A Conversation With Miller & Chevaliers Loren Ponds

Shortly afterLoren Pondscompleted her LLM in tax atGeorgetown College, she packed up her condominium in Washington and moved to Germany to analysis worldwide tax underneath a prestigious, German-funded world fellowship.

It might appear to be a routine transfer for a global tax lawyer, particularly one likePonds, who was excited about changing into a legislation professor and needed to discover a place that might pay her to put in writing andshoptalkpapers.

However on the time a few of her classmates thought she may very well be damaging her profession by accepting the German Chancellor Fellowship which is awarded to 50 folks yearly as an alternative of going straight to a legislation or accounting agency. A number of folks warned her that she may not be capable to get again on observe.

I believed, nicely, the companies arent going anyplace, so let me attempt to do what I wish to do and see how that works out, Ponds instructedTax Notes.

After transferring to Germany in 2007, Ponds researched switch pricing points, which segued right into a stint on theOECDin Paris. From there she landed atEY, the place she spent a number of years within the agencys nationwide switch pricing group. She then took a historic tax job majority tax counsel for theHome Methods and Means Committee, the place she helped write the Tax Cuts and Jobs Act.

It seems that taking the unconventional path paid dividends for Ponds, who’s now a member atMiller & Chevalier Chtd. and laughs that folks now love her journey.

It’s important to be just a little immune to exterior strain to observe a sure path if it really works for you. Some folks dont have a really a giant urge for food for threat,Pondsstated.

If one thing doesnt make me just a little bit excited and nervous, I dont wish to do it. Thats all the time been my strategy.

A Girl-Ahead OECD

In Germany Ponds shortly realized that academia would make an incredible profession, simply not for her. She discovered the work a bit isolating and lonely.

However whereas she was in Europe, she spent a number of months as a trainee on theOECDs Tax Treaty, Switch Pricing, and Monetary Transactions Division (now folded into the Centre for Tax Coverage and Administration). Not many U.S. tax attorneys get an opportunity to work on theOECD, and Ponds actually valued that have for the technical work and the mentorship.

One factor she remembers concerning theOECDis simply how woman-forward her staff was.

It was refreshing, statedPonds, who labored underneathMary BennettandCaroline Silberztein each now withBaker McKenzieLLP.

It was an setting the place we have been inspired to study, develop, focus on, and trade concepts; everybodys enter was valued. It was a very supportive setting,Pondsstated. For a younger lawyer, it was a very nice setting to be in as I began to construct my follow.

You By no means Know Who Is Watching

WhenPondsreturned to the USA in 2009 she joinedEY, the place she spent almost eight years working her approach up throughout the agencys nationwide switch pricing group. She began as a senior supervisor and later served as the worldwide switch pricing operations supervisor, a job by which she helped deal with switch pricing operations for your complete agency.

That position got here early in her profession, simply two years after becoming a member ofEY. For that place, Ponds moved to Germany and took on extra worldwide work. She stated it was pivotal for her profession each substantively and from a enterprise standpoint.

As much as that time my follow had been very U.S.-centric, however I realized quite a bit about switch pricing administration, native nation points for elements of the world that I actually hadnt spent any time in, and differing considerations with respect to switch pricing enforcement throughout totally different areas. The issues taxpayers are involved about when they’re coping with tax authorities in different nations will be very totally different from the issues they give thought to once theyre coping with theIRS. And as much as that time, the one approach to actually see that was via mutual settlement process circumstances, however you dont actually work together with the opposite facet, so it was attention-grabbing,Pondsstated.

It was additionally actually instructive as a result of I realized a lot concerning the enterprise of working the corporate and the economics and the metrics that matter,Pondsadded. Understanding the economics of any enterprise is vital and I used to be in a position to do this at a really younger age.

WhereasPondswas atEY, U.S. tax reform turned an actual risk underneathPresident Donald Trump, who had a Republican majority in each homes ofCongress.

When congressionalRepublicansdetermined to go forward with tax reform, they tappedBarbara Angus, certainly one ofEYs high worldwide tax attorneys, to function chief tax counsel for theHome Methods and Means Committee.

AsAnguswas constructing her staff, somebody inPondss skilled community reached out to her unprompted and prompt thatPondsapply for a place with the committee, which finally employed her to deal with the worldwide provisions of the tax reform package deal.

