Form 8833 Treaty-Based Return Position Disclosure: Claiming a Treaty-Based Position

Alden Dilanni-Morton

Jones Day

Alden DiIanni-Morton

• Works primarily in the areas of U.S. federal corporate taxation, assisting in advising clients on the tax aspects of complex transactions
• Drafted tax opinions and a variety of key deal documents and has helped clients navigate complex tax issues on a variety of transactions, including multijurisdictional mergers and acquisitions
• Prior to attending law school, Alden worked for Teach For China during its transition to the Teach For All network

Lori Hellkamp

Jones Day

• Partner at Jones Day in the Washington, D.C. office
• Provides commercial solutions to complex tax issues by taking creative and practical approaches to problem-solving
• Practice spans a broad range of areas, including corporate and international tax, M&A, and tax controversy
• Her practice has a particular emphasis on international tax planning, counseling, and compliance, as well as tax-efficient structuring for cross-border transactions and investments
• Has extensive experience helping clients address issues arising from foreign (inbound) investments into the United States and in the fintech and renewable energy sectors; in addition, she regularly advises clients on tax and structuring issues related to cryptocurrencies, NFTs (non-fungible tokens), and other digital assets
• Counseled public and private companies facing a wide variety of multijurisdictional tax issues, both internally and before the Internal Revenue Service; has helped clients obtain favorable private letter rulings and advance pricing agreements, resolve disputes at Appeals and in Competent Authority proceedings, and navigate complex tax treaty, transfer pricing, withholding, FIRPTA (Foreign Investment in Real Property Tax Act), anti-boycott, and U.S. tax reform issues
• Chair of the ABA Tax Section’s Committee on U.S. Activities of Foreigners & Tax Treaties (USAFTT) and a member of the ABA Tax Section’s task force on cryptocurrency; active member of the D.C. Bar and frequently speaks and publishes on a variety of tax topics; board member of the George Washington University-IRS International Annual Tax Institute and serves on Jones Day’s Recruiting Committee
• Can be reached at 202.879.3787 or [email protected]