Marsha Laine Dungog

Talks

• 'Returning to Oz for Good,' Withers US-Australia Shindig - February 20, 2026, moderator

• 'Estate planning considerations for boomerang families,' Withers US-Australia Tax and Estate Planning Symposium - February 19, 2026, speaker

• 'Expatriating and life insurance as estate planning tools,' Withers US-Australia Tax and Estate Planning Symposium - February 19, 2026, moderator

• 'In transit: staying compliant between the IRS and the ATO,' Withers US-Australia Tax and Estate Planning Symposium - February 19, 2026, moderator

• 'Recent Trends and Developments: International Tax and Wealth Transfer Planning for Globally Mobile Asian Families,' Hawaii Tax Institute 62nd Annual In-Person Conference - November 5, 2025, speaker

• 'Cross-Border Estate Planning Traps for the Unwary,' STEP Western Australia Annual Conference - September 26, 2025, speaker

• 'US-AUS Cross-Border Tax and Estate Planning Issues in the Trump Administration,' - STEP Western Australia Policy Committee - September 25, 2025, speaker

• 'Life, Death and Ressurection: International Tax and Estate Planning for Globally Mobile Families,' SFEPC Annual Estate Planning Symposium & Summer Social - June 5, 2025, speaker

• 'Is it time to expatriate?' Washington State CPA International Tax Conference - May 15, 2025, speaker

• ​​​​'New Zealand and Australia immigration, tax and investment - What you need to know,' Withers New Zealand and Australia Reception and Seminar - April 24, 2025, moderator

• 'US-Australia tax developments' and 'US-Australia estate planning considerations,' Withers US-Australian Tax and Estate Planning Symposium - February 11, 2025, panelist

• 'Returning to Oz: Your Checklist for the Big Move Back,' Withers US-Australia Shindig and Seminar - February 7, 2025, moderator

• 'Managing Foreign Bequests and Legacy Structures,' The Tax Institute Death & Taxes Conference - October 10, 2024, presenter

• 'Navigating North America: Key Considerations for Moving, Investing,and Planning in Canada and the US,' Withers modern families navigating through trustplanning and tax codes event - October 1, 2024, presenter

• 'Mateys ForEVER: Life, Death and (US) Taxes,' STEP Victoria-Tasmania Conference - July 29, 2024, presenter

• 'Cross-Border Curb Appeal: Legal Do's and Don'ts for Foreign Persons Investing in U.S. Real Estate,' Beverly Hills Bar Association - June 26, 2024, co-presenter

• 'International Estate Planning for Canada and Mexico,' 46th Annual UCLA/CEB Estate Planning Institute - April 19, 2024, co-presenter

• 'Collections, Collection Due Process Hearings and International Penalties,' American Bar Association Tax Section 2024 Midyear Tax Meeting - January 18, 2024, co-presenter

• 'US Estate Considerations for Cross-Border Estates,' The Tax Institute's Death and Taxes Conference - October 11, 2023, co-presenter

• 'Calling all Brits! Updates on International Tax & Estate Planning, UK Pensions, Immigration and More! - Everything Expats Need to Know,' British-American Business Council - April 26, 2023, panelist

• 'US Tax Treatment and Reporting of Cross-Border Pensions and Retirement Plans,' USC 2023 Tax Institute - January 24, 2023, co-presenter

• 'Planning for US Persons with Foreign Assets,' Redwood Empire Estate Planning Council in Sonoma, CA - January 4, 2023, co-presenter

• 'What Every Estate Planner Needs to Know When Contacted by an Alien,' STEP Silicon Valley - November 16, 2022, co-presenter

• 'Controversies: Foreign Trusts and Gifts - Reporting Obligations, Compliance Issues and Challenging Those Egregious Penalties!' Hawaii Tax Institute 59th Annual In-Person Conference - November 6, 2022, co-presenter

• 'Planning with our Neighbors: U.S.-Mexico-Canada a Multinational Case Study,' California Lawyers Association 2022 Annual Tax Meeting - November 4, 2022, co-presenter

