Professor of Law, University of Cincinnati College of Law
Professor Stephanie Hunter McMahon has taught courses in tax law and legal history at the University of Cincinnati College of Law since 2008, and while doing so has won two of the law school’s teaching awards, its faculty excellence award, and its award for scholarship.
To date, much of her scholarship explores the relationship between taxation and the public’s perception of taxation with respect to families and the application of administrative law to tax. Her interest in the development of tax policy led her to write Principles of Tax Policy for West’s Concise Hornbook Series. In the last two years, she has begun scholarship focusing on the tax treatment of disadvantaged groups, both women seeking abortions in states that do not provide access to care and the discriminatory tax treatment of inmate labor.
Her writings have been published in peer-reviewed journals, The Tax Lawyer (ABA journal), Florida Tax Review, and the Virginia Tax Review, as well as student-reviewed journals, such as Northwestern Law Review, Washington Law Review, and Michigan State Law Review. Professor McMahon received her J.D. from Harvard Law School and PhD in American history from the University of Virginia. Following law school, Professor McMahon practiced in the New York offices of Cravath, Swaine & Moore and Skadden, Arps, Slate, Meagher & Flom.
Partner, Jones Day
Ray Wiacek is one of the world’s leading international tax lawyers. He represents multinational corporations on cross-border financings, international acquisitions and reorganizations, and transfer pricing. He is particularly skilled at global planning involving intellectual property. Ray also defends his advice, favorably resolving tax disputes ranging from the proper pricing of foreign autos to the effectiveness of an agreement to share R&D costs worldwide. He is currently challenging the IRS’ anti-inversion regulations in court.
Ray negotiated and closed billions of dollars of cross-border financings for Bank of America against many of the leading banks in Europe. He led the worldwide team integrating Warner-Lambert and Pharmacia with Pfizer after Pfizer’s overhaul of those companies. This included the disposition of nonstrategic assets, such as Schick and Wilkinson Sword to Energizer and Chiclets and Dentyne to Cadbury. Ray also led the team that implemented a worldwide business and tax plan for Halliburton.
In addition to Bank of America, Pfizer, and Halliburton, representative clients have included Bridgestone/Firestone, Celgene, Dow Corning, H.J. Heinz, Isuzu Motors, JP Morgan, Transworld Oil, and United Coal.
Ray has testified many times on international tax matters before Congress and the Internal Revenue Service. He has been listed every year in the Chambers guide to best lawyers, with clients describing him as “pragmatic and deal oriented,” “an excellent negotiator,” with “superb technical skills and analytic ability.”
Of Counsel, Covington & Burling LLP
The Honorable Paul J. Ray is currently Of Counsel at Covington & Burling LLP where he advises clients on regulatory opportunities and challenges and helps them formulate and execute advocacy strategies for their regulatory policy priorities before the executive branch and Congress.
During the first Trump Administration, Paul held various senior positions at the Office of Information and Regulatory Affairs (OIRA) within the White House’s Office of Management and Budget, including as acting, and then Senate-confirmed, head of the office. As OIRA Administrator (the "regulations czar"), Paul supervised the review of hundreds of regulations from across the government, drafted numerous executive orders governing the regulatory process, and led the Administration’s regulatory reform effort. As a result of this experience, Paul is well-positioned to help clients understand and achieve regulatory policy priorities in the context of the government’s regulatory agenda and ongoing reform efforts.
Most recently, Paul was also the Director of the Roe Institute for Economic Policy Studies at The Heritage Foundation. In that role, he supervised the formulation of the Foundation’s economic and regulatory policy recommendations and provided technical assistance to congressional committees and staff regarding legislative changes to the regulatory process. In addition to his role at The Heritage Foundation, Paul also served as a Senior Advisor at a strategic advisory firm. Before his time in government, Paul practiced law at a law firm in Washington, specializing in administrative law matters.
Prior to his role at the White House, Paul was Counselor to the Secretary at the U.S. Department of Labor. There he led departmental efforts in high-profile rulemakings and helped formulate the Department’s legal positions and strategy.
Paul served as a law clerk to Supreme Court Justice Samuel Alito and as a law clerk to the Honorable Debra Livingston of the U.S. Court of Appeals for the Second Circuit.
Paul is a thought leader in the conservative legal movement and is a frequent commentator and speaker on regulatory policy and reform matters, including at law schools, professional gatherings, and other venues. He is the Chairman of Innovations in Peacebuilding International and the Regulatory Process Working Group of the Federalist Society’s Regulatory Transparency Project and a public member of the Administrative Conference of the United States. Paul is also an adjunct lecturer at the Hillsdale College School of Government.
