International Tax Conference 2025 IN PERSON

Carly Doshi, Managing Director, HSBC Bank USA N.A

Carly is Head of Wealth Planning & International Connectivity with HSBC Private Banking, based in New York City. In her role, Carly leads a team of subject matter experts, including former practicing lawyers and accountants, who provide wealth planning and thought leadership on a wide array of planning topics, including multi-generation wealth transfer, business succession, philanthropy, family office structuring, and family governance strategies. She works directly with the firm’s most sophisticated clients and their legal and tax professionals, and prides herself on a client-led, bespoke approach to planning advice delivery.

Christopher Saddock, Shields Legal Group

Chris Saddock, JD, LLM Taxation, practices business and individual tax planning for high-net-worth individuals and closely-held corporations and partnerships. Chris has an extensive history serving private clients as a tax and business adviser by preparing and implementing complex business and holding structures, as well as maximizing tax efficiencies and ensuring compliance. His areas of practice include U.S. passthrough entity planning, U.S. trust and estate tax planning, mergers and acquisitions, fund formation, startups, cryptocurrency, and international income and estate tax planning.

Darek Jarski

Mr. Jarski represents clients in a wide range of tax controversy matters before the Internal Revenue Service. Mr. Jarski also assists clients with international tax and information return compliance matters.His cases include, but are not limited to, complex IRS audits, challenging Trust Fund Recovery Penalty assessments, and offshore and domestic voluntary disclosures, non-filers, IRS collection cases, penalty abatements, employment tax matters, refund claims, ESRP/Sec. 4980H matters, criminal tax matters, domestic and international information return matters.

Mr. Jarski joined a boutique tax controversy law firm in 2003 after having completed the Masters of Law in Taxation program at New York University. While at NYU, he focused on business taxation, with an emphasis on corporate reorganizations and partnership taxation.

Prior to attending NYU, he graduated magna cum laude from Gonzaga University School of Law in Spokane, Washington. While at Gonzaga, he interned with United States Attorney’s Office for the Eastern District of Washington.

Mr. Jarski speaks Polish and studied German and Russian. In his free time, he enjoys snow skiing, cycling, and spending time with his wife and two children.

Emma Raivio, Tax Manager, VSH, PLLC

After graduating from Western Washington University in 2019, Emma joined the VSH team in 2020 as a Staff Accountant. Emma is a dedicated member of VSH’s International department and excels in her work. Now serving as a Tax Manager, she specializes in helping international and cross-border businesses address their intricate accounting, taxation, and business planning requirements. Emma especially enjoys helping clients have a meaningful understanding behind the numbers.

Emma found a passion for accounting at an early age, and her natural curiosity led her to discover that accounting principles can be applied to many different aspects of life. She is also driven by her love of learning and is always looking for ways to expand her knowledge and apply that knowledge practically. She truly enjoys the accounting profession and that translates into her determination to do her absolute best for clients.

Eric Kodesch, Ballard Spahr (Portland)

Eric Kodesch counsels clients on a wide array of federal income tax, and state and local tax issues in both transactional and litigation matters, including general business planning, structuring investments to obtain opportunity zone benefits, financial transactions, trust taxation, executive compensation, and choice of entity issues. Eric also assists clients with payroll protection program (PPP) loan issues and other CARES Act issues. For state and local matters, Eric assists clients with obtaining tax incentives such as property tax exemptions for new investments and in resolving audits, even when litigation is necessary. He provides experience in navigating these friendly or adversarial situations. Eric also regularly represents clients in the Oregon Tax Court in controversies involving Oregon corporation excise tax and property tax.

Helen Cheng, Partner, Withers Worldwide (San Francisco)

Helen S. Cheng is a partner in the private client and tax team at the international law firm, Withers. Helen is the office managing director of the firm’s San Diego location. She is a trusts and estates attorney who focuses on exempt organizations and international tax planning for inbound and outbound transactions. She assists clients in all aspects of estate planning, estate and trust administration and charitable planning.

Jennifer Silvius, Withers Worldwide (San Francisco)

Jennifer Silvius is an international estate planning associate in the private client and tax team at Withers in San Francisco. Prior to joining Withers, Jennifer was worked at a boutique Canadian tax firm based in Calgary, Alberta which specialized in cross-border tax planning between the US, Canada and Australia. She provides US international income, trusts and estate tax planning for high net worth individuals and family businesses and advises trustees, executors, fiduciaries and beneficiaries on cross-border probate tax filing positions, estate administration and US expatriation options. She provides tax advisory guidance for foreign investors, founders and entrepreneurs deriving income from US-based sources and operations, as well as foreign legal, financial and tax advisors on the US taxation of foreign pensions and retirement arrangements, US-based investments and exit strategies for corporate executives, global employees and US persons living abroad.

Jennifer has published tax technical papers that have been presented to the tax-writing committees of the US Congress and the US Treasury Department on the US taxation of foreign pensions and retirement, cross-border estates and trusts between the US, Canada and Australia.

She received her LL.M. in Taxation from University of Florida, Fredric G. Levin College of Law, her J.D. from Charlotte School of Law and her B.A. from University of Alberta. She is licensed to practice in California, New York and North Carolina.

Jordan Reichelt, Partner, Spott Lucey & Wall Seattle

Jordan Reichelt, CPA, is a Partner at Spott, Lucey & Wall, a CPA firm specializing in international tax and cross-border issues. His clients include many investors and entrepreneurs in the real estate, technology, and creative sectors and businesses from around the world. Jordan has developed a special focus on state and local compliance services for multinational businesses and issues involving international trusts and estates. He leads Spott, Lucey & Wall’s Seattle office and is a frequent speaker on international tax topics including GILTI, subpart F, and other CFC issues.

