Xueshu (“Shae”) Qian is special counsel in the firm’s Tax Practice Group. Her practice centers on tax planning, with particular depth in international tax, including the NCTI (formerly GILTI) and FDDEI (formerly FDII) regimes, foreign tax credit matters, U.S. minimum-tax regimes, and cross-border restructurings for inbound and outbound taxpayers. She helps clients model and optimize outcomes under various U.S. international tax provisions, navigating controversies involving the application of those rules, prepare comment letters on Treasury and IRS regulations, and secure closing agreements with the IRS.