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.
Published: TaxStringer, April 1, 2018
Published: TaxStringer, February 1, 2018
Foreign Corporation Not Taxable on Redemption of Partnership Interest: Tax Court Rejects Rev. Rul. 91-32by Michael J. Miller, Ellen Seiler Brody
Published: Tax Management International Journal, August 4, 2017
Published: Bloomberg BNA Daily Tax Report, August 3, 2017
Published: TaxStringer, August 1, 2017
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 Incomeby Michael J. Miller, Ellen Seiler Brody, Mark David Rozen
Published: R&H Letter to Clients and Friends, July 24, 2017