McDermott Will & Emery LLP

Tax/US & International Tax

Caroline H. Ngo is co-leader of the Firm’s International Tax Affinity Group and is based in Washington, DC. She advises publicly traded companies on international tax planning, cross-border mergers and acquisitions, application of bilateral income tax treaties, and other international tax matters. Since the passage of the Tax Cuts and Jobs Act of 2017 (TCJA), a substantial portion of Caroline’s practice has been advising clients on the new international tax provisions, including the new foreign tax credit regime (including expense apportionment), the GILTI regime, the participation exemption under section 245A, the BEAT, and the transition tax under section 965. Caroline recently served as lead counsel in a significant litigation in the US Tax Court, and her team secured a complete victory for the client.

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