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Professional background

AndreaSharetta

PartnerAndrea.Sharetta@ThompsonHine.com
New York

O 212.908.3990

AndreaSharetta

Partner

Focus Areas

Andrea’s experience prior to joining Thompson Hine includes:

  • Represented a global automotive parts company on U.S. tax consequences of corporate restructurings, including obtaining private letter rulings from the IRS Associate Chief Counsel, cross-border tax planning, debt refinancings, bond offerings, international tax issues arising post-tax reform, including the repatriation tax, GILTI, the PTEP ordering rules, and foreign tax credit rules, and assisted in resolving a significant tax audit at IRS Exam and IRS Appeals
  • Representing a Hawaiian client in arbitration proceedings on tax issues arising out of a tax-free split-off of a family business
  • Counseled a client on structuring a Singapore reverse takeover transaction to fall outside U.S. anti-inversion rules
  • Advising a leading South American consulting company in the architecture, engineering and construction industry on the U.S. tax consequences of restructuring and expanding its business into the United States
  • Represented a leading European retailer of gift experiences on U.S. tax aspects of expanding business into United States, including permanent establishment and other U.S. tax treaty issues arising under cross border business model for marketing and sales operations
  • Represented, as part of a team, the official creditor committee of one of the world’s largest manufacturers of automotive parts on the tax aspects of its cross-border insolvency proceedings pursuant to an asbestos-related chapter 11 plan of reorganization
  • Advised a multinational Norwegian risk management corporation on the internal restructuring of its domestic operations in various business sectors following merger with a leading organization in same field
  • Advised a global beauty company on the U.S. tax consequences of restructuring its international operations pursuant to nontaxable reorganizations and intragroup stock transfers
  • Advised a leading U.S.-based casual dining restaurant company on the U.S. tax consequences of restructuring its domestic operations under a new holding company structure
  • Advised high net worth client families in structuring real estate acquisitions including tax considerations of U.S. trade or business and effectively connected income analysis, the Foreign Investment in Real Property Tax Act of 1980 (FIRPTA), passive foreign investment company (PFIC) considerations, the active rents and royalties exception to subpart F, withholding tax issues and information reporting requirements
  • Advised foreign financial institutions on U.S. tax aspects of lending, portfolio investments and corporate financing structures
  • “U.S. Individuals with Foreign Business Operations,” Chapter 6, Basics of International Taxation Course Handbook 2019, Practicing Law Institute (PLI), April 2019
  • “U.S. Individuals with Foreign Business Operations,” Chapter 4, Basics of International Taxation Course Handbook 2018, Practicing Law Institute (PLI), April 2018
  • “U.S. Persons Operating Outside the United States: Outbound Active Business Operations,” Chapter 2, Basics of International Taxation Course Handbook 2017, Practicing Law Institute (PLI), April 2017
  • Co-author, “Crucial Considerations for EB-5 Immigrants and U.S. Visa Personal Income Tax,” EB5 Investors Magazine, May 16, 2016
  • “Expert Analysis—Case Study: Rigas v. US,” Law360, August 29, 2011
  • Lead Note, The Problem of Equitable Tolling in Tax Refund Claims, 72 Notre Dame Law Review 545, 1997
  • Presenter, “Tax Planning Considerations When Marrying a Non-U.S. Citizen,” New York Law School, Graduate Tax Program, New York, NY, December 2021
  • Speaker, “Impact of Tax Reform on U.S. Individuals with Business Operations Outside the U.S.,” Basics of International Taxation 2019, Practicing Law Institute (PLI), New York, NY (July 2019) and San Francisco, CA (September 2019)
  • Speaker, “U.S. Individuals with Business Operations Abroad—Examples of Impact of New Tax Law,” Basics of International Taxation 2018, Practicing Law Institute (PLI), New York, NY (July 2018) and San Francisco, CA (September 2018)
  • Speaker, “Tax Concerns for U.S. Persons Investing or Operating Outside the U.S. (Outbound Investments) —Active Business Operations,” Basics of International Taxation 2017, Practicing Law Institute (PLI), New York, NY (July 2017) and San Francisco, CA (September 2017)
  • Speaker, “U.S. Persons Investing or Operating Outside the United States (Outbound Investments)—Active Business Operations,” Basics of International Taxation 2016, Practicing Law Institute (PLI), New York, NY (July 2016) and San Francisco, CA (September 2016)
  • Speaker, “U.S. Persons Operating Outside the United States—Outbound Active Business Operations,” Basics of International Taxation 2015, Practicing Law Institute (PLI), New York, NY (July 2015) and San Francisco, CA (September 2015)
  • Speaker, “Outbound M&A,” Basics of International Taxation 2014, Practicing Law Institute (PLI), San Francisco, CA, September 2014

Professional Associations

  • Tax Section, New York State Bar Association
  • USA Branch, International Fiscal Association

Community Activities

  • Women’s Executive Circle of New York, Inc., Board of Directors2009-2012

Education

  • New York University, LL.M., 1998
  • University of Notre Dame Law School, J.D., 1997,

    Notre Dame Law Review

  • State University of New York at Binghamton, B.A., 1994,
    summa cum laude
    ,

    Phi Beta Kappa

Bar Admissions

  • Illinois
  • New York