Partner
Current- Advises clients on international, federal, and state corporate and individual taxation with an emphasis on risk management, FIN 48 planning and compliance, FATCA planning and compliance, and other reporting and disclosure issues.- Provides complete representation at IRS Exam and Appeals.- Provides advice on employment, excise, gift, and estate tax issues.- Provides advice on banking issues such as third-party liability, back-up withholding, and withholding reporting requirements; tax-exempt interest; REO costs; bad debts; nonaccrual interest; worthless stock; and valuations.- Provides advice on insurance issues including captive insurance company formation and defense, split-dollar life insurance, allocation of reinsurance under IRC section 845, and provides review of NAIC annual statements.- Provides advice on employee benefit plans; transfer pricing; accounting methods; the research credit and other incentives and credits. Leads the firm in providing its clients with audit defense services for these issues. - Practice leader in alternative dispute resolution, including arbitration, mediation, Pre-Filing Agreements, and Fast-Track Settlement.- Provides assistance with 9100 relief for missed elections and works with IRS Service Centers to correct errors to clients’ accounts.- Provides advice on ruling requests and the filing of claims for refund.- Provides advice on actual and anticipated federal and international tax disputes.- Provides advice on unclaimed property.- Former IRS Insurance Industry Counsel. - Provided advice and guidance to the IRS Examination, Collection, and Criminal Investigation Divisions, as well as to the IRS Service Center Directors and the Service’s Taxpayer Advocates.