Marsha Dungog, Withers Worldwide (San Francisco)

Marsha Laine Dungog is an international estate planning partner in the private client and tax team at Withers. Based in the firm’s San Francisco office, she provides US international income, trusts and estate tax planning for high net worth individuals and family businesses with respect to their global assets, investments and activities, with an emphasis on US, Canada and Australia. She is also licensed to practice law in both the United States and Canada and leads the firm’s US-Canada cross border tax and estate planning practice. She also advises trustees, executors and fiduciaries as well as financial, tax and legal advisors on international tax exposures and reporting obligations for beneficiaries and heirs of trusts and estates with US connections. Marsha’s practice includes US tax planning for foreign investors, founders and entrepreneurs deriving income from US-based sources and operations, as well as tax advisory services for foreign legal, financial and tax advisors on the US taxation of foreign pensions and retirement arrangements, US-based investments and exit strategies for corporate executives, global employees and US persons living abroad.

Marsha is an author and frequent speaker on international tax issues. She has published tax technical papers that have been presented to the tax-writing committees of the US Congress and the US Treasury Department on the US taxation of Australian Superannuation Funds, Mexican AFOREs and Canadian registered plans (RESPs and RDSPs). She has also spoken at international conferences and seminars in the US, Canada and Australia on the US taxation of foreign pensions and retirement, cross-border estates and trusts, international withholding and compliance enforcement initiatives, IRS voluntary disclosure programs and U.S. expatriation and green card termination alternatives. Prior to joining Withers, Marsha was the West Coast International Tax director at a global accounting firm’s office in San Francisco, and was a director at a boutique cross-border tax law firm based in Calgary, Alberta. Marsha is a public arbitrator for the US Financial Industry Regulatory Authority (FINRA) and has taught US international tax courses as an instructor for the American Institute of Certified Public Accountants (AICPA).

Marsha has been recognized in the Chambers High Net Worth Guide in the area of Private Wealth Law – Northern California since 2022. She is also recognized as a recommended lawyer in The Legal 500 US guide in 2024 in the area of International Tax. She was also named “Woman of Inspiration” (Authentic Leader Category) by the Canadian Business Chicks in 2018 and “Woman to Watch” (Experienced Leader Category) by the California Society of CPAs in 2020.

Mehrdad Ghassemieh, Harlowe & Falk LLP

Mehrdad Ghassemieh is a partner at Harlowe & Falk LLP. Mehrdad’s practice includes assisting clients of all sizes on domestic and international matters. This includes consulting with international business owners regarding the tax implications related to establishing new business entities, succession planning, and mergers and acquisitions. His clients include both U.S. based companies that have expanded abroad and foreign companies with U.S. ties. While helping clients in the setup of international structures, Mehrdad routinely helps clients find solutions to Subpart F and taxation on CFCs, taxation of PFICs, foreign tax credit planning, cross border withholding tax and attaining tax treaty benefits. Mehrdad also consults with U.S. based exporting companies to determine whether they qualify for IC-DISC tax incentive benefits, and assists in both implementation and maintenance of IC-DISC structures. Mehrdad is an adjunct professor at the University of Washington School of Law, where he teaches a class in advanced international taxation planning in the law school’s masters in tax program. He is also an adjunct professor at Golden Gate University, in the Masters in Tax Program.

Namir Hallak, Andersen LLP

Namir Hallak, CPA, CA, CPA (Kansas), CGMA, is a Vancouver, BC-based Tax Partner at Andersen with over 20 years of experience in cross-border tax compliance and planning for multinational Canadian and U.S. corporations. He specializes in advising businesses through international expansion, providing strategic tax insights on cross-border operations, investments, and mergers & acquisitions.

Philip Hodgen, HodgenLaw PC

Philip D. W. Hodgen is the principal attorney for Hodgen Law Group, which specializes in the international tax arena. He earned his undergraduate degree from Claremont McKenna College and his law degree from the School of Law at the University of California, Los Angeles. He then went on to earn a Master of Laws degree with a specialty in taxation from the University of San Diego School of Law.

Admitted to the California bar in 1982, Mr. Hodgen spent nine years in law firms and with a large U.S. bank before starting his own firm in 1991. For six years of his youth, he lived in Rhodesia, South Africa and New Zealand. Mr. Hodgen is a past chair of the International Tax Committee of the State Bar of California’s Tax Section and was a member of the Executive Committee of the State Bar of California’s Tax Section for 2004-2007.

Mr. Hodgen frequently speaks on a variety of international tax, trust and estate topics to attorneys, accountants, real estate professionals and other groups.

Roy Deaver III, Partner, Moss Adams LLP (Consulting Group)

Roy Deaver is a Partner in Moss Adams’ Seattle office. He has over 14 years experience in providing tax services to his clients, the last eight focusing on international tax matters. Roy has worked in both public accounting and in industry allowing him to provide practical tax advice to his clients. Roy has worked closely with his clients to optimize the worldwide effective tax rate and to reduce foreign taxes through, tax-efficient financing, efficient cash management, repatriation of earnings to the U.S., and transfer pricing analysis. Roy has assisted clients in both acquisition and divestiture structuring and in entry into new markets. Additionally, Roy has an extensive background in FAS 109 and its application to foreign subsidiaries.