Bob Stack is head of the firm's international tax practice group. His work for business clients has included structuring both inbound and outbound ventures, the establishment of efficient cross border structures, the formation of joint ventures and private equity funds and all aspects of international mergers and acquisitions. Bob also has extensive experience in the international tax aspects of e-commerce, including planning with respect to the cross-border ownership of intangible property, advising with respect to cross-border license arrangements, withholding issues, cost sharing, and similar issues. He has extensive experience in representing business clients before the Internal Revenue Service, including with respect to audits and appeals, competent authority proceedings, pre-filing agreements, private letter rulings, and advance pricing agreements.Bob's work for individuals includes representing U.S. and non-U.S. clients in connection with participation in the various IRS voluntary disclosure initiatives,including the 2011 Offshore Voluntary Disclosure Initiative (OVDI), as well as the Offshore Voluntary Disclosure Program (OVDP) announced in 2012.Specialties: Business Tax, International Tax, Tax Controversies, Subpart F, Transfer pricing, Foreign tax credits, Foreign currency, Withholding taxes, Dual consolidated loss rules, a wide variety of treaty issues, and voluntary disclosures