• 'Tax Treaties for the Estate Planner,' California Lawyers Association 2022 Annual Tax Meeting - November 4, 2022, co-presenter

• 'What every estate planner needs to know when contacted by an alien,' Kasner Symposium - September 8, 2022, co-presenter

• 'Foreign trusts and gifts - Reporting obligations, compliance issues, and challenging those egregious penalties!' California Lawyers Association Annual Estate and Gift Tax Conference - July 29, 2022, co-presenter

• 'US tax treatment and foreign trust reporting requirements for Canadian TFSAs and Retirement Compensation Arrangements (RCAs),' California Lawyers Association DC Delegation - May 9 - 11, 2022, co-presenter

• 'Tax treatment of inheritances and donations in Mexico, United States and Canada,' La Asociación Nacional de Abogados de Empresa (ANADE) Baja California's First Tri-national Seminar - February 17, 2022, co-presenter

• 'High net worth wealth transfer - Hot topics,' University of San Francisco Tax Seminar Series: Event 1 - January 25, 2022, panelist

• 'Spotlight on California: Grow Your Business in the State Where Innovation is Born,' US Commercial Service in Australia and New Zealand and the California Governor's Office of Business and Economic Development joint event - December 1, 2021, panelist

• 'Tips and Traps (or Hot Topics) in Dealing with International Taxpayers and Reporting,' CalLawyers Taxation Law Section 2021 Annual Meeting of the California Tax Bar and California Tax Policy Conference - November 4, 2021, co-presenter

• 'Hot Topics in Dealing with International Taxpayers and Reporting,' Sacramento Estate Planning Council - October 27, 2021, speaker

• 'LLC plus blocker - Australian businesses entering the US market,' Tax Talks Podcast - October 26, 2021, speaker

• 'Planning for US persons with foreign assets,' San Francisco Estate Planning Council - September 22, 2021, co-presenter

• 'Cross-Border Trusts and Estates: Tax 101,' Andersen in Canada webinar - September 21, 2021, panelist

• 'Does mateship really transcend borders? A discussion on U.S. and Australian legal and tax treatment of cross-border assets,' The Tax Institute's 2021 Death... & Taxes Conference - September 16, 2021, presenter

• 'Cross Border Investing and Planning Techniques - Triumphs and Tragedies II,' CalCPA presentation - August 19, 2021, co-presenter

• 'U.S. and Australian Legal and Tax Treatment of Cross-Border Assets,' Australian Tax Institute panel - August 1, 2021, presenter

• 'Cross Border Investing and Planning Techniques - Triumphs and Tragedies I,' CalCPA presentation - June 24, 2021, co-presenter

• 'Hot Topics on Dealing with International Taxpayers and Tax Treatises,' California Lawyers Association's Annual Estate and Gift Tax Conference - May 28, 2021, panelist

• 'Common cross-border income and estate planning issues when dealing with Canadians and Australians,' San Francisco Tax Club presentation - May 6, 2021, presenter

• 'US Tax Classification and Reporting Issues with Cross-Border Retirement Plans, Stock Options and Pensions,' STEP Los Angeles - US Taxation of Foreign Pensions - January 21, 2021, co-presenter

• 'What's next: 2021 foresight for individuals with US-Asia Pacific ties,' Withers webinar - January 13, 2021, co-presenter

• 'What's next: 2021 foresight for individuals with US-transatlantic ties,' Withers webinar - December 16, 2020, co-presenter

• 'Overview of US Estate Tax Regime,' presentation for Australian advisor audience - November 17, 2020, presenter

• 'Lesson 7: Cross Border Retirement Account Transfers,' Global Financial Planning Institute Master Class in 'US Inbound/Outbound International Financial Planning' - November 12, 2020, co-presenter

• 'Lesson 4: Treaties - Tax, Social Security and Estate Taxes,' Global Financial Planning Institute Master Class in 'US Inbound/Outbound International Financial Planning' - October 22, 2020, co-presenter

• 'U.S.-AUS cross-border estate planning,' Victoria Wealth Management webinar - October 8, 2020, presenter

