Tracy Villecco is an attorney for the Office of Associate Chief Counsel (International) Branch 1 of the Internal Revenue Service, which has primary subject-matter jurisdiction over U.S. income and transfer tax treaties. She specializes in issues pertaining to hybrid arrangements, cross-border compensation, and foreign trusts. Ms. Villecco received her J.D. from the University of Notre Dame and her LL.M. in tax from the University of Denver. Before joining the IRS, she was an attorney-advisor at the U.S. Tax Court. Ms. Villecco is admitted to practice in Colorado and Illinois, and before the U.S. Tax Court and the U.S. Supreme Court.