FacultyFaculty/Author Profile

Audrey W. Ellis

U.S. Department of the Treasury
Attorney-Advisor, Office of Tax Policy
Washington, DC, USA


EXPERIENCE
DEPARTMENT OF TREASURY, OFFICE OF TAX POLICY
Attorney Advisor (September 2017-Present)

PRICEWATERHOUSE COOPERS LLP  
Washington National Tax Services, Mergers & Acquisitions
Managing Director (July 2013-September 2017); Director (July 2010-July 2013); Manager (September 2008-July 2010)
Specialize in the taxation of partnerships, limited liability companies, and joint ventures. Assisted numerous public and private companies in addressing federal tax matters, including the structuring and negotiation of complex partnership arrangements; drafting requests for private letter rulings and closing agreements; providing advice with respect to IRS examinations and prefiling agreements; and structuring partnership employee compensation arrangements.  Participated in panel discussions and presented on partnership tax topics at tax institutes throughout the United States.  Coauthored articles on partnership tax topics including debt workouts, the definition of property, self-employment tax, and the partnership non-compensatory option regulations.  

• OFFICE OF CHIEF COUNSEL, IRS
Senior Counsel (October 2005−July 2008); Attorney Advisor (November 1998−October 2005) 
Division of Passthroughs and Special Industries.  Researched, drafted, and reviewed private letter rulings, regulations, field service advice, and special projects relating to the income taxation of trusts, partnerships, and subchapter “S” corporations.

  
EDUCATION
GEORGETOWN UNIVERSITY LAW CENTER, L.L.M., with Distinction, Taxation, February 2004
CORNELL LAW SCHOOL, J.D., cum laude, May 1998
  Editor, Cornell International Law Journal
  Concentration in Business Law and Regulation
PENNSYLVANIA STATE UNIVERSITY, B.A., High Distinction, Political Science, May 1995
  Minors: American Studies and Middle East Studies
  Honors: Dean’s List (all semesters); Phi Beta Kappa
  Study abroad: Tel Aviv University (Spring 1994)

BAR New York
 
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