• ‘Stuck in Lodi When You are From Rome or Timbuktu,' 16th Annual Jerry A. Kasner Estate Planning Symposium - September 25, 2020, co-presenter

• 'People in Tax,' American Bar Association Tax Section (Podcast) - July 2020

• 'Crossing Borders with COVID-19,' Tax Yak Podcast (Episode 38) - April 9, 2020

• 'What Happens To My International Assets When I Die?' Australian Unity Podcast (Episode 3) - March 17, 2020

• 'A Dive Down Under and Just Yonder-What Planners Need to Know When Dealing with the IRS,' STEP Victoria, Australia - February 2020, presenter

• 'US tax issues: a business perspective,' Tax Yak Podcast (Episode 37) - February 20, 2020

• 'Cross Border Estate Planning & Administration Challenges for Australians and U.S. Citizens,' Deakins University (Melbourne) and Victoria Wealth Management - February 2020, presenter

• ‘US Tax and Immigration Planning for Australians Acquiring U.S. Citizenship, Green Cards and Non-Immigrant Visas,' STEP Queensland - February 2020, presenter

• 'Taxation of Foreign Pensions: Application of IRC Section 402(b) and Avoiding Penalties for Non-Compliance,' Strafford Seminars - October 30, 2019, co-presenter

• 'Canadian Tax Matters of Interest for the International Private Client,' U.S. Commercial Service Breakfast Business Briefing, Calgary, AB, Canada - June 12, 2019, presenter

• 'How to Handle US Pensions Owned by Canadians,' MGTL University, Mount Royal University, Calgary, AB Canada - May 31, 2019, presenter

• 'U.S. and Canadian Personal Tax Considerations When Moving Across the Border,' 2019 Prairie Provinces Tax Conference & Webcast, Canadian Tax Foundation, Calgary, AB Canada - May 27, 2019, co-presenter

• 'When the IRS Goes Down Under: US Worldwide Taxation of Australians with US Connections,' Society of Trusts and Estates Practitioners (STEP) Australia National Conference, Brisbane NSW, Australia - May 15-17, 2019, presenter

• 'Advocating for Exemption of Canadian RESPs and RDSPs from U.S. Foreign Trust Reporting Requirements,' California Lawyers Association - Washington DC Delegation, District of Columbia, United States - May 5-7, 2019, co-presenter

• 'Owning US Property the Canadian Way,' RBC (Georgia) -Lennar-Remax/Excalibur Homeowner Seminars, Scottsdale-Mesa-Goodyear, Arizona United States - March 5-7, 2019, co-presenter

• 'Trump, Taxes & Cannabis,' RBC Private National Banking Conference, Toronto ON, Canada - November 7, 2018, co-presenter

• 'Mastering US Tax Reporting of Foreign Retirement Account Ownership and Distributions,' Strafford Seminars - October 3, 2018, co-presenter

• 'Is there Life After Wayfair? Top 10 Tips for Canadian Remote Sellers with US Customers,' - September 28, 2018, co-presenter

• 'C-Suite Executive Cross Border Issues for Tax Directors,' COST 2018 Canadian Tax Workshop for U.S. Companies, Oakbrook IL USA - September 26-28, 2018, co-presenter

• 'IRS Campaigns; Insights from the Tax Professional and IRS,' - September 18, 2018, co-presenter

• 'Canadian Tax Matters of Interest for the International Private Client,' U.S. Commercial Service Breakfast Business Briefing, Global Petroleum Show, Calgary, AB, Canada - June 13, 2018, presenter

• 'US Transition Tax, GILTI and FDII,' MGTL University, Mount Royale University, Calgary, AB, Canada - June 12, 2018, presenter

• 'US Tax Considerations for Canadian Businesses Expanding into the United States,' SelectUSA Canada Conference Program, Calgary, AB, Canada - April 12, 2018, presenter

• 'A Deep Dive Into What Planners Need to Know When Dealing with Our Foreign Neighbors,' 26th California Trusts & Estates Conference, California Bar Tax Section, San Francisco, CA - March 15-16, 2018, presenter

