ABOUT THE AUTHORS James M. Peaslee is a tax partner with the law firm of Cleary, Gottlieb, Steen & Hamilton, New York City. Mr. Peaslee is a past chair of the Tax Section of the New York State Bar Association. He holds an L.L.M. degree in taxation from New York University, a J.D. from Harvard University, and B.A. and M.A. degrees in Economics from Yale University. David Z. Nirenberg is a tax partner with the law firm of McKee Nelson LLP, New York City. He has played a significant role in the structuring of a wide variety of innovative domestic and cross-border financial products. He received his J.D. from Columbia University, an M.B.A. from Boston University, and a B.S. from Cornell University.