JOAN C. ARNOLD is a partner in Pepper Hamilton LLP, resident in the Philadelphia office, where she is the Chairwoman of the Tax Practice Group, and focuses her practice on federal and international income tax.  Joan is a Fellow of the American Counsel of Tax Counsel, and is the Chair of the ABA Tax Section Committee - U.S. Taxation of Foreigners and Tax Treaties.  Joan was a principal author of the Comments on Section 894 (Domestic Reverse Hybrid Entities), submitted by the ABA Tax Section on November 27, 2001.  In Philadelphia, she is on the Executive Board of the Philadelphia Tax Conference and is on the council of the Tax Section of the Philadelphia Bar Association.  A long term Adjunct Professor in the Graduate Tax program at Villanova Law School, Joan regularly teaches Taxable Acquisitions and Tax Free Mergers and Acquisitions, the International Tax Seminar and is presently teaching U.S. Taxation of Foreign Business Operations.  Before entering private practice, Joan was V.P. - Associate General Tax Counsel for Citicorp, a full time faculty member at Rutgers-Camden School of Law and a consultant in international tax to KPMG in its national office.  She holds a B.A. (Mathematics) from Wagner College, a J.D. from Villanova University School of Law, and an LLM (Taxation) from New York University School of Law.