Counsel
CurrentI am a tax attorney with extensive experience in tax planning and dispute work. My practice focuses on individuals, businesses, funds and non-profit organizations.Prior to starting my practice, I practiced tax law for ten years with firms in New York. I have successfully represented clients before federal and state tax authorities and in business negotiations.Representative matters include:Advising foreign businesses on minimizing and managing their U.S. tax exposures, including choices of U.S. business entities, tax treaty utilization, compensation for services and use of intellectual property, compliance requirements and other issues. Advising U.S. businesses and investors on foreign tax credit utilization, use of GILTI and FDII deductions, taxation of controlled foreign corporations and PFICs, qualified dividend rules, compliance with foreign income and asset reporting rules and other issues.Advising funds on structuring domestic, inbound and outbound investments, including issues such as entity election, drafting offering documents, tax treaty planning and compliance with withholding and reporting rules.Organizing and obtaining tax exemptions for many nonprofits including public charities and private foundations, advising nonprofits on all phases of their life-cycle, from formation to operations (including domestic and international) to dissolution. Representation of individuals before the Internal Revenue Service and the New York State Department of Taxation and Finance for relief from garnishment of wages and levies on bank accounts.I am a member of the New York City Bar Association. I have also been published in leading tax publications on issues ranging from taxation of real estate developments to international tax policy.Prior Experience:Norris McLaughlinLaw Office of William M. FunkPwCKatten Muchin RosenmanWindels Marx Lane & Mittendorf***Attorney Advertising***
