Mark Hamilton Email & Phone Number

Boulder, Colorado, United States

Boulder, Colorado, United States

I represent individuals, public and private companies on federal and state income taxation issues including transactional and planning matters. Advise clients on structuring tax-free and taxable acquisitions and dispositions, tax-free spin-offs, and internal restructurings, including providing opinion letters and seeking advance rulings from the IRS. I combine my policy and transactional background to advise clients on certain specialized tax issues, such as international reporting obligations and penalty abatement. I advise clients on digital currency transactions and conversions and on the intricate tax rules that govern investment and structure. I advise clients on a broad range of domestic tax policy issues, including corporate, partnership, healthcare, tax-exempt organizations, energy, state and local parity acts, income tax accounting, estate and gift, and tax procedure and administration.

Anchorage, Alaska Area

Inaugurated Tax Department for this Alaskan Native Corporation with $4B in revenue and 12,000 Native Alaskan shareholders. Responsible for the preparation, review, and audit administration of all Federal, State, and International Income Tax compliance, controversy and Tax planning. Served as advisor on all Property Tax and Sales Tax issues and monitored Federal and State Tax legislation while serving as a technical advisor to colleagues in other departments and the C-Suite. In collaboration with the IRS, offered strategic recommendations to facilitate closing Federal Income Tax audit cycles. Formulated Tax strategies in support of Arctic Slope’s Finance Department, returning millions of dollars in cash flow. Worked directly with, and managed, the Big 4 and Tax Counsel throughout the U.S. to resolve significant Tax issues totaling tens of millions of dollars.

Wichita, Kansas Area

Responsible for Federal and State Tax litigation, which included all phases of Tax Controversy from Administrative Appeals through litigation. Drafted Federal and State Tax Protests, managed Administrative Appeals, supervised and directed local Counsel and routinely negotiated settlements. Prepared an in-house Attorney-Client Privilege manual. Drafted Master Service Agreements with Big-4 Accounting firms, reflecting the latest Attorney-Client Privilege Tax developments.

Denver, Co

Responsible for litigating Federal and State Tax controversies. Interacted with the Internal Revenue Service and State Tax attorneys on a routine basis. Reviewed and conducted due diligence on numerous merger and acquisition proposals. Managed 15 contract attorneys.Successfully litigated three United States Tax Court matters. Gained substantial experience in IRS Appeals Mediation and Panel issues, including drafting relevant Closing agreements and Technical Advice Memorandum requests. Resolved a variety of State and Local Tax issues, which resulted in tax and interest savings of millions of dollars per year.Advised on tax issues for Senior Executives (including use of corporate aircraft) and managed the FAA tax practice. Provided withholding advice for H-1B visa holders. Experienced in Subpart F, CERCLA, FCPA and Boycott tax issues. Provided tax law assistance to Human Resources, Payroll, Accounts Payable, Employment Law, Treasury, and Business Development. Attorney Client Privilege expert.

Bentonville, Ar

Responsible for establishing the Research and Tax Planning group within the Tax Department. Managed and supervised four Attorneys, providing Tax Research and Planning to both the internal Income Tax and International Tax Departments. Implemented a State Tax LP entity restructure; implemented Check-the-Box restructuring; established a Captive Insurance Company; analyzed corporate business plans and provided advice on their Tax consequences; conducted research into tax laws and rulings; recommended company tax strategies and reporting methods for limiting or avoiding Tax liabilities.Highly skilled in leading multiple CPA firms and multi-tasked teams to achieve the organization’s Tax objectives.

Kalamazoo, Michigan, United States

In Stockholm: Primarily responsible for developing tax-efficient structures for European, corporate and finance transactions including providing strategic Tax advice and constructive solutions to U.S. and European Tax problems. Active and direct involvement in Pharmacia’s M&A, including the consolidation of entities throughout Europe.Created a European “tax shop” from the ground up, to assist European entities with a broad range of Tax services, including local dispute resolution and general Tax advisory services. Consulted with business services on intellectual property licenses, Tax Sharing Agreements and Tax sourcing decisions.In Kalamazoo: Responsible for Federal and State Tax litigation and Federal, State, and International Tax Research and Planning. Successfully resolved various Tax issues, saving more than $42 million over a four-year period.Experienced in Transfer Pricing issues and implementing worldwide Transfer Pricing Policies; sec. 936 corporations’ compliance; Foreign Sales Corporations; international reorganizations; Foreign Tax Credits; Earnings and Profits; and advisor on Foreign Tax Boycotts. Tax Counsel for the business acquisition area and advised on more than 125 in-bound and out-bound agreements. Significant transactional experience with acquisitions greater than $100 million.Responsible for Subpart F calculations and review of local entity Form 5471. Previously Taxed Income strategy (“PTI”) allowed Affiliated Group to use consolidated PTI. Research and Development Tax Credit expert and author of State Research Tax Credit legislation. Managed Canadian Research Tax Credit audit. Worked closely with Government Affairs unit to proactively monitor tax legislation.

Ll.M. In Tax, Tax Law/Taxation

Bachelor Of Science - Bs, Accounting

Doctor Of Law - Jd, Law