Hope P. Krebs is an international tax partner, the co-chair of the firm's International Practice and a member of our Corporate Transparency Act Strategy Team. Prior to joining Duane Morris, Ms. Krebs was a senior manager of International Tax Services for Ernst & Young LLP and, prior to that, was associated with the New York office of another major national law firm.
Ms. Krebs is the co-author of a Bureau of National Affairs, Inc. Tax Management Portfolio titled 915-1 T.M. U.S. Income Tax Withholding - Foreign Persons and the author of numerous tax, corporate and international articles. She is a frequent speaker on international tax topics at tax conferences across the country.
Ms. Krebs is a past Chair of Multilaw, the preeminent global legal network of independent law firms with over 10,000 lawyers in more than 150 commercial centers around the world. She served on Multilaw's Management Committee and chaired a number of its key operational committees, including its Finance, Appraisals, Conferences and Pro Bono committees. Ms. Krebs has served as President of the British-American Business Council of Greater Philadelphia and continues to serve as a Board member of the organization and its Vice President of Strategic Direction. She is a member of the Planning Board for the annual Philadelphia Tax Conference.
Ms. Krebs is admitted to practice law in New York and Pennsylvania and before the U.S. Tax Court. She is listed in Chambers USA: America's Leading Lawyers for Business, Who's Who in American Law, Who's Who of American Women and Who's Who in Finance and Industry.
Ms. Krebs is a 1992 graduate of New York University School of Law (LL.M., taxation), a 1987 graduate of Villanova University School of Law (J.D.) and a graduate of Drexel University (B.S., Business Administration).
Representative Matters
Represented Certified Collectibles Group, a leading global provider of authentication, grading and conservation services, in its sale to funds managed by private equity firm Blackstone (NYSE: BX)’s Tactical Opportunities business, which valued the company at more than $500 million.
Represented Allevi, Inc., a manufacturer of 3D bioprinters and bioinks trusted by leading researchers worldwide, in the $9.5 million sale of its business to 3D Systems (NYSE: DDD), a provider of 3D printing and digital manufacturing solutions.
Represented Sports Reference LLC, a sports statistics data compilation company in its purchase of certain datasets for professional baseball, football, basketball and hockey from prominent aggregators Gary Gillette, Peter Palmer and Kenneth Pullis.
Represented MLP Ventures and real estate developer J. Brian O’Neill in the closing of a $144.6 million debt and equity financing to fund MLP Ventures’ purchase of the former GlaxoSmithKline Research & Development Center in Upper Merion, Pennsylvania, and to fund future operating costs, renovations, and leasing costs for prospective tenants moving into the center.
Represented DuPont (NYSE: DD), a global innovation leader with technology-based materials, in its $110 million acquisition of Evoqua’s Memcor business, which includes ultrafiltration and membrane bio-filtration technologies.
Represented a foreign family office in a $5 million Series C investment in a US-based leading global provider of parcel delivery software and hardware to businesses in the U.S. and Europe.
Represented YouVisit, LLC, a company that has created virtual tours of campuses for more than 600 educational institutions, in its sale to EAB, a portfolio company of Vista Equity Partners that provides research, enterprise technology, and data-enabled services for education institutions.
Represented an affiliate of Deerfield Management Company, L.P. in a $540 million acquisition financing for the purchase of an office building at 345 Park Avenue South, New York, New York and for the redevelopment of the building as office building with lab space; financing included three mortgage loans and a mezzanine loan.
Represented New Hampshire-based Unitil Corporation (NYSE: UTL) in its sale of $30 million aggregate principal amount of 3.70% senior notes to several well-known insurance companies.
Represented Iroko Pharmaceuticals, LLC in connection with a $140 million secured loan facility with CRG, a healthcare investment fund, and the simultaneous pay-off of Iroko's loan facility with another lender.
Represented the owners of a test engineering and technical staffing services company in its sale for $39 million.
Represented the owners of a furniture retailer with approximately 40 locations in several states in its sale for $42 million.
Represented an international public energy services company and its U.S. subsidiary based in Houston in the negotiation and documentation of an amended and restated $75 million senior secured revolving credit facility. Converted the credit facility from a single-lender facility to a $75 million syndicated credit agreement, extended its maturity, added a swingline loan facility and restructured the financial covenants and certain other provisions. Certain of the borrower's international affiliates guaranteed the obligations under the facility.
