Ellen Seiler Brody, for more than 20 years, has represented U.S. and international clients on complex transactions. Working with multinational corporations, high net worth individuals, and foreign governments, she has created tax-efficient structures to hold their investments and operating business activities. She also works with private equity and hedge funds in structuring their operations and investments. She has advised on the taxation of financial instruments, including the application of straddle and swap rules and management of interest rate risk. She has been involved in numerous tax controversy matters at both the federal and state and local levels, representing large multinational corporations and high net wealth individuals in a wide variety of industries, ranging from manufacturing to financial services. Her experience with New York State and City tax litigation has included Personal Income, Corporate Franchise, General Corporation, UBT, and Real Property Transfer taxes.
LL.M (Taxation), New York University
J.D., New York University, cum laude
B.S., University of Pennsylvania Wharton School of Business, magna cum laude
Ellen is also a Certified Public Accountant.
Bloomberg Tax Management Portfolios
The Portfolio, Transferee Liability, analyzes the application of §6901 and related judicial interpretations.
The Portfolio, Tax Court Litigation, discusses the issues raised when a case is initiated and tried before the United States Tax Court.
The Portfolio, Refund Litigation, analyzes the process of filing and litigating a refund suit in a federal district court or the Court of Federal Claims.
The Portfolio, Qualified Business Income Deduction: Section 199A, No. 537, discusses a new provision of the Internal Revenue Code, §199A, which provides a 20% deduction for qualified
This Bloomberg Tax Portfolio examines the statutes of limitations on assessment and collection and reviews the procedural aspects of the tax laws.