Audrey W. Ellis

B.A., Pennsylvania State University; J.D., Cornell Law School; L.L.M. in Taxation, Georgetown University Law Center. Audrey Ellis is a Director in the PricewaterhouseCoopers LLP Washington National Tax Services Office in Washington, D.C. Since joining PwC in 2008, Audrey has specialized in the taxation of partnerships, limited liability companies, and joint ventures. Audrey has been actively involved in assisting numerous public and private companies in addressing federal tax matters including, the structuring and negotiation of complex partnership arrangements; drafting requests for private letter rulings and closing agreements; providing advice with respect to IRS examinations and prefiling agreements; and, structuring partnership employee compensation arrangements. Prior to joining PwC, Audrey was senior counsel for the IRS Office of Chief Counsel (Passthroughs and Special Industries). During her nine years at the IRS, she worked closely with senior IRS and Treasury attorneys on several significant partnership projects including proposed regulations addressing the treatment of partnership options and convertible debt, and proposed regulations addressing the treatment of partnership interests (capital and profits) issued in connection with the performance of services. Audrey also drafted and reviewed private letter rulings on a number of issues including, rulings on partnership issues, including issues with respect to publicly traded partnerships; S corporation terminations and elections; and, the income taxation of trusts. Audrey has participated in a number of panel discussions with senior government attorneys and lectured on a number of tax topics at tax institutes throughout the United States.