Attorney in Associate Chief Counsel's Office - International, Branch 6Extensive experience with outbound and inbound transfer pricing (including cost sharing arrangements) transactions at the audit, appeals, and litigation stages. Evaluated strengths, weaknesses, and litigation risks of transfer pricing structures. Transactions included inbound and outbound restructurings and transfers of intangible property, services transactions, financial and financial product transactions, insurance transactions, and tangible property.Significant experience with FDII final regulations, including drafting and implementation of final regulations. Subsequent experience analyzing issues occurring in audits under statute (pre-regulation), proposed regulations, and final regulations applicability years.Delegate to OECD Working Party 6.

Broad tax controversy and planning experience on a wide array of international, domestic, and state and local tax issues. Example matters:--Negotiated extremely successful settlement at IRS Appeals of dispute involving athlete compensation and intersection of first amendment rights, privacy rights, and publicity rights--Evaluated validity of regulations issued under Administrative Procedures Act (APA)--Advised clients planning and on examination of transfers of intellectual property, addressing structuring, pricing, and transfer pricing documentation.--Advised clients on 877A expatriation exit tax and qualifying for exemptions.--Advised clients on federal and state and local tax obligations, and on Chapter 3 and Chapter 4 (FATCA) withholding tax obligations for payments made to non-U.S. executives and sports players.--Advised clients regarding the application of income tax treaties to certain cross-border payments.--Advised a multi-national corporations on the application of subpart F rules to cross-border investments.--Advised clients seeking pre-filing agreements to resolve factual and methodological concerns prior to filing a tax return.--Advised financial institutions and sports teams regarding 1099 and 1042 reporting obligations.--Advised multinational clients regarding impact of 956 and 385 on global cash pooling arrangements.--Organized and advised tax-exempt 501(c)(3), 501(c)(4), and 501(c)(6), including regarding UBIT exposure and structuring joint ventures with for-profit organizations--Advised cutting-edge lending companies regarding state and local tax nexus and filing obligations.--Provided complete representation to tenants with housing subsidies in eviction lawsuits in DC Superior Court, including serving as lead attorney in motions practice, mediations and settlement, and pre-trial preparation--Litigated consumer rights cases and consumer protection act matters.

Judicial Law Clerk to the Honorable Mark V. Holmes