEIs 76th Annual Conference
- June 21, 2021
Cryptocurrency and Digital Transactions Tax Issues, 13th Annual U.S. and Latin America Tax Trends Conference
- March 5, 2021
International Tax Developments (Outbound) — Recently issued guidance applicable to PFICs, Federal Bar Association, Section on Taxation, 45th Annual Tax Law Conference
- March 4, 2021
Section 245A Update — Effect on US Shareholders in Cross-Chain Stock Sales, Federal Bar Association, Section on Taxation, 45th Annual Tax Law Conference
- 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)
International Fiscal Association (IFA), Women in IFA Network (WIN), D.C. Region Co-Leader
ABA Tax Section — Foreign Activities of US Taxpayers: Chair (2021 to present) and Vice Chair (2019 to 2021)
PepsiCo Chairman's Award — 2005