Assistant Professor of Law, Stanford Law School
Gregory Ablavsky’s scholarship focuses on early American legal history, particularly on issues of sovereignty, territory, and property in the early American West. A lawyer and historian, his publications explore a range of topics including the history of the Indian Commerce Clause and the importance of Indian affairs in shaping the U.S. Constitution and the balance of power between states and the federal government. In 2015, the American Society of Legal History named him a Kathryn T. Preyer Scholar. He is currently writing a book based on his dissertation, “The Adjudicatory State: Sovereignty, Property, and the Law in the U.S. Territories, 1783-1803.”
Prior to joining the Stanford Law faculty in 2015, Professor Ablavsky was the Sharswood Fellow in Law and History at the University of Pennsylvania, where he taught courses on land use law and the legal history of empire and race. He clerked for Judge Anthony Scirica of the U.S. Court of Appeals for the Third Circuit. He was also a law clerk for the Native American Rights Fund in Washington, D.C.
Vice President, Global Policy, BSA | The Software Alliance
Aaron Cooper serves as Vice President, Global Policy with BSA | The Software Alliance. In this role, Cooper leads BSA’s global policy team and contributes to the advancement of BSA members’ policy priorities: data privacy and security, intellectual property, and trade. Cooper joined BSA in February 2016 as Vice President, Strategic Policy Initiatives.
Prior to joining BSA, Cooper served as the Chief Counsel for Intellectual Property and Antitrust Law for Chairman Patrick Leahy on the U.S. Senate Judiciary Committee. Most recently, Cooper was of counsel at Covington and Burling, where he provided strategic counseling and policy advice on a range of intellectual property, communications, and privacy issues. Cooper has also served as Legal Counsel to Senator Paul Sarbanes.
Cooper is a graduate of Princeton University and Vanderbilt Law School. He clerked for Judge Gerald Tjoflat on the U.S. Court of Appeals for the Eleventh Circuit.
Partner, Duane Morris LLP
Brian Pandya is Partner at Duane Morris LLP. A member of the firm’s Trial Practice Group, Brian represents technology, manufacturing, and healthcare companies in high-stakes litigation, arbitrations, investigations and appeals. He has served as lead trial counsel in a range of intellectual property, antitrust, complex commercial and white-collar matters. He also regularly counsels clients on cybersecurity and national security issues, particularly matters concerning emerging technologies and artificial intelligence.
Before joining Duane Morris, Brian served at the U.S. Department of Justice as Deputy Associate Attorney General from 2019-21, where he oversaw investigations and litigation undertaken by the Antitrust Division and Civil Division and served on several high-profile task forces and trial teams. Brian was also previously a litigation and IP partner at another prominent Washington, DC firm.
Brian clerked for Judge Leonard Davis on the United States District Court for the Eastern District of Texas. He is a two-time recipient of the Federal Circuit Bar Association’s Pro Bono Advocacy Award for work on behalf of military veterans and has served as volunteer federal public defender in the Eastern District of Virginia, among many other bar and community engagements.
Brian graduated cum laude from the University of Michigan Law School, where he was articles editor of the Michigan Telecommunications and Technology Law Review, and with honors and high distinction in mechanical engineering from Penn State University, where he received the Ralph Dorn Hetzel Memorial Award.
Partner, Shore Chan Depumpo LLP
Michael W. Shore practices in the areas of intellectual property commercialization, business litigation, and other select litigation matters. His intellectual property practice is multifaceted, aiding clients in commercializing their patent and copyright portfolios through strategic development, licensing and litigation. Mr. Shore currently represents clients ranging from Fortune 500 companies to individuals located in the United States, Japan, Great Britain, Luxembourg, Taiwan (ROC) and the People's Republic of China. Prior to forming Shore Chan DePumpo LLP, Mr. Shore headed the Intellectual Property Licensing and Litigation Practice Group as a partner at Akin Gump Strauss Hauer & Feld, LLP.
Assistant Professor of Law, Stanford Law School
Gregory Ablavsky’s scholarship focuses on early American legal history, particularly on issues of sovereignty, territory, and property in the early American West. A lawyer and historian, his publications explore a range of topics including the history of the Indian Commerce Clause and the importance of Indian affairs in shaping the U.S. Constitution and the balance of power between states and the federal government. In 2015, the American Society of Legal History named him a Kathryn T. Preyer Scholar. He is currently writing a book based on his dissertation, “The Adjudicatory State: Sovereignty, Property, and the Law in the U.S. Territories, 1783-1803.”