Advised concerning year-end multi-country corporate restructuring for South American investors of $72 million in real estate and other assets, which were located in six jurisdictions (France, Panama, Peru, Massachusetts, Florida and Colorado) and transferred to a new South American holding company.
Represented a public company in negotiating and documenting its Fourth Amended and Restated Credit Agreement with a syndicate of lenders, increasing the capacity under the senior secured revolving credit facility from $1.3 billion to $1.8 billion. The entire amount of the facility may be used for loans and letters of credit in certain non-U.S. currencies.
Represented a specialty chemical company in closing a $175 million credit facility, comprised of revolving credit, term loan, swing line and letters of credit sub-facilities. The credit agreement contains an accordion feature affording the client the right to increase the revolving credit facility size by $50 million.
Represented Voxx International Corporation in its $20 million acquisition, through Newco, a Delaware LLC, of 54 percent of the assets of EyeLock, Inc., a Puerto Rico corporation, and EyeLock Corporation, a Delaware corporation, and a wholly-owned subsidiary of EyeLock, Inc.
Represented Quanta Services, Inc. (NYSE: PWR) in the sale of five subsidiaries comprising its fiber optic licensing operations to Houston-based Crown Castle International Corp. (NYSE: CCI) for $1 billion in cash.
Acted as sole international legal counsel to JM Financial Securities Limited and Bajaj Finance Limited on Bajaj Finance Limited's Rs. 14.0 billion (US$222 million) sale of its shares in a QIP, including a concurrent private placement to QIBs in the United States.
Served as the sole international legal counsel on Capital First Limited's recent sale of Rs. 3,000 million (US $48 million) of its shares in a qualified institutional placement (QIP), including concurrent private placements in the United States and other jurisdictions outside India. The team represented Axis Capital Limited and JM Financial Institutional Securities Limited, the Book Running Lead Managers for the offering.
Represented Aurigene Discovery Technologies Limited in its collaboration, license and option agreement with Curis, Inc. for immuno-oncology and selected precision oncology targets.
Represented a public international energy services company and its U.S. subsidiary in Houston in the negotiation and documentation of a $50 million secured revolving credit facility.
Represented TÜV SÜD in its strategic acquisition of RCI Consultants Inc., located in Houston, Texas.
Represented Balchem Corporation in a $450 million syndicated credit facility led by Bank of America. (Nasdaq: BCPC)
Represented a private investment company focused on casino operators and suppliers in (i) rolling up its various gaming equipment finance businesses, (ii) completing a reverse takeover of a Canadian public shell company, and (iii) completing a public offering of $10 million of common stock and $10 million of secured convertible debentures.
Represented a Chicago-based private equity fund in the sale of a Michigan headquartered benefits payments processing services company to an Ohio-based private equity firm.
Represented a manufacturer of boilers, generators and heaters in its sale to a private equity company.
Represented Iroko Pharmaceuticals, a global specialty pharmaceutical company dedicated to advancing the science of responsible pain management, in securing $75 million in debt financing to support general business operations and the commercialization of Iroko's FDA-approved ZORVOLEX™ (diclofenac), a drug that uses iCeutica Inc.’s proprietary SoluMatrix Fine Particle Technology™ to both reduce the dosage of active ingredients ingested by the patient and accelerate the dissolution of the drug in the patient.
Represented a French CAC 40 company in connection with the sale of its wind-to-energy subsidiary for $81 million.
Represented a major French CAC 40 company as lender and guarantor in connection with a $230 million project syndicated loan to a wind energy project.
Represented the lender in obtaining a $55 million secured financing, consisting of U.S. and Dutch credit facilities, provided to a global transportation company.