• 'US Tax Reform for Canadians Explained in Plain English,' Moodys Gartner Tax Law, Calgary. Canada - February 2, 2018, presenter

• 'A Deep Dive Into What Planners Need to Know When Dealing with Our Foreign Neighbors,' California Tax Section Annual Conference, Carlsbad, CA - November 3, 2017, presenter

• 'Canadian Tax Matters of Interest for the International Private Client,' U.S. Commercial Service Breakfast Business Briefing, Calgary, AB, Canada - June 14, 2017, presenter

• 'Canadian Tax Matters of Interest for the International Private Client,' U.S. Commercial Service Breakfast Business Briefing, Calgary, AB, Canada - June 1, 2016, presenter

• 'Common Cross-Border Issues for Tax Practitioners,' The Canadian Institute's Trusts and Estates Forum, Calgary AB - December 8, 2015, presenter

• 'Planning for Successful Entry into the United States: When Tax and Immigration Collide,' American Chamber of Commerce (Calgary & Edmonton Chapters), Alberta, Canada - March 28, 2017, presenter

• 'AICPA International Tax Seminar Course on Taxation of Individuals Living Abroad for AICPA Chapter in Indianapolis,' Indiana USA - November 2016, instructor

• 'US Taxation of Foreign Retirement Plans,' University of San Diego-Procopio International Taxation Institute 2016 International Tax Update: US-Mexico-Canada Cross Border Tax Issues, San Diego, California USA - October 20-21, 2016, presenter

• 'Tax Efficient Charitable Giving Webinar,' Moodys Gartner Tax Law - September 19, 2016, presenter

• 'US-Canada Income Tax Treaty: Tax Treaty Tickle Points,' Council on State Taxation 2016 Canadian Tax Workshop, Detroit, Michigan USA - September 21-23, 2016, co-presenter

• 'United States Taxation of Superannuation Funds for Members with a US Connection,' Australian Tax Institute 2016 National Superannuation Conference, Melbourne, NSW - August 23-25, 2016, co-presenter

• 'US Tax for US Citizens in Australia,' Sydney-Melbourne-Brisbane - August 22-24, 2016, presenter

• 'Residence, Citizenship, and Liability for Tax: US and Canada Rules,' Canadian Young Practitioners, Canadian Tax Foundation, Edmonton, AB, Canada - June 7, 2016, co-presenter

External publications

• 'Tax and disability in the UK: review of trusts and other savings options,' Institute for Fiscal Studies Tax Law Review Committee (TLRC) Discussion Paper - January 15, 2026, contributor

• 'Killing trusts softly: Can Australia abate Trump duties with Aussie super funds?'  Tax Notes International - October 6, 2025, co-authored

• 'Killing Trusts Softly: The Australia-Canada-U.S. Trust Paradox,' Tax Notes International - March 17, 2025, co-authored

• 'Foreign pensions and the US – what globally mobile individuals need to know to protect your retirement,' Withers Insight - February 29, 2024, featured

• 'International families in California – beware of the tax implications of community property,' Withers Insight - January 24, 2024, featured

• 'Frozen Out of the Great White North: Thawing the Canadian Real Estate Iceberg,' Withers Insight - February 3, 2023, co-authored

• 'How Will Canada's Foreign Buyer Ban Impact The US?,' Law360 - January 17, 2023, quoted

• 'Bringing Home the (Canadian) Bacon: U.S. Tax and Canadian Retirement Plans,' Tax Notes - October 17, 2022, co-authored

• 'Withers' Bet on Private Clients in California Is Powering US Growth,' The Recorder (subscription required) - June 14, 2022, quoted

• 'How I Made Office Managing Director: ‘Find Your Purpose and Nurture Community to Build Resilience' Says Marsha Dungog of Withers,' Law.com - February 16, 2022, featured

• 'Withers Launches US-Canada Cross-Border Practice in California,' Law.com International - December 8, 2021, featured

