- 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 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 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 Vice Chair of the American Bar Association's Foreign Activities of U.S. Taxpayers (FAUST) 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.
- Chambers USA: Tax (District of Columbia), 2021
- International Tax Review: Women in Tax Leaders, 2016 - 2017
- Legal 500: Tax: International Tax, 2014 - 2021
- Legal 500: Tax: U.S. Taxes: Non-Contentious, 2016, 2018 - 2021
- Legal 500: Tax: U.S. Taxes: Contentious, 2019 - 2020
- Washington, DC Super Lawyers®: Super Lawyer, Tax, 2018 - 2020
- Washington, DC Super Lawyers®: Rising Star, Tax, 2014 - 2017
- DC Bar Capital Pro Bono Honor Roll, 2016 - 2017
- The National Law Journal, DC Rising Star, 2014
- Former Chair, Taxation Community, District of Columbia Bar (2016 – 2017)
- Member, Taxation Community, District of Columbia Bar
- Member, Section of Taxation, American Bar Association
- Vice Chair, Foreign Activities of U.S. Taxpayers (FAUST) Committee, American Bar Association
- Member, International Fiscal Association
- Fellow, American College of Tax Counsel
District of Columbia
Layla Asali and George Hani will speak at Practising Law Institute's (PLI's) Tax
Layla Asali will speak on the "International Tax Update" panel at the 32nd Annual Philadelphia Tax Conference on November 9, 2021.
Washington, DC, September 24, 2021 – Miller & Chevalier today announced that Members Layla J.
Tax Member Layla Asali commented on an August 20 ruling from the Internal Revenue Service (IRS) Office of Chief Counsel involving a taxpayer that wanted to amend its tax returns to claim foreign ta
On September 29, 2020, the Treasury Department and IRS issued final and proposed regulations addressing a host of issues relating to the foreign tax credit, including proposed regulations that cont
In this article, Layla Asali discusses various tax policy issues raised by disrega
On September 1, 2020, Treasury and the IRS released additional guidance under section 59A, the base erosion and anti-abuse tax (BEAT) added by the 2017 Tax Cuts and Jobs Act.1 These fina
On July 9, 2020, Treasury and the IRS released final regulations under section 250, which provides a deduction for a domestic corporation's foreign derived intangible income (FDII) and global intan
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