LaVonda D. Napka

Practices

• Tax

Professional Experience

LaVonda is an associate in the Tax practice group who focuses her practice on international tax matters. She has represented clients on cross-border mergers and acquisitions, Section 482 transfer pricing matters, CFC, PFIC and FIRPTA matters, withholding tax, limitations on benefits and other tax treaty issues. Prior to joining Thompson Hine LaVonda worked in the international tax group of an international accounting firm.

Education

• Case Western Reserve University School of Law, J.D., 2006, cum laude
• Ohio Northern University, B.A., 2001

• Representative International Tax Projects
• Drafted competent authority submissions concerning transfer pricing issues.
• Have advised on matters regarding cross-border transactions between related parties (i.e. sales/distributions/payment of loan).
• Regularly advise U.S. banks on withholding tax matters and potential Subpart F impact of lending to foreign entities.
• Regularly advise on controlled foreign corporation and passive foreign investment company matters.
• Regularly advise U.S. multinationals on Subpart F matters.
• Regularly advise both U.S. and foreign entities on withholding tax, limitations on benefits, and other tax treaty issues.
• Regularly advise foreign persons on tax planning opportunities and compliance requirements of acquiring or investing in U.S. real property, including compliance with the Foreign Investment in Real Property Tax Act (FIRPTA).
• Regularly advise on Section 338(g) and Section 338(h)(10) elections.
• Have advised on tax consequences of cross-board reorganizations.
• Have advised on filing informational reporting requirements with respect to CFCs and foreign-owned U.S. entities.
• Other Matters
• Regularly advise Hedge Funds on issues relating to revising and updating tax disclosures contained in private placement memorandums.
• Advised LLC's regarding tax computation and cash analysis with respect to the sale of partnership interest.

• "Authority? Authority?! Of Course I have Authority! Thoughts on Closing Agreements, Delegation Orders and Signature Authority" · Journal of Tax Practice and Procedure, June-July 2009, co-author

• "Taxation of Employment Recoveries", co-presenter, Northern Ohio Labor and Employment Law Conference (CMBA), June 2008 and 2009
• "U.S. Taxation of Multi-National Corporations", co-presenter, Case School of Law International Business Organizations Course Lecture, February 2009
• "FIN 48, Tax Accrual Work Papers – IRS Audit Considerations", co-presenter, Tax Executives Institute, Inc. (Pittsburg, PA), September 2007