Bozena M. Diaz

Bozena (Bonnie) has over 20 years of experience advising on the federal income tax aspects of mergers and acquisitions, spin-offs, and other divestitures. She regularly counsels clients on tax aspects of business and real estate joint ventures, restructurings and workouts, and taxable and tax-free reorganizations.

Bonnie’s practice spans the full lifecycle of transactions. In addition, a significant portion of Bonnie’s practice is devoted to international tax, including inbound and outbound planning, foreign tax credit optimization, Subpart F and GILTI compliance, withholding tax issues, FATCA, treaty interpretation, and structuring for controlled foreign corporations (CFCs) and passive foreign investment companies (PFICs). She also counsels on complex tax reporting matters such as 1099 and payroll compliance, PTEP calculations, and IRS disclosures.

Bonnie also regularly works with clients in the renewable energy sector, where she advises developers, investors, and project sponsors on the tax aspects of renewable energy transactions, including tax equity flips, power purchase agreements, and lease arrangements. She also has significant experience in structuring Qualified Opportunity Zone Fund investments for a range of clients and has been a frequent speaker on the subject for industry groups, bar associations, and real estate professionals. 

In the area of tax controversy, Bonnie has significant experience with representing clients before the IRS and state taxing authorities in audits, appeals, and voluntary disclosure matters. She has successfully negotiated significant reductions in federal and state tax liabilities on behalf of her clients.

In the area of employee benefits and executive compensation, Bonnie advises on the design, implementation, and compliance of qualified retirement plans (including 401(k) and pension plans), welfare benefit plans, and cafeteria plans. She regularly counsels clients on ERISA fiduciary responsibilities, COBRA, and the treatment of benefits in M&A transactions. Her executive compensation work includes structuring nonqualified deferred compensation plans, Section 409A compliance, equity incentive plans (such as stock options and restricted stock) and advising on Section 280G parachute payment issues. She frequently drafts and negotiates employment and severance agreements.

Prior to joining Archer, Bonnie was a partner and chair of the Tax Department at Cullen and Dykman LLP in New York, where she led the firm’s tax practice and advised on high-value, complex matters across a wide range of industries. She also held senior positions at several other leading regional and national firms.

Bonnie is fluent in English and Polish, and conversational in Spanish.