Ms. Herzfeld specializes in cross-border taxation, and has experience advising both public and private clients in complex international acquisitions, dispositions, and joint ventures. She also regularly consults with clients on international tax policy developments.

Ms. Herzfeld is a Professor of Tax Practice at the University of Florida, Frederic G. Levin College of Law, where she teaches courses in tax policy and international taxation for LL.M students. Since 2014, she has been a Contributing Editor to Tax Notes International, a weekly magazine on tax developments published by Tax Analysts. In that capacity, she has written over 250 articles on international tax policy developments and cross-border transactions, and has also written extensively on U.S. tax reform efforts.  Her work has been widely cited in academic articles, Congressional research reports and Treasury papers both in the U.S. and overseas. She is the author of the bestselling introduction to the field, International Taxation in a Nutshell, 12th ed. (West 2020).

Previously, Ms. Herzfeld worked at the national tax office and the New York office of a Big 4 accounting firm, where she provided transactional advice to U.S. and foreign multinational corporations, private equity funds, venture capital funds and individuals on a broad range of U.S. and cross-border tax issues.

Ms. Herzfeld began her career in the New York office of a global law firm and has also worked as in-house tax counsel at a large automotive manufacturing company.

Representative Experience

  • Advised public companies on structuring multi-billion dollar cross-border acquisitions, dispositions and spin-offs, with particular experience in the manufacturing, oil & gas, and tech sectors.  
  • Advised global private equity and venture capital funds on inbound and outbound foreign investments, including for corporate and partnership structures.
  • Advised privately held companies on the tax implications of greenfield investments in new jurisdictions.
  • Advised multinationals on tax-efficient IP holdings.

Publications and Speeches

International Taxation in a Nutshell (West, 12th ed. 2020)

Designing International Tax Reform: What Went Wrong? Upcoming in ITAX (December 2020)

US Tax Reform: A Multilateral Success? 2019 British Tax Rev. 487

Debate on the US Tax Reform and the EU ATAD: Can GILTI + BEAT = GLOBE?, 47 InterTax 504 (2019)

US Perspectives on the Multinational Instrument 46 InterTax 80 (2018)

International Taxation in a Nutshell (West, 11th ed. 2018) (with Richard Doernberg) 

The Case Against BEPS:  Lessons for Tax Coordination, 21 FL. TAX. L. REV. 1 (2017)

U.S Perspectives on the Multilateral Instrument, 46 Intertax 1:80-85 (2018)

United States National Report to the 2013 IFA Annual Congress, Subject I: The taxation of foreign passive income for groups of companies IFA, 98a Cahiers de Droit Fiscal International, 2013 (with Yariv Brauner) 

Debt Modifications –International Tax Considerations for U.S. Multinationals, 13 Int’l  Tax J. 17 (2010) (with John Kennedy) 

Stapled Stock Regulations Finalized as Proposed, 33 Intertax 0: 482 (2005) (with Diane Renfroe) 

Proposed Regulations Issued on Treatment of Stapled Foreign Corporations, 32 Intertax Issue 12, 630-31 (2004) (with Diane Renfroe)  

U.S. Tax Scene:  US IRS Issues Proposed Regulations on ECI Treatment of Stock Held by Insurance Companies 32 Intertax 533 (2004) (with Thomas Fuller)

Recent and Selected Tax Notes Publications (with notable citations)

The Democrats’ New Mantra: Tax Harmonization, 101 Tax Notes Int’l 1095 (March 1, 2021)

For Biden’s Treasury Team, Big Ideas Are About to Meet Reality, 101 tax Notes Int’l 841 (February 15, 2021)

The New Regulatory Architecture for U.S. International Tax, 101 Tax Notes Int’l 10 (January 4, 2021)

Are Pillars 1 and 2 Compatible with Democracy and Sovereignty, 100 Tax Notes Int’l 1264 (December 7, 2020)

Tax Optimism for a Post-Pandemic World, 98 Tax Notes Int’l 399 (April 27, 2020)

Global Crises and Loss Planning, 166 Tax Notes Federal 1709 (March 16, 2020)

