Bloomberg BNA’s Tax Management International Forum Advisory Board is comprised of esteemed professionals from renowned corporations around the world. Below is a list of our current board members.
Leonard L. Silverstein is the founder of Silverstein and Mullens, which later became part of Buchanan Ingersoll & Rooney PC. He concentrates his practice in estate planning, nonprofit organizations, charitable contributions and representation before the Internal Revenue Service and Treasury Department.
Leonard serves as founder of the highly regarded Tax Management publication series. For the past 50 years, Tax Management has produced and maintained more than 500 portfolios, monthly journals and periodicals, providing tax professionals and advisors with a sophisticated analysis, application and interpretation of the Internal Revenue Code.
Before he founded his own firm with Richard A. Mullens in 1960, Leonard served as an attorney in the Office of Chief Counsel for the Internal Revenue Service and on the legal advisory staff of the Treasury Department. His long history of professional and community service includes roles on the Advisory Group of the House Ways and Means Committee in the late 1950s, as executive director of the "Filer" Commission on Private Philanthropy and Public Needs, as a member of President-elect Nixon's Task Force on Taxes, President Reagan's Committee on the Arts and Humanities and as a member of the IRS Commissioner's (Lawrence Gibbs) Exempt Organizations Advisory Group.
Peréz Alati, Grondona, Benites, Arntsen & Martínez de Hoz, Buenos Aires
Manuel M. Benites, a founding partner of Peréz Alati, Grondona, Benites, Arntsen & Martínez de Hoz, focuses his practice on tax law. Admitted to the bar in 1980, he is a graduate of the University of Buenos Aires (JD, 1980); master in laws, Southern Methodist University, Dallas, Texas (LLM, 1987). He is professor of Corporate Income Tax at Universidad Torcuato Di Tella and professor of Tax-free Corporate Reorganisations, Universidad Católica Argentina, School of Law. He is a member of the Argentine Association of Fiscal Studies, IFA, the Tax Committee of the International Bar Association and of the Buenos Aires City Bar Association. He is the author of several articles on tax law and a lecturer and panellist at national and international congresses and seminars.
Alejandro E. Messineo,
M. & M. Bomchil, Buenos Aires
Alejandro E. Messineo is a lawyer and partner in charge of the tax department of the law firm, M. & M. Bomchil, where he deals with both tax litigation and tax planning. He has recognized experience in international tax issues and corporate reorganisations. He lectures in Universidad Austral Law School on international taxation. He is a member of IFA, the Buenos Aires City Bar, the Public Bar of Buenos Aires and the Argentine Association of Fiscal Studies (and a former member of its board).
Clayton Utz, Melbourne
Dr Niv Tadmore is a Tax Partner at Clayton Utz. His main areas of practice are international tax, transfer pricing and the conduct and resolution of tax disputes with the Australian revenue authorities. Niv's international tax experience focuses on the tax law aspects of cross-border
transactions, such as treaty issues, legal structures, the interaction of two or more tax systems, inbound and outbound operations, and the legal documentation and factual basis on which international tax positions are based. Niv is a member of the Australian Federal Treasury Specialist Reference Group
on Multinational Corporate Taxation, which recently issued a report on base erosion and profit shifting, following the OECD's BEPS Action Plan.
Niv received his Doctor of Juridical Science, International Taxation from Deakin University (2004) and his Bachelor of Laws and Commerce (First Class Hons) from Murdoch University (1996).
Minter Ellison, Melbourne
Adrian Varrasso is a Partner with Minter Ellison in Melbourne, Australia. Adrian's key areas of expertise are tax and structuring advice for mergers, acquisitions, divestments, demergers and infrastructure funding. Adrian has advised on an extensive range of general income tax issues for Australian and international clients, with a special interest in tax issues in the energy and resources sectors and inbound and outbound investment. His experience includes advising on taxation administration and compliance issues, comprehensive tax due diligence reviews and managing tax disputes. Adrian also has tax expertise in the automotive sector and infrastructure sector.
He received his BComm (2002) and an LLB (Hons) (2002) both from the University of Melbourne. He is admitted as a barrister & solicitor in Victoria, and is a member of the Law Council of Australia (Taxation Committee Member and National Chair and also a member of the National Tax Liaison Group (NTLG)); the Taxation Committee of the Infrastructure Partnerships Australia; the Law Institute of Victoria; and an Associate of the Taxation Institute of Australia.