• 'Withers launches U.S.-Canada practice in San Francisco with new team,' Withers Insight - December 8, 2021, quoted

• 'Dixon: A Cautionary Case of U.S.-Australian Tax Issues,' Tax Notes - February 8, 2021, co-authored

• 'Proposed Estate Tax Closing Letter Fee Earns Sigh of Relief,' Tax Notes - December 30, 2020, quoted

• 'Implications for franking credits in US tax case,' SMSF Adviser - December 17, 2020, quoted

• 'Tax implications of Biden win for SMSF properties in US,' SMSF Adviser - November 10, 2020, quoted

• 'IRS removes one of four options to correct foreign reporting,' Accounting Today - November 9, 2020, co-authored

• ‘Should Canadian RESPs and RDSPs Be Exempted From Foreign Trust Reporting Requirements?' Tax Notes Federal - July 22, 2019, co-authored

• ‘US Reporting Obligations for the Life Insurance Settlement Industry,' Conference for Advanced Life Underwriting (CALU) Report - July 2019, authored

• ‘50 Ways to Leave - Tax Considerations For Departing Canadian Individuals,' Mondaq - March 5, 2019, co-authored

• ‘Trump Transition and GILTI Tax Captures Canadian Taxpayers', The Conference for Advanced Live Underwriting (CALU) Report - March 2018 (Vol 4), co-authored

• ‘Reporting Australian Superannuation Funds As Foreign Trusts For Tax Purposes,' Mondaq - October 9, 2018, authored

• ‘New IRS Campaigns On Withholding And International Individual Tax Compliance,' Mondaq - May 25, 2018, authored

• ‘The Impact of US Tax Reform on Australian Superannuation Funds and Beneficiaries,' Taxation in Australia - April 1, 2018, co-authored

• ‘The Top Ten US Tax Reform Changes That Will Impact Everyday Canadians,' Mondaq - January 19, 2018, co-authored

• ‘The U.S. Income Tax Treatment of Mexican Retirement Funds Owned by U.S. Persons,' 453 Tax Management Compensation Planning Journal Issue No. 11 - November 13, 2017, co-authored

• ‘What U.S. Workers Need to Know About Australian Superannuation Plans,' Bloomberg BNA Tax Management International Journal - August 11, 2017, co-authored

• ‘What US Workers Need to Know About Australian Superannuation Plans,' BNA Compensation Planning Journal - June 29, 2017, co-authored

• ‘How the super reforms impact US expats,' SMSF Adviser - May 12, 2017, authored

• ‘U.S. Income Tax Treatment of Australian Superannuation Funds,' Tax Notes International - October 10, 2016, co-authored

• ‘The United States Income Tax Treatment of Australian Superannuation Funds Owned by U.S. Persons,' California Tax Lawyer, Vol. 25, No. 3 - September 2016, co-authored

• ‘U.S. Taxation of Superannuation Funds: When the Super is NOT so super after all,' Moodys Gartner Tax Law - July 27, 2016, authored

Admissions

• California, 1996

• Michigan, 2005

• Alberta, Canada, 2019

Education

• Georgetown University Law Center, LLM in Taxation, with distinction, 1999

• Golden Gate University School of Law, JD, Certificate of Specialization in International Law, with honors, 1996

• University of the Philippines, BA Political Science, cum laude, 1993

Languages

• English
• Tagalog

Memberships

• Australian American Chamber of Commerce San Francisco, board member 

• Alberta Law Society

• California Lawyers Association (CLA)

• Michigan Bar Association

• Australian American Chamber of Commerce (San Francisco)

• Australian Tax Institute

• American Institute of Certified Public Accountants (AICPA)

• Canadian Tax Foundation

• Canadian Business Chicks

• California Society of CPAs (CalCPA)

• National Asian American Bar Association (NAPABA)

• U.S. Financial Institutions Regulatory Authority (FINRA)

• San Francisco Estate Planning Council

• San Francisco Tax Club
• San Francisco Foundation Professional Advisors Council 
• STEP Australia (Affiliate)

Key dates

• Year joined: 2020