Dianne C. Mehany is a Member in Caplin & Drysdale's Washington, D.C., office. She also serves on the Firm’s Board of Directors.
Ms. Mehany's practice focuses on international tax controversies and planning, including tax audits in the cross-border context, inbound and outbound tax planning, foreign tax credits, tax treaties, tax audits, and planning and compliance with respect to Puerto Rico’s Act 60 (formerly Act 20:22). She also has experience in tax compliance of individuals, companies and financial institutions in the cross-border context, including FATCA reporting, reporting of ownership or beneficiary interests in foreign trusts, offshore financial accounts and assets.
Ms. Mehany's practice also encompasses income tax and succession planning for wealthy individuals and families, including pre-immigration and pre-expatriation planning, and foreign trusts.
In addition to advising clients in these areas, Ms. Mehany has extensive experience advising individual and corporate clients in federal civil and criminal tax controversy matters. She guides clients through all stages of IRS disputes, including preparing protests of IRS actions, representing clients at appeals conferences, filing petitions in the Tax Court and complaints in District Court, and assisting with trial matters and settlement discussions. Moreover, Ms. Mehany has counseled individual clients and financial institutions on the U.S. government's investigation of undisclosed foreign assets, particularly with respect to the classification of foundation and trust structures.
Ms. Mehany speaks before many professional associations and conferences. Her recent engagements include:
- Panelist, The Role of Legal Privilege in the Protection of Taxpayer Rights, 6th International Conference on Taxpayer Rights, October 6, 2021
- Chair, Tax Audits and Criminal Investigations of High-Net-Worth Individuals in the Transparency Era, ABA 21st Annual U.S. and Europe Tax Practice Trends Conference, March 22, 2021
- Speaker, Roundtable Three: Advising the Ever-Changing Client, IBA 26th International Private Client Virtual Conference: Advising real clients in a virtual world, March 3, 2021
- Speaker, How to Solve a Problem Like...U.S. Tax Compliance, Frank Hirth, February 10, 2021
- Panelist, U.S. Expatriation (Tax & Immigration), U.S. and UK Tax Planning Digital Week, October 20, 2020
- Speaker, The IRS - What is Around the Corner for International U.S. Taxpayers?, Frank Hirth, June 4, 2020
- Panelist, When A Civil Audit Turns: Navigating an Audit when the Mistakes are not Unintentional, Federal Bar Association, 44th Annual Tax Law Conference, March 6, 2020
- Moderator, Tax Enforcement – U.S. & UK Update: what is around the corner?, U.S./UK Tax Planning 2019, London, November 7, 2019
- Speaker, Allocation of Trust Distributable Net Income Between Trust and Multistate Beneficiaries, Strafford Publications, October 8, 2019
- Panelist, To Err is Human, to Forgive Divine: A Guide to Reasonable Cause And Other Defenses to Form 3520 Penalties, 2019 ABA Section of Taxation Fall Meeting, October 5, 2019
- Chair, The New OECD Global Anti-Base Erosion Proposal, IBA Annual Conference 2019, September 24, 2019
- Speaker, Inclusion of Capital Gains in Distributable Net Income for Trusts and Estates: Allocations for Optimal Tax Treatment, Strafford Publications, September 19, 2019
- Panelist, Welcome to International Private Client: Analyzing Foreign Trusts Workshop, 2019 ABA Section of Taxation May Meeting, May 11, 2019
- The Landscape of Tax Enforcement in the U.S. and UK, U.S./UK Tax Planning, Los Angeles 2019, May 6, 2019
- Panelist, The Landscape of Tax Enforcement in the U.S. and UK, U.S./UK Tax Planning, New York 2019, May 2, 2019
- Speaker, Multistate Allocation of Trust Distributable Net Income: Income Sourcing and Apportionment, Strafford Publications, February 21, 2019
- Panelist, 360 Degree Perspective: U.S. Withholding and Global Information Reporting, ABA Section of Taxation, 2019 ABA Midyear Meeting, January 17, 2019
- Panelist, Calculating Foreign Trust DNI and UNI: Avoiding Throwback Tax on Undistributed Net Income, Strafford Publications, October 31, 2018
- Panelist, Dispute Resolution, ICAP, MAP, OECD International Tax Conference, June 4, 2018