Realigning Tax, Trade & Treaties in a Digital Age, 166 Tax Notes Federal 1068 (February 17, 2020)

Did Treasury Weaken the TCJA? 97 Tax Notes Int’l 135 (January 13, 2020)

A Better Alternative to Wealth Taxes, 96 Tax Notes Int’l 586 (November 18, 2019)                                              

From TCJA Guidance, a New Regime Begins to Emerge, 95 Tax Notes Int’l 665 (August 19, 2019)

Gaps in the TCJA Guidance, 95 Tax Notes Int’l 482 (August 5, 2019)

Status Check on TCJA Guidance, 95 Tax Notes Int’l 381 (July 29, 2019)

ICAP as a Tool for Addressing the Digital Economy, 95 Tax Notes Int’l 183 (July 15, 2019)

Treasury’s Fantasy of an Integrated International System, 95 Tax Notes Int’l 106 (July 8, 2019)

Locating Sales: FDII Regs Address Questions OECD Workplan Must Answer, 94 Tax Notes Int’l 1282 (June 24, 2019)

FDII and Export Subsidies: Trade Politics, 94 T Tax Notes Int’l 1043 (June 10, 2019)

Tariffs, Taxes & Trade: Shifting Dynamics, 94 Tax Notes Int’l 795 (May 27, 2019)

The U.N.’s Role in Rewriting International Tax Rules for the Digital Age, 94 Tax Notes Int’l 601 (May 13, 2019)

Reforming Capitalism: Implications for the Corporate Tax, 94 Tax Notes Int’l 408 (April 29, 2019)

Can the OECD Fix the BEAT, 93 Tax Notes Int’l 1147 (March 18, 2019)

Moving to Market, Competing Considerations, 93 Tax Notes Int’l 908 (March 4, 2019)

The OECD Consults on a New World Order, 93 Tax Notes Int’l 702 (February 18, 2019)

Hybrids, BEPS & the TCJA, 93 Tax Notes Int’l 468 (February 4, 2019)

Three Attempts to Fix GILTI, 162 Tax Notes 266 (January 21, 2019)

What the OECD Can Learn From the U.S. GILTI Regime, 93 Tax Notes Int’l 163 (January 14, 2019)

BEPS Implementation, TCJA Responses Top 2019 Agenda, 92 Tax Notes Int’l 1265 (December 24, 2018)

Post Midterms: A Progressive Tax Agenda?, 92 Tax Notes Int’l 1049 (December 10, 2018)

Accounting Disclosures Post-TCJA, 92 Tax Notes Int’l 862 (November 26, 2018)

Treasury Strikes a Bold Regulatory Path Post-TCJA, 92 Tax Notes Int’l 679 (November 12, 2018)

Germany Weighs in on Digital Debate, 92 Tax Notes Int’l 487 (October 29, 2018)

Value Creation & Digital Profits, 92 Tax Notes Int’l 261 (October 15, 2018)

Looming GILTI Battles, 92 Tax Notes Int’l 7 (October 1, 2018)

Can the BEAT Fix Transfer Pricing? 91 Tax Notes Int’l 1203 (September 17, 2018)

GDP, Transfer Pricing, and Value Creation, 91 Tax Notes Int’l 978 (September 3, 2018)

Digital Optimism, Tax Notes Int’l (July 16, 2018)

Cited in India Central Board of Direct Taxation, Public Consultation on the proposal for amendment of Rules for Profit attribution to Permanent Establishment (April 18, 2019)

Cited in Australia Treasury, The digital economy and Australia's corporate tax system, Treasury Discussion Paper (October 2018)

Splitting Digital in Two, Tax Notes (July 6, 2018)

The Origins of GILTI, Tax Notes Int’l (June 25, 2018)

A Post-Truth Tax World, Tax Notes Int’l (June 16, 2018)

Tax Cuts Chaos Part IV: Can Congress Fix It? Tax Notes Int’l (June 4, 2018)

Tax Cuts Chaos, Part III:  Can Treasury Fix It? Tax Notes Int’l (May 21, 2018)