Admissions
- Pennsylvania
- New York
- U.S. Tax Court
Education
- New York University School of Law, LL.M. - Taxation, 1992
- Villanova University Charles Widger School of Law, J.D., 1987
- Drexel University, B.S., Business Administration, 1984
Experience
- Duane Morris LLP, Philadelphia, Pennsylvania
- Partner, 1998-present
- Co-Chair, International Practice, 2001-present
- Member, Corporate Transparency Act Strategy Team, 2023-present
- Member, Recruitment and Retention Committee, 2000-2007 - Villanova University School of Law, Graduate Tax Program, Villanova, Pennsylvania
- Lecturer in Law, 1995-2007 - Ernst & Young LLP, Philadelphia, Pennsylvania
- Senior Manager, International Tax Services, 1997-1998 - Piper Marbury LLP (now known as DLA Piper), New York, New York
- Tax Attorney, 1995-1997 - Varet & Fink PC (formerly Milgrim, Thomajan & Lee PC), New York, New York
- Tax Attorney, 1990-1995 - Gordon Hurwitz Butowsky Weitzen Shalov & Wein, New York, New York
- Tax Attorney, 1987-1990
Professional Activities
Activities
Multilaw, the Multinational Association of Independent Law Firms
- Immediate Past Chair, 2017-2018
- Chair, 2015-2017
- Management Committee, 2014-2018
- Board of Directors, 2011-present
- Chair, Appraisals Committee, 2018-present
- Chair, Finance Committee, 2017-2018
- Chair, Future Conferences Committee, 2012-2015
- Chair, Pro Bono Mission, 2011-2015British-American Business Council of Greater Philadelphia
- President, 2011-2013
- Vice President, Strategic Direction 2021-Present
- Vice President, Membership, 2005-2011, 2014-2015
- Board of Directors, 2005-present- Philadelphia Tax Conference
- Planning Board and Executive Committee, 2001-present - Chair, "Transfer Pricing 101," Executive Enterprise Institute, Chicago, Illinois, June 20, 2013
- Chair, "International Tax Bootcamp," Executive Enterprise Institute, Chicago, Illinois, June 18-19, 2013
- Chair, "International Taxation Bootcamp," Executive Enterprise Institute, New York, New York, June 22-23, 2010
- Co-Chair, Fifth Annual Inbound Tax Conference, "Current U.S. Tax Planning Strategies for Foreign-Controlled U.S. Companies," Council for International Tax Education, New York, New York, May 13-15, 2002
- Chair, "Advanced International Taxation - Strategic Planning," Executive Enterprise Institute, Chicago, Illinois, October 17-18, 2001; October 4-5, 2000
- Chair, "Introduction to International Taxation - Conceptual Bootcamp," Executive Enterprise Institute, Chicago, Illinois, October 15-16, 2001; October 2-3, 2000
Associations
- International Fiscal Association
- American Bar Association
- Section of Taxation
-- Committee on U.S. Activities of Foreign Taxpayers
-- Committee on Foreign Activities of U.S. Taxpayers - New York State Bar Association
- Tax Section
-- Committee on U.S. Activities of Foreign Taxpayers
Honors and Awards
Listed in The Best Lawyers in America, 2020-2024
Listed in Chambers USA: America's Leading Business Lawyers, 2017-2024
Listed in Philadelphia Business Journal Best of the Bar: Top Lawyers in Philadelphia - Tax, 2018
- Listed in Marquis Who's Who in American Law
- Listed in Marquis Who's Who of American Women
- Listed in Marquis Who's Who in Finance and Industry
- AV Preeminent® Peer Review Rated by Martindale-Hubbell®
Selected Publications
- Co-author, "CTA Revived – Fifth Circuit Grants Temporary Stay of Nationwide Preliminary Injunction, FinCEN Provides Limited Filing Extensions," Duane Morris Alerts, December 24, 2024
- Co-author, "FinCEN Speaks – Posts Position to Comply with Texas Court's Preliminary Injunction of the Corporate Transparency Act While It Remains in Effect," Duane Morris Alert, December 9, 2024
- Co-author, "Corporate Transparency Act Enforcement Preliminarily Enjoined Nationwide – What It Means to Reporting Companies," Duane Morris Alert, December 5, 2024
- Co-author, "The CTA Filing Deadline Is Fast Approaching with Signs of Last-Minute Rush," Duane Morris Alert, October 15, 2024
- Co-author, "New York State Amends Its LLC Transparency Act, Pushes Back Effective Date," Duane Morris Alert, June 18, 2024
- Co-author, "The CTA at 150 Days - Prepare Now or Risk Noncompliance Penalties Later," Duane Morris Alert, May 31, 2024
