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 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 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.

She received a B.S. magna cum laude from the Wharton School of the University of Pennsylvania, and her J.D. cum laude and LL.M (Taxation) from New York University, where she was Note and Comment Editor of the Law Review. She is also a Certified Public Accountant.

The New Qualified Business Income Deduction Under IRC Section 199A

by Ellen Seiler Brody
Published: TaxStringer, April 1, 2018
Download this File.

The Tax Cuts and Jobs Act - Traps for the Unwary Accountant

by Ellen Seiler Brody
Published: TaxStringer, February 1, 2018
Download this File.

Foreign Corporation Not Taxable on Redemption of Partnership Interest: Tax Court Rejects Rev. Rul. 91-32

by Michael J. Miller, Ellen Seiler Brody
Published: Tax Management International Journal, August 4, 2017
Download this File.

Reliance on a CPA As Reasonable Cause: "Neanatology" Lives on After "Grecian Magnesite Mining"

by Ellen Seiler Brody, Michael J. Miller
Published: Bloomberg BNA Daily Tax Report, August 3, 2017
Download this File.

Is New York Overreacting on Audit and Litigation of Federal Issues?

by Joseph Lipari, Ellen Seiler Brody
Published: TaxStringer, August 1, 2017
Download this File.

Tax Court Rejects Revenue Ruling 91-32 -- Holds Greek Corporation's Gain from the Redemption of Its Partnership Interest Not To Be Taxable as Effectively Connected Income

by Michael J. Miller, Ellen Seiler Brody, Mark David Rozen
Published: R&H Letter to Clients and Friends, July 24, 2017
Download this File.

Expats Live in Fear of Malevolent Time Machine

by Michael J. Miller, Ellen Seiler Brody
Published: International Tax Journal, March 5, 2013
Download this File.

IRS Provides Detailed Guidance on 2012 Offshore Voluntary Disclosure Program and Announces New Alternative Procedure for Certain Taxpayers Living Abroad

by Michael J. Miller, Richard A. Levine, Howard J. Levine, Mark David Rozen, Ellen Seiler Brody
Published: R&H Letter to Clients and Friends, July 3, 2012
Download this File.

Foreign Asset Reporting Under Code Section 6038D

by Michael J. Miller, Ellen Seiler Brody
Published: International Tax Journal, May-April, 2012
Download this File.

New Proposed Regulations Provide Some Welcome Relief for Foreign Financial Institutions under FATCA

by Mark David Rozen, Ellen Seiler Brody, Libin S. Zhang
Published: BNA Tax Planning International Review, March 01, 2012
Download this File.

An Absolute Provision Is Not Always So Absolute, Revisted -- En Banc Rehearing Brings Common Sense Back

by Ellen Seiler Brody
Published: Journal of Taxation, January 01, 2012
Download this File.

The New Voluntary Disclosure: No, It's Not For Those Hidden Foreign Bank Accounts -- This Time It's For Employers Who Need to Reclassify Their Workers As Employees

by Norman J. Misher, Allen J. Erreich, Ellen Seiler Brody
Published: R&H Letter to Clients and Friends, October 19, 2011
Download this File.

The 2011 OVDI: Is Voluntary Disclosure Really Better the Second Time Around?

by Michael J. Miller, Ellen Seiler Brody
Published: Tax Management International Journal, May 13, 2011
Download this File.

The Requirement For a Deficiency Notice -- When an Absolute Provision Is Not Always Absolute

by Ellen Seiler Brody
Published: Journal of Taxation, August 01, 2010
Download this File.

Should Retirees Still Consider Expatriating?

by Ellen Seiler Brody
Published: Journal of Retirement Planning, May 01, 2009
Download this File.

Proposed Legislation Affecting Assets Held Overseas

by Mark David Rozen, Ellen Seiler Brody
Published: Rothschild Trust Review, April 01, 2009
Download this File.

U.S. Adopts Exit Tax Upon Expatriation

by Ellen Seiler Brody
Published: BNA Tax Planning International Review, December 16, 2008
Download this File.

Expenditure Deductions: The Right Track for Capitalization of Costs

by Ezra Dyckman, Ellen Seiler Brody
Published: New York Law Journal, February 26, 2003
Download this File.

New U.S. Withholding Rules for Hybrids and Passthroughs

by Ellen Seiler Brody, Peter A. Glicklich
Published: Canadian Tax Journal, June 01, 2000

Rules for Product Liability Losses for Consolidated Groups

by Elliot Pisem, Ellen Seiler Brody
Published: New York Law Journal, April 20, 2000
Download this File.

Update of Recent Actions by U.S. Taxing Authorities

by Ellen Seiler Brody, Peter A. Glicklich
Published: Canadian Tax Journal, March 01, 2000

Important New Rules on QSubs

by Elliot Pisem, Ronald A. Morris, Ellen Seiler Brody
Published: R & H Letter to Clients & Friends, February 28, 2000

Bankruptcy Code Trumps Internal Revenue Code

by Elliot Pisem, Ellen Seiler Brody
Published: New York Law Journal, December 24, 1998
Download this File.

Electronic Commerce: Taxation of Services Provided via the Internet

by Sanford H. Goldberg, Howard J. Levine, Ellen Seiler Brody, Peter A. Glicklich
Published: R & H Newsletter -- Tax Insights, October 01, 1997

Electronic Services: Suggesting a Man-Machine Distinction

by Howard J. Levine, Sanford H. Goldberg, Ellen Seiler Brody, Peter A. Glicklich
Published: Journal of Taxation, August 15, 1997

Employee Sells a Home and Employer Gets a Tax Deduction

by Elliot Pisem, Ellen Seiler Brody
Published: New York Law Journal, June 26, 1997
Download this File.

Continuity of Interest Rules May Be Liberalized -- But Can Remain a Trap for the Unwary

by Elliot Pisem, Ellen Seiler Brody
Published: New York Law Journal, February 27, 1997
Download this File.