- 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
District of Columbia
Layla Asali was quoted on the need for IRS guidance regarding the rules for previously taxed earnings and profits (PTEP) and mid-year distributions of current-year global intangible low-taxed incom
At the March 2020 Federal Bar Association Tax Law Conference, Asali discussed potential guidance on the section 245A dividends-received deduction (DRD) or participation exemption with Laura William
Miller & Chevalier attorneys to speak at the Federal Bar Association 2020 44th Annual Tax Law Conference on March 6, 2020, in Washington, DC.
Layla Asali and David Zimmerman will speak at the Houston Tax Executives Institute (TEI) 2020 Tax School on February 26, 2020, in Houston, Texas.
Layla Asali commented on the U.S. Department of Treasury's position towards the availability of foreign tax credits for foreign taxes paid with respect to payments to disregarded entities.
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