Lori Hellkamp provides creative solutions to complex tax issues by taking a practical approach to problem solving. Her practice spans a broad range of areas, including corporate and international tax, M&A, and tax controversy. Lori's practice has a particular emphasis on international tax planning, counseling, and compliance as well as tax-efficient structuring for cross-border transactions and investments. Lori has extensive experience helping clients address issues arising from foreign (inbound) investments into the United States and in the fintech sector. She also regularly advises clients on tax and structuring issues related to cryptocurrencies, NFTs (non-fungible tokens), and other digital assets.
Lori has counseled public and private companies facing a wide variety of multijurisdictional tax issues, both internally and before the Internal Revenue Service. She has helped clients obtain favorable private letter rulings and advance pricing agreements, resolve disputes at Appeals and in Competent Authority proceedings, and navigate complex tax treaty, transfer pricing, withholding, FIRPTA (Foreign Investment in Real Property Tax Act), anti-boycott, and international tax reform issues.
Lori is a board member of the George Washington University-IRS International Annual Tax Institute, an adjunct professor of international taxation at American University, and the former chair of the ABA Tax Section's Committee on US Activities of Foreigners & Tax Treaties (USAFTT). Lori is also a member of the ABA's task force on cryptocurrency and is the hiring partner for the Washington Office of Jones Day.
Expérience
Autres publications
- August 2021
Demystifying the Saving Clause and Re-Sourcing Rules in Treaties, Tax Notes and Tax Notes International - June 2020
It's Time to Look Again at the Anti-Hybrid Rules, Tax Notes Federal and Tax Notes International - July 5, 2019
Virtual Money (or Property), With Real-World Tax Implications, Corporate Counsel Business Journal - February 2019
Brexit and NAFTA Demise Could Jeopardize U.S. Treaty Benefits, Tax Notes International
Interventions
- November 14, 2023
Troubled Companies: Pitfalls and Opportunities, NYU Institute of Federal Taxation - November 13, 2023
International M&A: US Tax Considerations and Planning, NYU Institute of Federal Taxation - June 14, 2023
Blockchain, Cryptocurrency and the New Frontier, ABA Annual US & Latin America Tax Practice Trends Conference - March 30, 2023
The Role of Competent Authority and Double Taxation Resulting from DSTs, Minimum and Other Taxes, US and Europe Tax Practice Trends Annual ABA Conference - February 10, 2023
International Information Exchange for Tax Controversy, 2023 ABA Midyear Tax Meeting - January 25 2023
Taxation of Cryptocurrency and Related Reporting Issues, DC Bar Annual Tax Legislative and Regulatory Update Conference - December 21, 2022
US Tax Treaties - What You Need to Know, Lorman Webinar - December 15, 2022
Foreign Tax Credit Developments, GWU-IRS Annual Institute on Current Issues in International Taxation - November 14, 2022
International Mergers & Acquisitions: U.S. Tax Considerations & Planning Techniques, 81st NYU Institute on Federal Taxation - October 25, 2022
Tax Considerations in FinTech, FinAccelerate - May 13-14, 2022
The Good, the Bad, the GILTI – OECD Pillar 2 & the U.S. GILTI Regime, 2022 Annual ABA Tax May Meeting - May 4, 2022
International Tax: Inbound Developments, DC Bar Annual Tax Legislative and Regulatory Update Conference - April 13, 2022
U.S. Income Tax Treaties and Claiming Treaty-Based Positions, Lorman Webinar - April 1, 2022
Where Did I Park My IP? Rewriting the ABCs of Taxation of Intellectual Property, ABA Annual Conference on US & Europe Tax Practice Trends - December 8, 2021
Pharma Tax Considerations in Strategic M&A, Joint Ventures, Co-development and Royalty Sales - October 19, 2021