Cited in Daniel Shaviro, The New Non-Territorial U.S. International Tax System, 160 Tax Notes 57 (July 2, 2018)

Tax Cuts Chaos, Part II:  Whither Section 367(b)? Tax Notes Int’l (April 2018)

Tax Cuts Chaos: Part I, Tax Notes Int’l (April 8, 2018)

Cited in Patrick Driessen, In Defense of Cross-Border Expense Apportionment, 160 Tax Notes 665 (July 30, 2018)

Cited in Senate Committee on Finance, Trump’s Tax Law and International Tax: More Complexity, Loopholes and Incentives to Ship Jobs Overseas (July 18, 2018)

The OECD (Finally) Tackles the Elephant in the Room Tax Notes Int’l (March 26, 2018)

Cited in Monica Gianni, OECD BEPS (In)Action 1: Factor Presence as a Solution to Tax issues of the Digital Economy, 72 Tax Lawyer (2018)

Digital Nexus in the EU and the United States, Tax Notes Int’l (March 13, 2018)

The New Imperialists:  Tax Bureaucrats, Tax Notes Int’l (February 26, 2018)

Who Loses in Tax Wars, Tax Notes Int’l (February 12, 2018)

Will Effective Tax Rates Converge? 89 TAX NOTES INT’L 389 (January 29, 2018) 

How Some Taxpayers Got Cut Out of the Tax Cuts and Jobs Act, 89 TAX NOTES INT’L 277 (January 22, 2018)

Cited in Congressional Research Rpt R45186 Issues in International Corporate Taxation: The 2017 Revision (P.L. 115-97) (August 23, 2019)

Competition or Coordination: Responses to the Tax Cuts and Jobs Act, 89 TAX NOTES INT’L 209 (January 15, 2018)

The U.S. Congress Does BEPS One Better, 88 TAX NOTES INT’L 715 (November 20, 2017)

Republicans Propose Upending the International Tax System, 88 TAX NOTES INT’L 609 (November 13, 2017)

A Territorial Move: Protecting the Base, 157 TAX NOTES INT’L 7 (October 2, 2017)

Implementing BEPS:  The Official Version and the Reality, Part 2, 86 TAX NOTES INT’L 1125 (June 26, 2017)

The White Working Class and Post-2016 Tax Policy, 155 TAX NOTES 1219 (May 29, 2017)

Will International Tax Regulations Survive Executive Orders? 86 TAX NOTES INT’L 637 (May 22, 2017) 

Parity for Corporations and Passthroughs through Integration, 86 TAX NOTES INT’L 378 (May 1, 2017)

What is a Reciprocal Tax? 154 TAX NOTES 1176 (March 6, 2017)

Who Will Pay for Tax Reform? 154 TAX NOTES 775 (February 13, 2017)

Bursting Global Tax Bubbles, 82 Tax Notes Int’l 315 (April 25, 2016) 

Could Integration be the Antidote to Inversions? 81 Tax Notes Int’l 711 (February 29, 2016)  

Belgian Excess Profits:  The Commission Strikes Again, 81 Tax Notes Int’l 291 (January 25, 2016)

Cited in Elizabeth A. Jone, State Aid in the EU through Tax Rulings and Transfer Pricing (Seton Hall Student Scholarship 2016)

EU Strikes down Treaty LOB Provision – What it Means, 81 Tax Notes Int’l 13 (January 4, 2016) 

U.K. Leads on BEPS Implementation While U.S. Dithers, 80 Tax Notes Int’l 727 (November 30, 2015) 

Why BEPS is Just the Beginning, 79 Tax Notes Int’l 983 (September 21, 2015)  

Splitting Profits with Communists, 79 Tax Notes Int’l 467 (August 10, 2015)  

The Inevitability of a Carbon Tax, 79 Tax Notes Int’l 179 (July 20, 2015)  

PEs and Foreign Tax Credits: Who Wins, Who Loses? 78 Tax Notes Int’l 320 (April 27, 2015) 