I used to be minding my very own enterprise, I used to be not excited about leaving,Pondslaughed. The chance got here, and naturally, there was a whole lot of buzz and you mayt assist however get excited concerning the prospect of attending to take part in severe tax reform, which hadnt occurred in 30 years.

Curiously, the person who really helpful thatPondsapply wasnt precisely a profession sponsor or formal mentor, however was slightly an individual who had taken an curiosity inPondss profession from afar and the route by which it was going.

Ive had fantastic mentors alongside the best way and infrequently folks suppose mentors must be with you each step of the best way. Thats not true. I do have longer-term mentors, however Ive had mentors who have been with me for a really brief time, however performed vital roles that helped me take the subsequent step,Pondsstated. This was an instance.

It was a nudge. But it surely was a nudge in the appropriate route, and a really pivotal second in my profession,Pondsstated. Lots of little pushes alongside the best way have actually been instrumental for me, and I attempt to do that for others. Slightly push, or simply serving to somebody make a connection, or providing a suggestion, can actually make a distinction. I dont know that you simply all the time want a proper mentor; you simply want somebody in your nook and it doesnt must be for lengthy.

Creating the Tax Cuts and Jobs Act

Ponds joined theMethods and MeansCommittee in April 2017. That very same month, the Trump administration launched its define for enterprise and particular person tax reform.

By December of that 12 months the TCJA was signed into legislation. Between April and December Ponds and the remainder of the congressional staff labored grueling days . . . however whatPondsremembers probably the most is that the method was extremely collaborative.

My colleagues and I actually had an incredible skilled relationship cast out of fireplace. We have been working collectively underneath extraordinarily intense circumstances with quite a bit on the road, so a whole lot of credit score needs to be given to them,Pondsstated.

She and her colleagues have been taking conferences on a regular basis, on daily basis within the lead-up to the discharge of the TCJA draft,Pondsstated. We by no means stated no to a taxpayer assembly the place folks gave suggestions, concepts, communicated considerations.

As soon as the invoice was launched for markup, issues turned extraordinarily frenzied. Ponds remembers that it was launched on a Friday and he or she and her colleagues have been on the telephone early the subsequent morning and over your complete weekend, getting suggestions from taxpayers on how the principles would work with their particular details.

The TCJA made a number of substantial adjustments to the U.S. company tax regime. It dropped the company tax fee from 35% to 21%, launched the worldwide intangible low-taxed earnings regime and the bottom erosion and antiabuse tax two measures meant to guard the nations tax base. It additionally moved the nation nearer to a territorial tax system.

For probably the most half taxpayers have been understanding of what we have been attempting to do, and I believe most taxpayers on the entire have been appreciative if not of each single particular person provision, definitely of the trouble concerned. The top outcomes and the big ideological adjustments the decrease company tax fee, the transfer to a extra territorial system have been welcome,Pondsstated.

After the TCJA turned legislation,Pondsstayed on for nearly one other 12 months engaged on part 2 of the package deal, figuring out technical corrections and collaborating withTreasury.

In October 2018 she decamped forMiller & Chevalier, the place she now helps shoppers navigate the TCJA because it continues to evolve.

Tax reform is an iterative course of and the system continues to evolve. We see that now, with new proposals supplied by a probably new administration. We see that now with theOECDs work relating to the digitalization of the economic system. Thats the perfect a part of what we do. Nothing stays the identical,Pondsstated.


Within the wake of the coronavirus pandemic, the job market is extra unsure for younger attorneys as legislation companies defer begin dates and furlough and lay off attorneys.

Ponds recollects the occupation confronted comparable struggles when she graduated from legislation faculty, months after the September 11 terrorist assaults.

On this setting,Pondssays it’s particularly vital for younger attorneys to do not forget that the place they begin is just not essentially the place they are going to find yourself.

I hope that folks take away from this text that there are numerous, many paths to success,Pondsstated. Im not doing something I dont wish to be doing. Perhaps thats a luxurious, nevertheless it additionally takes some braveness. I believe it’s important to be trustworthy about what youre doing and why. And it’s important to be clear about your objectives. It takes self-reflection and honesty. Not everybody needs to be a legislation agency associate and thats OK.

AsPondscontinues on this newest part of her profession, she, too, believes theres extra for her to achieve.

I dont really feel Ive reached the top. Im nonetheless studying, Im nonetheless rising, theres way more left in retailer for me professionally,Pondsstated. I dont ever really feel like Ive made it. Completely not. I really feel like Im transferring ahead, like Im making progress, however Im not completed.

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