US Taxation of IP After Tax Reform
The new tax law has had some important changes relating to taxation of IP. Such changes include a new tax on certain global income...
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About Me
I focus my practice on U.S. tax planning and tax controversy matters, with an emphasis on international tax planning (inbound and outbound) and restructurings, mergers and acquisitions and transfer pricing. I represent clients from a diverse set of industries and geographic areas. I have represented a number of Fortune 500 companies in U.S. federal income tax matters and have successfully represented clients in federal tax controversies at all levels.
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Taxation of Intellectual Property
My colleagues and I co-authored a chapter in Taxation of Intellectual Property under Domestic Law, EU Law and Tax Treaties, which is a...
Holding Company Structures after TCJA
Is a holding company structure still useful after TCJA? It depends on the facts. A holding-company structure might reduce...
IRS Updates Questions and Answers about Reporting Related to Section 965 on 2017 Tax Returns
The IRS published updated Section 965 FAQ on 4/13/18, which may be relevant for sec. 965 payments due. Sec. 965 payments need to be...
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