Senior Counsel
CurrentPractice centers on taxation, with emphasis on international, corporate transactional and tax controversy matters. General business tax counseling and planning on a variety of issues, including business and tax structures for foreign investment in the U.S. (organizational and investment structures, FIRPTA, transfer pricing, branch profits, repatriation and treaty issues), outbound transactions and controlled foreign corporation issues, offshore account compliance issues, mergers and acquisitions, corporate reorganizations, S corporations, and LLC taxation. Significant transactional experience, having represented clients in a variety of industries. Develop effective planning approaches to minimize taxation. Represent clients before state taxing authorities, the Internal Revenue Service, the U.S. Tax Court, and U.S. District Court with regard to a wide variety of tax audits and litigation, including international tax audits, transfer pricing issues, spin-off and reorganization issues, refund litigation, treaty interpretation, corporate tax assessments, trust fund liability, sales and use taxation, state income tax allocation and apportionment issues, debt restructuring, and excise taxation. Handled IRS and state taxation audits, and substantial experience in resolving cases at the administrative level in a creative and cost effective manner.