- Co-author, "New York Law Requires Limited Liability Companies to Disclose Beneficial Ownership Information," Thomson Reuters Real Estate Finance Journal, Spring 2024
- Co-author, "Appeal Filed by Justice Department in Case Declaring Corporate Transparency Act Unconstitutional – To File or Not to File?" Duane Morris Alert, March 14, 2024
- Co-author, "Court Declares Corporate Transparency Act Unconstitutional – What Happens Now?" Duane Morris Alert, March 6, 2024
- Co-author, "Financial Services Industry Must Navigate the Russian Sanctions and Anti-Money Laundering Compliance Terrain as Treasury Signals Historic Enforcement Efforts," Duane Morris Alert, January 29, 2024
- Co-author, "Are You Exempt from Reporting Under the Corporate Transparency Act?" Duane Morris Alert, January 9, 2024
- Co-author, "As Year-End Approaches, So Too Does the Corporate Transparency Act's Effective Date," Duane Morris Alert, December 7, 2023
- Co-author, "New CHIPS Act Funding Opportunities Coincide with Expanded Semiconductor-Related Export Controls and Investment Restrictions," Duane Morris Alert, November 3, 2023
- Co-author, "Comments Due Soon on New Executive Order Curbing U.S. Investments in China Related to Sensitive Technologies," Duane Morris Alert, September 11, 2023
- Co-author, "Scrutiny of Foreign Investment in the United States Continues to Increase," Duane Morris Alert, August 23, 2023
- Co-author, "Deadline Nears for Filing the Mandatory Bureau of Economic Analysis 2022 BE-12 Survey," Duane Morris Alert, June 16, 2023
- Co-author, "New and Expanded U.S. Export Controls and Sanctions Against Russia and Belarus Create Additional Compliance Concerns for Companies," Duane Morris Alert, June 5, 2023
- Co-author, "Significant U.S. Sanctions Against Russia Create Challenges for Many Companies," Duane Morris Alert, March 3, 2022
- Co-author, "USTR Initiates New Section 301 Investigations Relating to Digital Services Taxes from Various Countries," Duane Morris Alert, June 10, 2020
Co-author (with Duane Morris colleague Thomas Ostrander), "Tax Litigation in the United States: Overview," Tax Litigation Global Guide (2018), Thomson Reuters
- Featured in "Not Ready for a Merger? Law Firm Networks Offer an Expansion Alternative," ABA Journal, June 1, 2017
- Quoted in "How Does a Foreign Buyer Get Around the Residency Requirements of Certain Countries?" Mansion Global, January 5, 2017
- "New Annual U.S. Tax Reporting Required for Foreign-Owned U.S. Limited Liability Companies and Other U.S. Business Entities," Duane Morris Alert, December 15, 2016
- Co-author, "Tech Start-Ups' Welcome to Philadelphia," Doing Business with Israel Legal and Business Guide, 2016
- Quoted in "Networks Competing with Big Firms Internationally," reprinted from The Lawyers Weekly July 15, 2016 issue.
- Co-author (with Duane Morris colleague, Thomas Ostrander), USA Chapter, Tax Litigation — A Global Guide from Practical Law, 2nd Ed 2016, Thomson Reuters (Professional) UK Limited
- Co-author, "Why Philadelphia is Perfect for Israeli Companies Looking to Enter the U.S. Market ," Philadelphia Business Journal, May 12, 2016
- Co-author, "IRS Proposes New U.S. Tax Reporting by Foreign-Owned U.S. Limited Liability Companies," Duane Morris Alert, May 18, 2016
- Featured in "How This International Lawyer Became the First Female Chair of a Global Legal Network," Philadelphia Business Journal, January 6, 2016
- Featured in "Duane Morris Partner Elected Chair of Multilaw," The Legal Intelligencer, November 4, 2015
- Co-author, "First-ever Tax Treaty and Protocol Between the United States and Vietnam Signed," Duane Morris Alert, July 15, 2015
- Quoted in "Inversions May Slow, but Related Legal Work Won't," The Legal Intelligencer, September 24, 2014
- Co-author, "House Ways and Means Committee Releases Proposal on Tax Reform," Duane Morris Alert, February 28, 2014
- Co-author (with Duane Morris colleague, Thomas Ostrander), USA Chapter, Tax Litigation — Jurisdictional Comparisons, 1st Ed 2013, Thomson Reuters- European Lawyer Reference Series
- Quoted in "Multilaw's Mission Pro Bono," Canadian Lawyer, August 21, 2012
- Quoted in "International Networking in Philadelphia—Kibitizing with Brits," Philadelphia Inquirer, December 15, 2011
- Co-author, "2009 – A Year of Increased Focus on International Tax Reporting," 68 New York University Institute on Federal Taxation, Volume 1, Chapter 3 (Matthew Bender 2010)
