Elyce Friedfeld, J.D., LL.M
President & Director of Tax Department
Elyce Friedfeld is an attorney with a substantial career in international, corporate and partnership taxation and has extensive experience structuring and negotiating cross-border investments, financings and commercial transactions. Ms. Friedfeld manages and advises on mergers and acquisitions, corporate reorganizations and joint ventures. She counsels investors and lenders in connection with multi-national loan facilities and other equity-type hybrid participations. Additionally, she advises U.S. and non-U.S. businesses on tax efficient capitalization, financing and operating structures, insolvency and restructuring matters, and equity and debt offerings.
Ms. Friedfeld has structured and negotiated cross-border project financings on non-recourse and limited recourse bases. She develops bankable commercial and infrastructure investment projects (including preparation of business plans and financial models), develops financing alternatives and support packages (including inter-creditor and sophisticated security arrangements), prepares funding applications and manages and reports on project feasibility studies, often funded by government or IFI agencies.
In addition, Ms. Friedfeld has advised on double taxation treaty matters (including permanent establishment, withholding tax, treaty shopping and Limitations on Benefits issues), section 482 transfer pricing and compliance arrangements, Subpart F, FPHC and PFIC repatriation limitations and NOL, SRLY and section 382 consolidated return issues. She has structured offshore investments using hybrid entities, conducted securities registrations and equity and debt issues (including convertible and exchangeable securities). She also represents corporations and individuals in controversies with the IRS and other taxing authorities and before the Tax Court and state administrative tribunals.
Ms. Friedfeld holds a J.D. and a LL.M. in Taxation from New York University School of Law. She graduated Wesleyan University, Phi Beta Kappa with a B.A. in Russian Language and Literature.
Ms. Friedfeld is native in English and is fluent in Hebrew and Russian.