The Power of a Name: Stateless Income and Its Failings, 77 Tax Notes Int'l 1019 (March 23, 2015)  

Input Needed on Transfer Pricing Drafts, 77 Tax Notes Int’l 392 (February 2, 2015) 

Trends in 2014 Inversion Activity, 144 Tax Notes 532 (August 4, 2014)  

Is the United Kingdom a Rogue State or Bold Leader? 77 Tax Notes Int’l 198 (January 19, 2015) 

MAP Statistics Tell a Sorry Tale, 76 Tax Notes Int’l 977 (December 15, 2014) 

The U.N. Rewrites International Tax Rules, 76 Tax Notes Int’l 477 (November 10, 2014)   

What Can Treasury Do About Inversions? 75 Tax Notes Int’l 595 (August 25, 2014)  

What’s Really Driving Inversions? Walgreens Revisited, 144 Tax Notes 393 (July 28, 2014)  

Cited in Edward Kleinbard, ‘Competitiveness’ Has Nothing to do with It, 144 Tax Notes 1055 (2014)

The IRS Shuts Down the Serial ‘Killer B’, 74 Tax Notes Int’l 394 (May 5, 2014)  

The Camp Proposal: A Game Changer for Multinationals, 73 Tax Notes Int’l 1051 (March 24, 2014)  

What’s Next in Inversion Land? 74 Tax Notes Int’l 988 (June 16, 2014) 

Cited in J.C. Fleming Jr., R.J. Peroni, & S.E. Shay, Getting Serious about Cross-Border Earnings Stripping: Establishing an Analytical Framework, 93 N.C.L. L. Rev. 673 (2014-15)

Political Reality Catches Up With BEPS, 73 Tax Notes Int’l 387 (February 3, 2014)


Panelist, A Summary of Recent Transfer Pricing Issues, ABA Tax Section Mid-Year Meeting, Boca Raton, FL (January 2020)

Moderator, International Ripple Effects of TCJA, National Tax Ass’n Annual Meeting, Tampa FL (November 2019)

Moderator, The New Populism and Presidential Candidates’ Tax Proposals, The Tax Council, Washington D.C. (November 2019)

Luncheon Speaker, TCJA Regulatory Update, Florida Tax Bar, Miami FL (October 2019)

Panelist, Treaty Developments: US Perspective, USD/Procopio Int’l Tax Institute, San Diego, CA (October 2019)

Moderator, US and Global Tax Trends, Morgan Stanley Investor Tax Conference, New York (May 2019)

Panelist, US Tax Reform: How are Companies & Countries Reacting? Global Tax Policy Conference: Global Tax Driving the Future, Irish Tax Institute, Harvard Kennedy School Ash Center for Democratic Governance & Innovation, Dublin, Ireland (May 2019)

Moderator, TCJA’s International Provisions: Reflections on the First Year, National Tax Ass’n Spring Meeting, Washington, D.C. (May 2019)

Panelist, What’s New with the US Anti-Hybrid Rules? International Tax Institute, New York (May 2019)

Luncheon Speaker, Hybrids, BEPS & the TCJA, International Fiscal Ass’n USA Branch Westchester County, Stamford, CT (May 2019)

Panelist, Digital Taxation, Tax Foundation Global Tax Policy Retreat, Napa, CA (April 2019)

Instructor, US Taxation, IBFD Tax Course, Amsterdam, Netherlands (April 2019)

Speaker, Corporate Taxation in the Global Economy, PIIE, Washington, D.C. (March 2019)

Panelist, Eyes on the Horizon, What will Follow the TCJA? Federal Bar Ass’n Tax Section Annual Meeting, Washington, D.C. (March 2019)

Panelist, Global Response to the TCJA, IFA USA Annual Meeting, Washington, D.C. (February 2019)

Panelist, The Evolving Boundaries of Tax, TCPI, Washington, D.C. (February 2019)

Presenter, U.S. Tax Reform: A Multilateral Success? International Tax Cooperation: The Challenges and Opportunities of Multilateralism, Oxford Center for Business Taxation, UK (December 2018)