Co-author, "U.S. Accounts to Be Disclosed Under U.S.-Swiss Settlement Agreement," Practical US/International Tax Strategies, September 15, 2009
- Quoted in "Tax Benefits For US Shareholders In Foreign Mergers" by Claire Spencer, Financier Worldwide, July 2009
- Co-author, "By the Numbers — Coping with International Tax Reporting for International Matters," 67 New York University Institute on Federal Taxation, Volume 1, Chapter 15 (Matthew Bender 2009)
- Co-author, Tax Management Portfolio, 915-1 T.M., U.S. Income Tax Withholding - Foreign Persons
- Co-author, "Tax Consequences of Investing in the United States," Eighteen Chapters on American Law, a Primer for Taiwanese Investment in the United States, Chapter 3, 1993
Selected Speaking Engagements
2024
- Speaker, "The U.S. Corporate Transparency Act: What U.S. and Foreign Entities (and Their Advisors) Need To Do NOW to Address the Fast Approaching Filing Deadline," Duane Morris LLP, Webinar, July 17, 2024
2023
- Panel Co-Chair, “International Tax Update,” 34th Annual Philadelphia Tax Conference (co-sponsored by the American Bar Association Section of Taxation), Philadelphia, PA, November 14-15, 2023
2022
- Panel Chair, “International Tax Update,” 33rd Annual Philadelphia Tax Conference (co-sponsored by the American Bar Association Section of Taxation), Philadelphia, PA, November 14-15, 2022
2021
- Panel Chair, “International Tax Update,” 32nd Annual Philadelphia Tax Conference (co-sponsored by the American Bar Association Section of Taxation), Virtual, November 8-9, 2021
2020
- Panel Chair, “International Tax Update,” 31st Annual Philadelphia Tax Conference (co-sponsored by the American Bar Association Section of Taxation), Virtual, November 10, 2020
2018
"Passive Foreign Investment Companies," Introduction to International Taxation, New York University Summer Institute in Taxation, New York, New York, July 17, 2018
"Foreign Income & Asset Reporting After TCJA," Pennsylvania Society of Tax & Accounting Professionals, Philadelphia Tri-County Chapter, Springfield, PA, June 5, 2018
“Foreign Ownership of U.S. Residential and Investment Properties,” 14th Annual International Estate Planning Institute, co-sponsored by New York State Bar Association and Society of Trust and Estate Practitioners (STEP), New York, NY, March 22, 2018
2017
"Tax Considerations of Returning Capital to and From Australia, Austria, Brazil, Canada, China, Ireland, the UK and the USA,” 2017 International Bar Association Annual Conference, Sydney, Australia, October 12, 2017
“Passive Foreign Investment Companies,” Eisner Amper LLP Partners and Senior Tax Management, North Brunswick, NJ, May 16, 2017
2016
- "International Issues for Local Practitioners," Internal Revenue Service 2016 Eastern Pennsylvania Working Together Conference, Penn State Great Valley Conference Center, Malvern, Pennsylvania, May 18, 2016
2015
- "Challenges of International Tax Compliance Facing Accountants Today," Pennsylvania Society of Tax and Accounting Professionals, BuxMont Chapter, Horsham, Pennsylvania, September 29, 2015
- "Basics of International Tax Compliance," Introduction to International Taxation, New York University Summer Institute in Taxation, New York, New York, July 21, 2015
- "U.S. Taxation of Foreign Persons," Introduction to International Taxation, New York University Summer Institute in Taxation, New York, New York, July 20, 2015
- "International Issues for Local Practitioners," Internal Revenue Service 2015 Eastern Pennsylvania Working Together Conference, Penn State Great Valley Conference Center, Malvern, Pennsylvania, May 20, 2015
2014
- "Challenges of International Tax Compliance," Introduction to International Taxation, New York University Summer Institute in Taxation, New York, New York, July 22, 2014
- "U.S. Taxation of Foreign Persons," Introduction to International Taxation, New York University Summer Institute in Taxation, New York, New York, July 21, 2014
- "International Issues for Local Practitioners," Internal Revenue Service 2014 Eastern Pennsylvania Working Together Conference, Penn State Great Valley Conference Center, Malvern, Pennsylvania, May 22, 2014