Taxes and Cryptocurrency, Lorman Webinar - June 18, 2021
The Biden Administration's Tax Reform: Potential Impact on Australian Investment in the United States - March 23, 2021
Understanding and Applying Section 163(j), Tax Executives Institute Midyear Conference - January 14, 2021
Cross-Border Financing: Hybrid, 163(j) Interest Limitation and Other Tax Issues, DC Bar 2021 Tax Legislative and Regulatory Update Conference - October 28, 2020
GILTI and FDII Planning, 75th Annual TEI Conference. - October 2, 2020
Cross-border Hybrid Issues: The Final Section 267A and 245A(e) Regulations, ABA Virtual 2020 Fall Tax Meeting. - August 18, 2020
Partnership Reporting: New (Inbound) International Tax Provisions, IRS and Treasury Panel - June 30, 2020
Downward Attribution under Section 958 - New Guidance and Practical Considerations, Tax Executives Institute (TEI) Midyear Conference - May 12, 2020
Final and Proposed Regulations Addressing Hybrid Dividends, Hybrid Arrangements and Other Issues, DC Bar Association - December 19, 2019
GILTI – Updates and Selected Issues, George Washington University-IRS Annual Institute on Current Issues in International Taxation - December 5, 2019
Cryptocurrency Compliance Issues - December 4, 2019
The Ethics of Emerging Technologies - December 3, 2019
The Ethics of Emerging Technologies - October 4, 2019
IP in the New International Tax Landscape, ABA 2019 Fall Tax Meeting - June 14, 2019
The Effect of EU Information Disclosure Rules (DAC 6) and ATAD on Cross-Border Transactions with Latin America and the United States, ABA Annual U.S. and Latin America Tax Practice Trends - March 7, 2019
Impact of the TCJA and BEPS on Transfer Pricing Planning, Annual Federal Bar Association Tax Law Conference - December 14, 2018
Inbound developments in International Tax, George Washington University-IRS Annual Institute on Current Issues in International Taxation - May 11, 2018
Inbound U.S. Tax Issues Related to Tax Reform, ABA Section of Taxation May 2018 Meeting - March 9, 2018
Inbound Taxation and Tax Reform, Federal Bar Association Annual Meeting - March 9, 2018
Transfer Pricing Developments, Federal Bar Association Annual Meeting - February 8, 2018
The Tax Cuts and Jobs Act of 2017: How It Affects Your Business - February 7-8, 2018
The Tax Cuts and Jobs Act of 2017: How It Affects Your Business - December 12, 2017
International Tax Impact of Business Entity Selection for Foreign Operations of US Companies - October 30, 2017
Investment Structuring and Treaty Protection - September 26, 2017
Section 336(e) Elections: Tax Basis Step Up Through Deemed Asset Sale Treatment, Strafford Webinar - August 2, 2017
Common Cross-border Issues in M&A and Tax Planning, ABA Webinar - May 11-13, 2017
Common Cross-border Issues in M&A and Tax Planning, ABA Section of Taxation May 2017 Meeting - November 18, 2016
Tax Treaty Developments, International Bar Association, The New Era of Taxation: what you need to know in a constantly changing world - October 25, 2016
Recent Developments in Corporate Tax, Tax Executives Institute - May 7, 2016
Fundamentals of Tax Treaties and the Competent Authority, moderator, ABA Section of Taxation May 2016 Meeting - May 6, 2016
What’s New in the 2016 US Model Treaty?, ABA Section of Taxation May 2016 Meeting - April 27, 2016
International Tax Seminar for Detroit Chapter of Tax Executives Institute - August 14, 2014
Deal Structure in Mergers and Acquisitions (Tax-Free Reorganizations), American Management Association Course on Mergers and Acquisitions
- Georgetown University (LL.M. in Taxation 2011); Duke University (J.D. 2008); University of Oxford (M.Phil. 2005); Rice University (B.A. magna cum laude 2002)
- District of Columbia, New York, and U.S. Tax Court
- Legal Externship, Overseas Private Investment Corporation (2008)
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