Jonathan Silverstein Email & Phone Number

Potomac, Md, Us

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Washington National Tax Services - International Tax Services

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Washington National Tax Services - International Tax Services

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London, Gb

Create PowerPoint presentations for Israeli clients providing advice on their intergroup transactions. Those presentations focus on identifying and mitigating U.S. permanent establishment, U.S. withholding tax, and Subpart F income exposure. Write memorandums on U.S. international and corporate tax issues. The topics of those memorandums have included: the limitation on benefits provision of the U.S.-Cyprus tax treaty; the anti-conduit rules under Treas. Reg. § 1.881-3; classification of distributions as dividends, return of capital or capital gain under IRC § 301(c); and ownership of intangible property under Treas. Reg. § 1.482-4(f)(3). Perform research regarding specific client questions and as part of larger projects. This research has covered: treatment of stock redemptions under IRC §§ 302 and 304; qualification for tax-free treatment under IRC § 355; the inversion rules under IRC § 7874; and treatment of a subsidiary company’s use of parent stock to compensate employees under Treas. Reg. § 1032-3, among other topics.Write detailed emails to clients describing whether the client is a CFC or PFIC, or both a CFC and PFIC. Those emails are based on an analysis of each client’s shareholder table, balance sheet, and profit and loss statements.

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Wrote memorandums on U.S. international and corporate tax issues. The topics of those memorandums have included: whether an intergroup reorganization would qualify as a tax-free reorganization under IRC § 368(a)(1)(D); the increased limitation on the use of NOLs after an ownership change under Notice 2003-65; whether an Israeli subsidiary that is a CFC would satisfy the substantial contribution test under Treas. Reg. § 1.954-3(a)(4)(iv); whether a conveyance of intellectual property from an Israeli company to a U.S. company would be considered a sale or license and whether the consideration paid would be considered royalties; and whether the presence of employees of an Israeli company at a construction site in the United States would constitute a U.S. permanent establishment.Created PowerPoint presentations for Israeli clients that analyzed whether a permanent establishment would exist in the United States and provided advice on how to reduce the risk that a permanent establishment would arise. Those PowerPoint presentations primarily focused on the activities that corporate officers perform in the United States.Created PowerPoint presentations that advised clients on how to avoid generating foreign base company sales income as a result of sales that take place outside a CFC’s country of incorporation.

Researched laws from all 50 states relevant to trust formation, trust administration, creditors’ rights against trust beneficiaries, funding of trusts and trustee responsibilities, among other areas. Updated the Multistate Guide to Trusts and Trust Administration based on this research to reflect recent changes to state law.

Read briefs filed as part of § 2255 claims, social security appeals and patent infringement actions. Researched case law and regulations regarding those claims; drafted official reports and recommendations based on this research.

Reviewed articles on derivatives in law journals and financial publications. Focused particularly on correlations between structured products and the degree to which issuing corporations operate with high effective leverage.

Reviewed briefs filed as part of Social Security and Supplemental Security appeals. Researched case law and regulations relevant to those appeals; drafted official reports and recommendations based on this research.

Rye, Ny, Us

Ascertained and corrected discrepancies between trading positions as reported on internal databases and by prime brokers. Performed a variety of research tasks.

Master Of Laws (Llm)

Education record

Bachelor Of Arts (B.A.)