- "By the Numbers – Coping with US Tax Reporting for International Matters," PA Society of Tax and Accounting Professionals, Philadelphia Tri-County Chapter, Springfield, Pennsylvania, May 21, 2014
2013
- "International Tax Issues," Business Tax Planning Guide, National Business Institute, Philadelphia, Pennsylvania, December 9, 2013
- "Passive Foreign Investment Companies," Introduction to International Taxation, New York University Summer Institute in Taxation, New York, New York, July 17, 2013
- "U.S. Taxation of Foreign Persons," Introduction to International Taxation, New York University Summer Institute in Taxation, New York, New York, July 15, 2013
- "Managing Passive Foreign Investment Company Exposure," International Tax Bootcamp, Executive Enterprise Institute, Chicago, Illinois, June 19, 2013
- "U.S. Tax issues for Foreign Taxpayers," International Tax Bootcamp, Executive Enterprise Institute, Chicago, Illinois, June 18, 2013
2012
- "Passive Foreign Investment Companies," Introduction to International Taxation, New York University Summer Institute in Taxation, New York, New York, July 25, 2012
- "U.S. Taxation of Foreign Persons," Introduction to International Taxation, New York University Summer Institute in Taxation, New York, New York, July 23, 2012
- "International Issues for Local Practitioners," Internal Revenue Service 12th Annual Eastern Pennsylvania Working Together Conference, Penn State Great Valley Conference Center, Malvern, Pennsylvania, May 17, 2012
2011
- "International Business Issues," Sax Macy Fromm's 7th Annual Bankers Breakfast, Hanover Marriot, Whippany, NJ, September 27, 2011
- "Passive Foreign Investment Companies," Introduction to International Taxation, New York University Summer Institute in Taxation, New York, New York, July 13, 2011
- "U.S. Taxation of Foreign Persons," Introduction to International Taxation, New York University Summer Institute in Taxation, New York, New York, July 11, 2011
- "International Issues and IRS Global High Wealth Industry Exam Program Panel," Internal Revenue Service 11th Annual Eastern Pennsylvania Working Together Conference, Philadelphia, Pennsylvania, May 18, 2011
2010
- "Passive Foreign Investment Companies," Introduction to International Taxation, New York University Summer Institute in Taxation, New York, New York, July 21, 2010
- "U.S. Taxation of Foreign Persons," Introduction to International Taxation, New York University Summer Institute in Taxation, New York, New York, July 19, 2010
- "A Primer on U.S. Taxation of Non-Residents and Foreign Corporations," International Taxation Bootcamp, Executive Enterprise Institute, New York, New York, June 23, 2010
- "U.S. Tax Issues in Structuring Foreign Operations," Council for International Tax Education (CITE) Annual Conference Series on U.S. International Tax Reporting & Compliance, Philadelphia, April 19-20, 2010
- "IRS Enforcement Initiatives - Planning and Coping Strategies for Accountants and their Clients with International Activities," Pennsylvania Institute of Certified Public Accountants - Greater Philadelphia Chapter, Philadelphia, PA, January 20, 2010
2009
- "By The Numbers - Coping with US Tax Reporting for International Matters," New York University 68th Institute on Federal Taxation, New York, New York, October 19, 2009
- "Passive Foreign Investment Companies," Introduction to International Taxation, New York University Summer Institute in Taxation, New York, New York, July 15, 2009
- "U.S. Taxation of Foreign Persons," New York University Summer Institute in Taxation, New York, New York, July 13, 2009
2008
- "By The Numbers - Coping with US Tax Reporting for International Matters," New York University 67th Institute on Federal Taxation, New York, New York, October 23, 2008
- "Passive Foreign Investment Companies," Introduction to International Taxation, New York University Summer Institute in Taxation, New York, New York, July 16, 2008
- "U.S. Taxation of Foreign Persons," Introduction to International Taxation, New York University Summer Institute in Taxation, New York, New York, July 14, 2008
- "Introduction to International Tax," training program for Amper, Politziner & Mattia PC, New Brunswick, New Jersey, June 18, 2008
- "U.S. Taxation of Foreign Persons," Introduction to International Taxation, New York University Summer Institute in Taxation, New York, New York, July 16, 2007