Ellen K. Harrison
Partner
ellen.harrison@pillsburylaw.com
Ms. Harrison’s practice covers a broad range of tax issues, including estate planning and administration, tax controversies, and income, gift and estate tax planning for individuals, businesses and charitable organizations. Ms. Harrison has significant experience drafting wills, trusts, powers of attorney, prenuptial agreements, buy-sell agreements, a variety of corporate documents, and family partnership agreements. Her tax controversy and estate litigation experience includes Internal Revenue Service (IRS) audits, IRS appeals, refund claims, and U.S. Tax Court litigation.
She has been recognized in Chambers USA, and is recognized as one of the nations best lawyers in The Best Lawyers in America.
Education
J.D., Harvard Law School, 1971 cum laude
B.A., University of Michigan, 1968 with highest honors
Admissions
District of Columbia, State of Maryland
U.S. Tax Court, U.S. Supreme Court
Affiliations
American College of Trust and Estate Counsel, Regent, International Estate Planning Committee (Past Chair); American Bar Association, Section on Real Property Probate and Trust Law (Liaison with AICPA); American Law Institute; and International Academy of Estate and Trust Law
External Publications
Estate Planning Under the Bush Tax Cuts, National Tax Journal, Issue 3, Volume 60, Sept-2007
U.S. Taxation of Foreign Trusts, Trust with Non-U.S. Grantors and Their U.S. Beneficiaries, ALI-ABA, 17-Aug-2007
Estate Planning Under the Bush Tax Cuts, National Tax Association Spring Symposium, 12-May-2007
10 Best Ideas I Am Willing to Share, New York State Bar Program, 10-May-2007
Planning for Families with Lulti-National Connections: The United States Prospective, International Academy of Estate and Trust Law, Boston, May-2007
Best Planning Ideas, New York State Bar, Jan-2007
Matrimonial Rights Upon Divorce and Death – The United States Perspective, IBC International Trust Tax Planning Summit, 30-Oct-2006
Moving the Situs of a Trust into or out of the U.S., ACTEC, 12-Oct-2006
U.S. Taxation of Foreign Trusts, Trusts with Non-U.S. Grantors and Their U.S. Beneficiaries, Nineteenth Annual Advanced ALI-ABA Course of Study on Sophisticated Estate Planning Techniques, Co-Authored by Elyse Kirschner and Carlyn McCaffrey, 06-Oct-2006
International Grant Making, the War on Terrorism, and the Impact of the Treasury, ACTEC, 06-Jul-2006
Tax Issues Relevant to Gifts to Foreign Charities, New York State Bar, 17-Mar-2006
Tax Considerations Relevant to a Transfer of a U.S. Establishment, IBC International Trust Tax Planning Summit, 15-Feb-2006
Protecting the Heirs: GST Planning during the Phaseout of Transfer Taxes, Society of Financial Services Professionals, 10-Oct-2006
Use of Trusts in Estate Planning, International Academy of Estates and Trust Law, May 2005
Generation Skipping Planning in Light of EGTRRA, ALI-ABA 9-Mar-2005 & Philip Heckerling Institute on Estate Planning, January 2005
We're Sorry. Your Exemptions Have Been Disconnected. Please Check the Number and Try Again Later., Philip Heckerling Institute on Estate Planning, 01-Jan-2005
Selected Planning Techniques, 39th Annual Southern Federal Tax Institute, 01-Oct-2004
Selected Planning Techniques, ACTEC Mid-Atlantic Regional Meeting, September 2004
Your Exemptions Have Been Disconnected. DO YOU KNOW WHERE YOUR EXEMPTIONS ARE AND HOW THEY GOT THERE?, ACTEC, Co-Authored by Thomas E. Peckham, July 2004
Planning with Grantor Trusts, 40th Annual Advanced ALI-ABA Summer Program at the University of Wisconsin Law School, 21-Jun-2004
Estate Planning in Uncertain Times: The Impact of the Economic Growth and Tax Relief Reconciliation Act of 2001 on Estate Planning, U.S. Trust Company Forum, 05-May-2003
Selected Cutting Edge Techniques, Advanced Tax Institute Conference, 2003
Ten Best Ideas I am Willing to Share, Heckerling Institute on Estate Planning, January 2003
Proposed Split-Dollar Regulations Offer Some Surprises, Multi-Jur, Co-Authored by Michelle Huhnke, July 2002
Planning for Carryover Basis That Can Be/Should Be/Must Be Done Now, Estate Planning, Vol. 29 No. 3, Co-Authored by Frank S. Berall, Jonathan G. Blattmachr and Lauren Y. Detzel, March 2002
Ten Best Ideas I Am Willing To Share, ACTEC, February 2002
Estate Planning After the Economic Growth and Tax Relief Reconciliation Act of 2001, Hebrew Home, January 2002
Dynasty Trust Planning Under Economic Growth and Tax Relief Reconciliation Act of 2001, University of Texas School of Law at Austin, October 2001
Chapter on U.S. tax rules applicable to foreign investors: Offshore Service, Spitz & Clarke, Co-Authored by Mitch Moetell, 2001
Charitable Giving And Tax Reform, Currents, 2001
Estate Planning for Non-U.S. Persons, 09-Aug-2000
Tax and Trusts for the International Client, The United States Perspective; Tax Planning for the Non-Resident US Citizen and Non-US Citizens Who Have Permanent Resident Status But Do Not Live in the US, American Bar Association Real Property Probate and Trust Law Section, Co-Authored by Carlyn S. McCaffrey, July 2000
Inbound Grantor Trusts, PLI, June 2000
Constitutional Issues in State Taxation of Trusts, District of Columbia Bar, 15-Mar-2000
Factors Relevant to Choosing the Best Split Interest Technique, ACTEC, 02-Mar-2000
Income and Estate Planning Opportunities Upon the Sale of a Closely Held Business, District of Columbia Bar, 15-Oct-1999
Intentionally “Defective” Grantor Trusts, Montgomery/Prince George’s County Tax Study Group, July 1999
Retained Annuities and Sales to Grantor Trusts; The Risks and Rewards, ALI-ABA, July 1999
Foreign Aspects of Charitable Remainder Trusts, ACTEC International Estate Planning Committee, June 1999
Post Mortem Income Tax Changes Under the Taxpayer Relief Act of 1997, ABA, November 1997
Life Insurance In Estate Planning, Women and Money Group, 08-Jul-1996
Planning With Grantor Trusts, Estate Planning Committee of the D.C. Bar, 10-Jun-1996
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