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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.

by Ellen Seiler Brody
Published: TaxStringer, April 1, 2018
Download the file for The New Qualified Business Income Deduction Under IRC Section 199A.
by Ellen Seiler Brody
Published: TaxStringer, February 1, 2018
Download the file for The Tax Cuts and Jobs Act - Traps for the Unwary Accountant.
by Michael J. Miller, Ellen Seiler Brody
Published: Tax Management International Journal, August 4, 2017
Download the file for Foreign Corporation Not Taxable on Redemption of Partnership Interest: Tax Court Rejects Rev. Rul. 91-32.
by Ellen Seiler Brody, Michael J. Miller
Published: Bloomberg BNA Daily Tax Report, August 3, 2017
Download the file for Reliance on a CPA As Reasonable Cause:
by Joseph Lipari, Ellen Seiler Brody
Published: TaxStringer, August 1, 2017
Download the file for Is New York Overreacting on Audit and Litigation of Federal Issues?.
by Michael J. Miller, Ellen Seiler Brody, Mark David Rozen
Published: R&H Letter to Clients and Friends, July 24, 2017
Download the file for 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
Published: International Tax Journal, March 5, 2013
Download the file for Expats Live in Fear of Malevolent Time Machine.
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 the file for IRS Provides Detailed Guidance on 2012 Offshore Voluntary Disclosure Program and Announces New Alternative Procedure for Certain Taxpayers Living Abroad.
by Michael J. Miller, Ellen Seiler Brody
Published: International Tax Journal, May-April, 2012
Download the file for Foreign Asset Reporting Under Code Section 6038D.
by Mark David Rozen, Ellen Seiler Brody
Published: BNA Tax Planning International Review, March 01, 2012
Download the file for New Proposed Regulations Provide Some Welcome Relief for Foreign Financial Institutions under FATCA.
by Ellen Seiler Brody
Published: Journal of Taxation, January 01, 2012
Download the file for An Absolute Provision Is Not Always So Absolute, Revisted -- En Banc Rehearing Brings Common Sense Back.
by Norman J. Misher, Allen J. Erreich, Ellen Seiler Brody
Published: R&H Letter to Clients and Friends, October 19, 2011
Download the file for 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 Michael J. Miller, Ellen Seiler Brody
Published: Tax Management International Journal, May 13, 2011
Download the file for The 2011 OVDI: Is Voluntary Disclosure Really Better the Second Time Around? .
by Ellen Seiler Brody
Published: Journal of Taxation, August 01, 2010
Download the file for The Requirement For a Deficiency Notice -- When an Absolute Provision Is Not Always Absolute.
by Ellen Seiler Brody
Published: Journal of Retirement Planning, May 01, 2009
Download the file for Should Retirees Still Consider Expatriating?.
by Mark David Rozen, Ellen Seiler Brody
Published: Rothschild Trust Review, April 01, 2009
Download the file for Proposed Legislation Affecting Assets Held Overseas.
by Ellen Seiler Brody
Published: BNA Tax Planning International Review, December 16, 2008
Download the file for U.S. Adopts Exit Tax Upon Expatriation.
by Ezra Dyckman, Ellen Seiler Brody
Published: New York Law Journal, February 26, 2003
Download the file for Expenditure Deductions: The Right Track for Capitalization of Costs.
by Ellen Seiler Brody, Peter A. Glicklich
Published: Canadian Tax Journal, June 01, 2000
by Elliot Pisem, Ellen Seiler Brody
Published: New York Law Journal, April 20, 2000
Download the file for Rules for Product Liability Losses for Consolidated Groups.
by Ellen Seiler Brody, Peter A. Glicklich
Published: Canadian Tax Journal, March 01, 2000
by Elliot Pisem, Ronald A. Morris, Ellen Seiler Brody
Published: R & H Letter to Clients & Friends, February 28, 2000
by Elliot Pisem, Ellen Seiler Brody
Published: New York Law Journal, December 24, 1998
Download the file for Bankruptcy Code Trumps Internal Revenue Code.
by Sanford H. Goldberg, Howard J. Levine, Ellen Seiler Brody, Peter A. Glicklich
Published: R & H Newsletter -- Tax Insights, October 01, 1997
by Howard J. Levine, Sanford H. Goldberg, Ellen Seiler Brody, Peter A. Glicklich
Published: Journal of Taxation, August 15, 1997
by Elliot Pisem, Ellen Seiler Brody
Published: New York Law Journal, June 26, 1997
Download the file for Employee Sells a Home and Employer Gets a Tax Deduction.
by Elliot Pisem, Ellen Seiler Brody
Published: New York Law Journal, February 27, 1997
Download the file for Continuity of Interest Rules May Be Liberalized -- But Can Remain a Trap for the Unwary.