Apportioning of Income for Nonresident Individuals

Ellen Swain is an experienced attorney specializing in taxation law, public service, and legal education. Her career began as a Judicial Law Clerk for the New Hampshire Superior Court, handling diverse legal issues like intellectual property disputes, criminal motions, and jury instructions. She then served as a Staff Attorney for the New Hampshire Public Defender, managing felony, misdemeanor, and juvenile cases, and litigating issues such as search and seizure, mental competency, and speedy trial rights.

Ellen developed her tax law expertise through roles as a Clinician in the Tax Appeals Assistance Program at the University of San Francisco, an Extern with the IRS Office of Chief Counsel, and a Legal Intern with the California Franchise Tax Board. She also served as a Special Assistant U.S. Attorney for the Northern District of California and chaired the Bar Association of San Francisco’s Section on Taxation.

Currently, Ellen is an Attorney IV at the California Franchise Tax Board, where she focuses on complex state and federal tax matters, multistate policies, and tax appeals. She previously served as Tax Counsel III at the Office of Tax Appeals, gaining further expertise in tax litigation.

Ellen is also a dedicated educator and mentor. She has worked with the Council on Legal Education Opportunity (CLEO), teaching law students skills in legal reasoning, briefing, and exam writing. Known for her analytical skills and commitment to public service, Ellen has built a career spanning over two decades as a leader in taxation law and legal education.

Oksana Jaffe is a Director at KPMG in the State and Local Tax group, specializing in California tax laws. Her expertise includes income and franchise taxes, market-based sourcing rules, cost-of-performance issues, and apportionment. She also serves as an adjunct professor at UC Hastings College of Law.

Before joining KPMG, Oksana was the Chief Consultant to the California Assembly Committee on Revenue and Taxation, where she advised legislators on tax laws, analyzed legislation, provided tax counsel during the annual budget process, and served as a liaison between the Assembly and state tax agencies. She also advised the Franchise Tax Board and the Executive Committee of the California State Bar’s Tax Section.

Oksana began her career as an international tax associate at Deloitte LLP in Los Angeles and later practiced international and federal corporate tax law as a tax attorney with Howard Rice in San Francisco. She holds a B.A. and M.A. in Philosophy from Kiev National University in Ukraine, a J.D. from Rutgers University School of Law, and an LL.M. in Taxation from NYU School of Law.

Cory Stigile specializes in tax controversies as well as business and international tax. His representation includes federal and state tax controversy matters, including sensitive tax-related examinations and investigations for individuals, partnerships, limited liability companies, and corporations. His practice also includes complex civil tax examinations, administrative appeals and tax collection proceedings (where he is widely respected for achieving meaningful resolutions of difficult tax collection issues). He has litigated cases in the U.S. Tax Court, the U.S. District Court, the Court of Federal Claims and the 9th Circuit Court of Appeals.

Mr. Stigile is a Certified Specialist, Taxation Law, The State Bar of California, Board of Legal Specialization. Mr. Stigile is also a CPA licensed in California.

Prior to practicing as an attorney, Mr. Stigile practiced in public accounting at KPMG LLP in federal taxation and then assurance. During law school, Mr. Stigile was a field placement intern with the IRS.