Chair, International Department
CurrentInternational Department Chair: Responsible for firm’s delivery of legal services to international clients; coordinate firm’s interaction with attorneys in foreign countries.Mergers & Acquisitions: Provide tax advice to efficiently structure M&A transactions and reduce tax on continuing operations.IC-DISC Planning: Implement IC-DISC strategies to obtain tax savings for U.S. manufacturers that export; draft implementation documents; design strategic structures; consult with accountants on maximizing the commission to an IC-DISC.Athletes & Entertainers: Conduct inbound and outbound planning for multi-national individuals in the music, equine and sports industries; negotiate central withholding agreements with the IRS for foreign athletes and entertainers to minimize their U.S. withholding obligations.Transfer Pricing: Coordinate all aspects of a multi-national client’s transfer pricing issues: draft transfer pricing documentation; negotiate advance pricing agreements with the IRS; litigate transfer pricing issues with the IRS; and draft intercompany agreements to implement tax saving transfer pricing strategies.Inbound Tax Planning: Develop and implement tax minimization strategies for foreign-owned companies; counsel clients with repatriation methods that take advantage of transfer pricing and avoid U.S. withholding taxes; advise clients on structures to avoid the U.S. taxing jurisdiction.Outbound Tax Planning: Develop and implement tax saving strategies for U.S.-based multi-national companies with foreign operations; assist clients with maximizing their foreign tax credits while avoiding the Subpart F and GILTI anti-deferral regimes.Tax Controversies: Assist clients at all stages of tax controversies with the IRS, including examinations, appeals, and trials before the U.S. Tax Court.
