Practices
Education
- J.D.Harvard Law Schoolcum laude2003
- A.B.Princeton Universitysumma cum laude1998
Layla J. Asali practices in a broad range of federal income tax matters, with an emphasis on the taxation of cross-border transactions and business activities. She advises U.S.-based and foreign-based multinational clients on international tax issues, including mergers and acquisitions, intellectual property transactions, supply chain planning, and financings.
Since the passage of the Tax Cuts and Jobs Act of 2017 (TCJA), a significant portion of Layla's practice has involved advising clients on the new international tax provisions of the tax reform legislation, including the base erosion and anti-abuse tax (BEAT), the section 965 transition tax, the global intangible low-taxed income (GILTI) regime, foreign tax credits, and the deduction for foreign-derived intangible income (FDII).
In addition to her consulting practice, Layla has experience representing clients before the Internal Revenue Service (IRS) National Office in obtaining favorable private letter rulings and resolving federal income tax controversies at the audit level and at IRS Appeals. She has also represented clients before the U.S. Department of the Treasury on regulatory and policy matters.
Layla is a frequently sought speaker on international tax matters and is an emerging authority on the international tax provisions of the Tax Cuts and Jobs Act. She has published articles in journals, including BNA Tax Management International Journal, BNA Tax Management Memorandum, the CCH International Tax Journal, and Tax Notes International. Layla is the former Chair of the DC Bar Taxation Community and she currently serves as a Member of the Taxation Community's Steering Committee. She has twice been named one of International Tax Review's Women in Tax (2016 – 2017).
- Advice and counseling with respect to technical issues arising under the transition tax, including the definition of cash equivalents.
- Counseling and advocacy related to the unintended consequences of the GILTI and BEAT regimes, including engagement with policymakers.
- Advised a U.S.-based natural resources company on the U.S. tax consequences of restructuring its international operations.
- Represented a foreign-based insurance company as special tax counsel in connection with an $800 million acquisition of a U.S. business.
- Counseled a foreign-based multinational on U.S. international tax and transfer pricing issues in connection with a restructuring of foreign operations held by its U.S. group.
- Advised a U.S.-based retail company on U.S. tax aspects of financing Canadian operations and managing its cross-border supply chain.
- International Tax Review: Women in Tax Leaders, 2016 - 2017
- Legal 500: Tax: International Tax, 2014 - 2019
- Legal 500: Tax: Non-Contentious, 2016, 2018 - 2019
- Legal 500: Tax: Contentious, 2019
- Washington, DC Super Lawyers®: Super Lawyer, Tax, 2018 - 2019
- Washington, DC Super Lawyers®: Rising Star, Tax, 2014 - 2017
- The National Law Journal, DC Rising Star, 2014
- Former Chair, Taxation Community, District of Columbia Bar (2016 – 2017)
- Member, Steering Committee, Taxation Community, District of Columbia Bar
- Member, Section of Taxation, American Bar Association
- Member, International Fiscal Association
Bar Admissions
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District of Columbia
Layla Asali and Rocco Femia will present at the George Washington University Law School 32nd Annual Institute on Current Issues in International Taxation on December 19, 2019.
Layla Asali and George Hani will speak at the 15th Biennial Parker C. Fielder Oil and Gas Taxation Conference on November 21, 2019, in Houston, Texas.
Houston, Texas
Layla Asali will speak at the Tax Executives Institute's (TEI) 2019 Annual Conference on October 29, 2019 in New Orleans. Asali will present, as part of a panel, "The Final BEAT Regulations: What
New Orleans, LA
Washington, DC, October 1, 2019 – Miller & Chevalier today announced that the firm's Tax Department was named a Tier 1 U.S.
Layla Asali commented on recent regulations released by the U.S.
Under immense pressure to devise a fair and administrable solution for taxing digital businesses by 2020, the OECD yesterday released a public consultation document to test the waters with a potent
On June 14, 2019, the Department of Treasury (Treasury) and the Internal Revenue Service (IRS) simultaneously issued proposed regulations (GILTI Proposed Regulations)1 and final regulati
On March 4, 2019, Treasury and the IRS issued proposed regulations (Proposed Regulations) under section 250.1 The 2017 Tax Cuts and Jobs Act added section 250, which provides a deduction
On December 13, 2018, the Department of Treasury (Treasury) and the Internal Revenue Service (IRS) issued proposed regulations (Proposed Regulations) under section 59A, the base erosion and anti-ab
On November 26, 2018, the Department of Treasury (Treasury) and the Internal Revenue Service (IRS) issued proposed regulations (Proposed Regulations) under section 163(j).1 The 2017 Tax