Photo of Jennifer Duval Lindy

Jennifer Duval Lindy

Senior Counsel

Education

University of Miami – B.B.A. with a minor in Legal Studies, May 2001

Nova Southeastern University – M.B.A., March 2003

Nova Southeastern University – J.D., May 2006

Emory University, International Law L.L.M., May 2007

University of Miami, School of Law, Taxation L.L.M., May 2008

Bar Admissions

Florida

Georgia

Court Admissions

U.S. Tax Court

Profile

Jennifer D. Lindy serves as Senior Counsel in the Tax Controversy & Litigation and International Tax Practice Groups. Jennifer represents individual, partnership/pass-through, and multinational corporate taxpayers with a special focus on cross-border and international tax issues in disputes with the IRS during all phases of the tax controversy and litigation process. Additionally, she has diverse experience in advising individuals, multinational entities, accountants, and other tax service providers with complex international tax matters, including U.S. inbound and outbound tax issues related to cross-border transactions, U.S. withholding tax, international tax compliance and reporting, and FATCA compliance for individuals and entities.

Before joining Chamberlain Hrdlicka, Jennifer worked in the International Tax Group at Ernst & Young LLP, where she spent over seven years advising high net-worth individuals and multinational corporations. Jennifer has five college degrees. She earned both a B.A. and L.L.M.T, with an additional concentration in international tax, from the University of Miami. She earned an M.B.A., with the highest ranking as a member of the Sigma Beta Delta Honor Society, and a J.D. from Nova Southeastern University. She also holds a L.L.M. in International Law from Emory University.

During law school, Jennifer interned at the IRS Office of Chief Counsel and was specially recognized in Estate of Lillie Rosen, et al., TC Memo 2006-115.

Overview of Practice Areas

  • International Tax, Dispute, and Compliance Matters
    • 2017 Tax Reform

    • Section 965 Repatriation Tax

    • Offshore Voluntary Disclosure Program (OVDP)
    • Streamline Domestic Offshore Procedure (SDOP)
    • Streamline Foreign Offshore Procedure (SFOP)
    • Delinquent International Information Return Submissions Procedure (DIIRSP)
    • Delinquent FBAR Submissions Procedure (DFSP)
    • Foreign account reporting (Form TD F 90-22.1, FinCEN Form 114, FBAR)
    • Foreign account tax compliance act (FATCA) for individuals and entities
    • Foreign asset reporting (Form 8938)
    • Controlled foreign corporations (Form 5471)
    • Foreign-owned U.S. corporations (Form 5472)
    • Foreign corporations with U.S. business (Form 1120-F)
    • Passive foreign investment company (Form 8621)
    • Foreign partnerships (Form 8865)
    • Foreign trusts (Form 3520 and Form 3520-A)
    • Foreign disregarded entities (Form 8858)
    • Foreign transfers (Form 926)
    • Non-resident alien returns (Form 1040NR)
    • Treaty-based tax return positions (Form 8833)
    • Closer Connection Exception (Form 8840)
    • Expatriation tax issues (Form 8854)
    • Foreign earned income exclusion (Form 2555)
    • Foreign tax credits for individuals and entities (Form 1116 and Form 1118)
    • Check-the-box foreign entity classification elections (Form 8832)
    • International withholding (Forms 1042, 1042-S, 8804, 8805, W-8BEN, W-8BEN-E, FATCA Self Certifications, etc.)
    • Foreign investment in real property tax act (FIRPTA)
  • Domestic Tax, Dispute, and Compliance Matters
    • Tax audits/examinations
    • Tax appeals with IRS Appeals Office
    • Tax Court litigation
    • Tax refund claims and litigation
    • Penalty abatement requests
    • Private letter ruling requests
    • Tax collection defense – liens, levies, collection due process hearings, installment agreements, etc.
    • Conservation easement disputes (Section 170)
    • Federal and state tax credit disputes
    • Captive insurance disputes
    • Reportable transactions (Form 8886)
    • Reasonable compensation disputes

Seminars & Presentations

  • “US Reporting and Withholding on Payments to Non-U.S. Persons: Section 1441, FATCA and FBAR,” Ernst & Young’s Jacksonville Tax Breakfast Series (May 2014)
  • “Documentation and Information Reporting from Foreign Affiliates: Forms 5471, 5472, 8858, and 8886,” A seminar on international informational return reporting, presented at the Tax Executives Institute 2014 International Tax Course (August 2014)

Professional Affiliations

  • State Bar of Florida – Tax Section

News

News

Publications

Articles & Publications

  • Chief Counsel Advice concludes when late-received documentation can support portfolio interest exemption, EY International Tax Alert (Hester, Lindy, Arbogast, & Blum, 2014)