- Presenter, Expatriation Tax, IBC Finance, May 8, 2018
- Panelist, Trust Distributions to Foreign Beneficiaries: Complex Planning and Calculation Challenges, Strafford, February 27, 2018
- Panelist, International Tax Reform, American Bar Association Section of Taxation 2018 Midyear Meeting, February 8, 2018
- Speaker, The Future of US Cross-Border Criminal Tax Enforcement, Cross Border Planning for the Private Client - Asia, August 16, 2017
- Panelist, U.S. Tax Compliances for Americans Living in India and Remedial Measures for Non-Compliance, Grant Thornton and Caplin & Drysdale, June 14, 2017
- Panelist, The Pressures on Offshore Jurisdictions, TransTrusts: International Forum 2017, May 5, 2017
- Panelist, Innovation - The Key to a Strong Economy: A Discussion of Immigration and Tax Policies to Encourage the Development of an Innovative Economy, American Bar Association Section of International Law, April 27, 2017
- Speaker, Subpart F Income Tax: Its Scope and Application to US Shareholders, ABA Tax Section, January 19, 2017
- Speaker, Trust Distributions to Foreign Beneficiaries, Strafford, January 5, 2017
- Speaker, Mastering Form 3520: Reporting Foreign Trust Activities on U.S. Income Tax Returns, Strafford, July 14, 2016
- Speaker, FATCA: How It Affects Every Practice, American Academy of Attorney-CPAs, June 23, 2016
- Speaker, Aetna International Customer Forum, Aetna International, November 3, 2015
- Panelist, Residence: Beyond the Basics, American Bar Association, 2015 Joint Fall CLE Meeting, September 18, 2015
- Seminar H: The Taxation of Global Families, International Fiscal Association, Basel 2015, September 2, 2015
- Navigating U.S. Tax Requirements and Strategic Methods of Coming into Compliance, Caplin & Drysdale, Chartered and Ham, Langston & Brezina LLP, U.S. Tax Requirements and Compliance Seminar, March 11, 2015
- Panelist, A Primer on Tax Treaties, American Bar Association, 2015 Midyear Meeting, January 31, 2015
- Panelist, How Many Shades of Grey? Current Ethical Issues for Tax Professionals, 66th Annual Virginia Conference on Federal Taxation, June 11, 2014
- Moderator, First Time on the Bench: Perspectives from Tax Court Judges, American Bar Association, 2014 May Meeting, May 9, 2014
- Panelist, Meeting the Ethical Challenges of Inbound Controversies, American Bar Association, 2014 May Meeting, May 9, 2014
- Panelist, Nuts & Bolts Series: International Tax Enforcement: FBARs, FATCA, and More, American Bar Association, 2014 May Meeting, May 8, 2014
- Panelist, Issue Spotting Across the Globe for Expatriate Executive Packages, American Bar Association, Joint Committee on Employee Benefits Webinar, December 17, 2013
- Speaker, Advising Clients with International Tax Issues: Form Numbers, PFIC and More, American Law Institute (ALI) CLE, Hot Topics for Accountants & Tax Lawyers: Tax Returns, Advice, & Examination, December 16, 2013
- Panelist, Leaving the U.S. – It's Very Different from Leaving Las Vegas. Tax Planning for U.S. Persons Living and Working Abroad, American Bar Association, 2013 Joint Fall CLE Meeting, September 20, 2013
- Panelist, Coping With FATCA If You're Not a Foreign Financial Institution, American Bar Association, 2013 May Meeting, May 10, 2013
- Speaker, The Ethical Framework - Duties of the Tax Practitioner to the Client and to the System, University of Virginia Tax Foundation, 64th Annual Conference on Federal Taxation, June 7, 2012
- Speaker, The Road Less Traveled: Exploring Niche Tax Practices, American Bar Association, 2012 May Meeting, May 1, 2012
- Moderator, The New Application of Transferee Liability, American Bar Association, 2011 Midyear Meeting, January 21, 2011
- Moderator, Tax Consequences of Disasters, American Bar Association, 2010 Joint Fall CLE Meeting, September 24, 2010
- Speaker, Four Actions Explained in Forty Minutes, American Bar Association, 2009 Fall Joint Meeting, September 24, 2009
- Speaker, Forever Ought to be Worth a Lot: Defending Perpetual Conservation Easements, Chamberlain Hrdlicka Law Firm, 2008 Annual Tax Forum, December 17, 2008
- Panelist, Getting the Most Out of Your Expert Witness in Tax Cases, American Bar Association, 2008 Joint Fall Meeting, September 22, 2008
Click here for a full list of speaking engagements.