Prior to joining the Stanford Law faculty in 2015, Professor Ablavsky was the Sharswood Fellow in Law and History at the University of Pennsylvania, where he taught courses on land use law and the legal history of empire and race. He clerked for Judge Anthony Scirica of the U.S. Court of Appeals for the Third Circuit. He was also a law clerk for the Native American Rights Fund in Washington, D.C.
Vice President, Global Policy, BSA | The Software Alliance
Aaron Cooper serves as Vice President, Global Policy with BSA | The Software Alliance. In this role, Cooper leads BSA’s global policy team and contributes to the advancement of BSA members’ policy priorities: data privacy and security, intellectual property, and trade. Cooper joined BSA in February 2016 as Vice President, Strategic Policy Initiatives.
Prior to joining BSA, Cooper served as the Chief Counsel for Intellectual Property and Antitrust Law for Chairman Patrick Leahy on the U.S. Senate Judiciary Committee. Most recently, Cooper was of counsel at Covington and Burling, where he provided strategic counseling and policy advice on a range of intellectual property, communications, and privacy issues. Cooper has also served as Legal Counsel to Senator Paul Sarbanes.
Cooper is a graduate of Princeton University and Vanderbilt Law School. He clerked for Judge Gerald Tjoflat on the U.S. Court of Appeals for the Eleventh Circuit.
Partner, Duane Morris LLP
Brian Pandya is Partner at Duane Morris LLP. A member of the firm’s Trial Practice Group, Brian represents technology, manufacturing, and healthcare companies in high-stakes litigation, arbitrations, investigations and appeals. He has served as lead trial counsel in a range of intellectual property, antitrust, complex commercial and white-collar matters. He also regularly counsels clients on cybersecurity and national security issues, particularly matters concerning emerging technologies and artificial intelligence.
Before joining Duane Morris, Brian served at the U.S. Department of Justice as Deputy Associate Attorney General from 2019-21, where he oversaw investigations and litigation undertaken by the Antitrust Division and Civil Division and served on several high-profile task forces and trial teams. Brian was also previously a litigation and IP partner at another prominent Washington, DC firm.
Brian clerked for Judge Leonard Davis on the United States District Court for the Eastern District of Texas. He is a two-time recipient of the Federal Circuit Bar Association’s Pro Bono Advocacy Award for work on behalf of military veterans and has served as volunteer federal public defender in the Eastern District of Virginia, among many other bar and community engagements.
Brian graduated cum laude from the University of Michigan Law School, where he was articles editor of the Michigan Telecommunications and Technology Law Review, and with honors and high distinction in mechanical engineering from Penn State University, where he received the Ralph Dorn Hetzel Memorial Award.
Partner, Shore Chan Depumpo LLP
Michael W. Shore practices in the areas of intellectual property commercialization, business litigation, and other select litigation matters. His intellectual property practice is multifaceted, aiding clients in commercializing their patent and copyright portfolios through strategic development, licensing and litigation. Mr. Shore currently represents clients ranging from Fortune 500 companies to individuals located in the United States, Japan, Great Britain, Luxembourg, Taiwan (ROC) and the People's Republic of China. Prior to forming Shore Chan DePumpo LLP, Mr. Shore headed the Intellectual Property Licensing and Litigation Practice Group as a partner at Akin Gump Strauss Hauer & Feld, LLP.
Regulation and Red Tape: Tax Inversions: Unpacking the Pfizer Case
Stephanie McMahon, Raymond Wiacek, Paul J. Ray
In 2014, the pharmaceutical company Pfizer initiated a restructuring, only to encounter impediments from the...
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Can Tribal Immunity Shield Blockbuster Drugs from PTAB Scrutiny?
The Patent Trial & Appeal Board, an administrative panel created as part of the America...
New Frontiers for Tribal Immunity: Patents, Pharmaceuticals, and the PTAB
Gregory Ablavsky, Aaron Cooper, Brian Pandya, Michael Shore
The courts and Congress have long acknowledged the sovereign status of Native American tribes. Tribes,...
New Frontiers for Tribal Immunity: Patents, Pharmaceuticals, and the PTAB
TeleforumTopics
Federal Court Strikes Down Obama-era Corporate Anti-Inversion Tax Regulations
In April 2016, The United States Department of Treasury employed a technique it commonly...