Panelist, multiple panels on U.S Tax Reform and Digital Taxation, International Taxation Conference, Foundation for International Taxation, Mumbai, India (December 2018)

Keynote Speaker, US Tax Reform, How Did We Get Here? The Future of the Corporate Tax, Tallinn, Estonia (September 2018)

Invited Participant, KPMG Roundtable on Taxation of the Digital Economy, Paris, France (July 2018)

Speaker, U.S. Views on Taxation of the Digital Economy, Oxford University Said School of Business Summer Conference (July 2018)

Discussant, Dan Shaviro, The New Non-Territorial U.S. International Tax System, Oxford University Said School of Business Academic Symposium (July 2018)

Speaker, U.S. Views on the Digital Economy, U.S.-China Tax Seminar, Shanghai (June 2018)

Speaker, Sweden IFA:  US Tax Reform: Worth Waiting 30 Years For? Stockholm (May 2018)

Presenter, Taxing Digital Across an Atlantic Divide, University of Florida Levin College of Law Faculty Workshop (with Georg Kofler) (March 2018)

Speaker, Webcast on Tax Cuts & Jobs Act, International Provisions, Florida Bar Tax Section (January 2018)

Panelist, IFA Miami, International Tax Reform (December 2017) 

Panelist, Foundation for International Taxation, Mumbai, Perspectives on the Multilateral Instrument (December 2017)

Panel Co-Chair, International Bar Association, Buenos Aires, Recent Developments in Treaty Anti-Avoidance Rules (November 2017)

Lecturer, A New Direction in U.S. International Tax Policy, Bar Ilan University School of Law, Ramat Gan, Israel (November 2017)

Lecturer, A New Direction in US International Tax Policy, East China University of Political Science and Law, Shanghai, China (November 2017)

Lecturer, A New Direction in US International Tax Policy, Shanghai Jiaotong (Koguan) School of Law, Shanghai, China (November 2017)

Panelist, U.S. Tax Reform, Tax Analysts Panel, IFA Annual Congress, Rio de Janeiro, Brazil (August 2017)

Presenter, The Case Against BEPS:  Lessons for Tax Coordination International Tax Policy Forum, Washington, DC (June 2017)

Panelist, U.S. Tax Implications for Multinationals from Brexit, ABA Tax Section Spring Meeting (May 2017)

Presenter, The Case Against BEPS:  Lessons for Tax Coordination, NYU Law School, (April 2017)

Presenter, IFA Westchester Branch, BEPS:  The Alternative Reality (April 2017)

Presenter, The U.S. in Post-BEPS World, American Chamber of Commerce Luxembourg (March 2016)

Panelist, American Chamber of Commerce Luxembourg (March 2016)                  

Presenter, The Limits of Tax Coordination, University of Florida Levin College of Law Tax Colloquium (February 2016)

Panelist, Global Tax Reset, Plenary at Deloitte International Tax Conference at Villanova University (November 2015)

Panelist, Base Erosion and Profit Shifting and International Tax Reform at American Tax Association Mid-Year Meeting (February 2015)

Panelist, Global Tax and Treasury Strategy Capturing, Communicating and Retaining

Value in a Fast-Changing World at Deloitte International Tax Conference at Villanova University (November 2014) 

Panelist, Selected BEPS Issues, University of Florida Levin College of Law International Tax Symposium (October 2014)    

BEPS Going Final -- the OECD moves towards final deliverables on Country by Country Reporting, Hybrids, and Treaty Abuse, IFA USA Westchester Branch (May 2014)

Memberships and Affiliations

  • International Fiscal Association, Miami Chapter, Member, Regional Council, DC Chapter, Member, Advisory Committee
  • National Tax Association, Member
  • American Bar Association, Member


Georgetown University Law Center, LL.M.

  • with distinction

Yale Law School, J.D.

Barnard College, B.A.

  • magna cum laude
  • Phi Beta Kappa

Previous Experience

Ivins, Phillips & Barker, Chtd., Of Counsel

Tax Analysts, Contributing Editor, Tax Notes International


  • District of Columbia
  • New York

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