- "IRS to "Campaign" into Puerto Rico; How can Taxpayers Defend?,"
with J. Clark Armitage, Amanda Reed, and Tom Duffy, Caplin & Drysdale Client Alert, February 3, 2021
- "The Adams Challenge Tax Court Decision Reinforces the Benefits of Foreign Taxpayers Filing Protective U.S. Returns,"
with J. Clark Armitage, James E. Salles, and H. David Rosenbloom, Caplin & Drysdale Client Alert, January 26, 2021
- "The IRS Resumes its Global High-Wealth Examination Program and Targets High Income Non-Filers,"
with Victor A. Jaramillo, Zhanna A. Ziering, Scott D. Michel, and Mark E. Matthews, Caplin & Drysdale Client Alert, July 22, 2020
- "Damage Mitigation: The IRS Helps Alleviate Effect of COVID-19 on U.S. and Foreign Residency,"
with Victor A. Jaramillo, Zhanna A. Ziering, and Jonathan R. Black, Caplin & Drysdale Client Alert, April 22, 2020
- "Updated Filing and Payment Extensions Under Notice 2020-23,"
with Victor A. Jaramillo, Scott D. Michel, Zhanna A. Ziering, and Aaron M. Esman, Caplin & Drysdale Client Alert, April 10, 2020
- "Collateral Damage: Covid-19 and its Unintended Effect on U.S. Residency,"
with Victor A. Jaramillo and Zhanna A. Ziering, Caplin & Drysdale Client Alert, April 1, 2020
- "Abatement of Foreign Pension Trust Penalties,"
with Kirsten Burmester, Victor A. Jaramillo, and Scott D. Michel, Caplin & Drysdale Client Alert, March 31, 2020
- "The Impact of Notice 2020-18 on Information Returns,"
with Victor A. Jaramillo, Zhanna A. Ziering, and Aaron M. Esman, Caplin & Drysdale Client Alert, March 30, 2020
- "The New Voluntary Disclosure Practice: A Fair Compromise?,"
with Zhanna A. Ziering, Scott D. Michel, and Mark E. Matthews, Caplin & Drysdale Client Alert, December 3, 2018
- "IRS Adds Foreign Trust Information Reporting to Compliance Campaign Program,"
with Victor A. Jaramillo, Kirsten Burmester, and Anne J. O'Brien, Caplin & Drysdale Client Alert, June 1, 2018
(republished in Global Tax Weekly)
- "IRS's Offshore Voluntary Disclosure Program Ending: Impact on U.S. Taxpayers,"
with Zhanna A. Ziering, Benjamin Z. Eisenstat, Scott D. Michel, and Mark E. Matthews, Caplin & Drysdale Client Alert, March 14, 2018
- "INSIGHT: First Class, Global Entry, and Now Tax Compliance: the New Must-Have for Today's International Traveler,"
Bloomberg Tax: Daily Tax Report, March 6, 2018
- "IRS to Revoke Passports for Seriously Delinquent Tax Debts Starting February 2018,"
with Zhanna A. Ziering, Mark D. Allison, Victor A. Jaramillo, and Christopher S. Rizek, Caplin & Drysdale Client Alert, February 12, 2018
- "Paradise Papers: U.S. Citizens and Residents Required to Report on Offshore Assets,"
with Mark D. Allison, J. Clark Armitage, Peter A. Barnes, and Kirsten Burmester, Caplin & Drysdale Client Alert, November 6, 2017
- "U.S. Passports in Jeopardy for Taxpayers Owing the IRS,"
with Mark D. Allison and Niles A. Elber, Global Tax Weekly, January 11, 2016
- "U.S. Passports in Jeopardy for Taxpayers Owing the IRS,"
with Niles A. Elber, Victor A. Jaramillo, and Zhanna A. Ziering, Caplin & Drysdale Client Alert, December 9, 2015
- "Steps Foreign Persons Can Take to Avoid Unnecessary U.S. Estate Tax,"
with Kirsten Burmester and Beth Shapiro Kaufman, Caplin & Drysdale Client Alert, November 9, 2015
- "The Final OECD BEPS Tome Has Arrived,"
with H. David Rosenbloom, Patricia Gimbel Lewis, J. Clark Armitage, and Peter A. Barnes, Caplin & Drysdale Client Alert, October 8, 2015
- "The Practical Protection of Taxpayers' Fundamental Rights,"
with Christopher S. Rizek and Scott D. Michel, International Fiscal Association 2015 Basel Congress, August 1, 2015
- "FATCA – Enforcement Win or Expatriate Generator?,"
with Mark E. Matthews, IFC Review, July 1, 2015
- "FATCA: An Overview of Its Scope and Application to Non-U.S. Entities Chapter,"
The International Comparative Legal Guide to: Private Client 2014, 3rd Edition, December 23, 2013
- "FATCA Reporting – Are Trusts and Trustees Caught in the Net?,"
Financier Worldwide, July 1, 2013
- "Comments to the Proposed Amendments to the Rules of the United States Tax Court,"
American Bar Association, May 27, 2009
Click here for a full list of publications.
