FacultyFaculty/Author Profile
Erica L. Gut

Erica L. Gut


San Francisco, CA, USA

Erica is a Managing Director with PwC’s FSR group (Financial Instruments, Structured Products and Real Estate) in the San Francisco office. She has significant experience working with the financial products, structured finance and real estate groups on product related tax issues and treasury planning, including the Foreign Account Tax Compliance Act.

Erica joined PwC in August 2011 after a career in New York, Philadelphia and London as a tax lawyer, banker and in-house tax adviser.  She started working in New York and then moved to Philadelphia where she became a partner at Pepper Hamilton.  She then relocated to London where she lived for 18 years working for a variety of investment banks.  She was most recently the head of the tax advisory group at Merrill Lynch (latterly Bank of America) in London where she managed the product support and control function.  She has extensive experience working with the US and international tax issues associated with complex financial instruments.

Typical engagements Erica has led or participated in:

  • Assessment and implementation of FATCA  for a variety of clients including banks, fund managers, private equity funds and other investment vehicles.
  • Advising on effect of FATCA on structured products, derivatives and securitization vehicles.
  • Analysis of broker-dealer tax positions and valuation of financial instruments for tax purposes.
  • Tax analysis of complex structured products and derivative transactions.
  • International corporate and financial institution treasury tax issues.
  • International tax issues associated with outbound operations of US companies.

Erica holds a BA with Honors from the University of Leeds. She received her JD and Master of Laws in Taxation from New York University School of Law.

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