Howard M. Liebman,
Jones Day, Brussels
Howard M. Liebman is a partner of the Brussels office of Jones Day. He has practiced law in Belgium for over 34 years. Liebman is a member of the District of Columbia Bar and holds A.B. and A.M. degrees from Colgate University and a J.D. from Harvard Law School. Mr. Liebman has served as a Consultant to the International Tax Staff of the U.S. Treasury Department. He is presently Chairman of the Legal & Tax Committee of the American Chamber of Commerce in Belgium. He is also the co-author of the BNA Portfolio 999-2nd T.M., Business Operations in the European Union (2005).
Liedekerke Wolters Waelbroeck Kirkpatrick, Brussels
Jacques Malherbe is a partner with Liedekerke in Brussels and Professor Emeritus of commercial and tax law at the University of Louvain. He is the author or co-author of treatises on company law, corporate taxation and international tax law. He teaches at EDHEC (Ecole des Hautes Etudes Commerciales) in France, as well as in the graduate programs of the Universities of Bologna and Hamburg. He is a corresponding member of the Spanish Academy of law and jurisprudence.
Pascal Faes is a tax partner with NautaDutilh in Brussels. He received his JD from the University of Ghent (1984); Special Degree in Economics, University of Brussels (VUB) (1987); and his Master in Tax Law, University of Brussels (ULB) (1991). He is a Special Consultant to Tax Management, Inc. Bloomberg BNA.
Henrique de Freitas Munia e Erbolato,
Henrique Munia e Erbolato is a tax lawyer in São Paulo, Brazil. Henrique concentrates his practice on international tax and transfer pricing. He is a member of the Brazilian Bar. Henrique received his LL.M with honors from Northwestern University School of Law (Chicago, IL, USA) and a Certificate in Business Administration from Northwestern University—Kellogg School of Management (both in 2005). He holds degrees from Postgraduate Studies in Tax Law—Instituto Brasileiro de Estudos Tributários—IBET (2002)—and graduated from the Pontifícia Universidade Católica de São Paulo (1999). He has written numerous articles on international tax and transfer pricing. He served as the Brazilian “National Reporter” of the Tax Committee of the International Bar Association (IBA)-2010/2011. Henrique speaks English, Portuguese and Spanish.
Pedro Vianna de Ulhôa Canto,
Ulhôa Canto, Rezende e Guerra, Advogados, Rio de Janeiro
Pedro is a tax partner of Ulhôa Canto, Rezende e Guerra Advogados, Rio de Janeiro, Brazil, and concentrates his practice on international and domestic income tax matters, primarily in the Financial and Capital Markets industry. Pedro served as a foreign associate in the New York City (USA) office of Cleary, Gottlieb, Steen & Hamilton LLP (2006-2007). He is a member of the Brazilian Bar. Pedro received his LL.M. from New York University School of Law (New York, NY, USA) in 2006. He holds degrees from his graduate studies in Corporate and Capital Markets (2006) and Tax Law (2004) from Fundação Getúlio Vargas, Rio de Janeiro, and graduated from the Pontifícia Universidade Católica do Rio de Janeiro (2000). Pedro speaks Portuguese and English.
Deloitte LLP, Toronto
Jay Niederhoffer is an international corporate tax partner of Deloitte, based in Toronto, Canada. Over the last 17 years he has advised numerous Canadian and foreign-based multinationals on mergers and acquisitions, international and domestic structuring, cross-border financing and domestic planning. Jay has spoken in Canada and abroad on cross-border tax issues including mobile workforce issues, technology transfers and financing transactions. He obtained his Law degree from Osgoode Hall Law School and is a member of the Canadian and Ontario Bar Associations.
Borden Ladner Gervais, LLP, Vancouver
Rick Bennett is a senior tax partner in the Vancouver office of Borden Ladner Gervais LLP. He is a Governor of the Canadian Tax Foundation, and has frequently lectured and written on Canadian tax matters. Rick was admitted to the British Columbia Bar in 1983, graduated from the University of Calgary Faculty of Law in 1982, and holds a Master of Arts from the University of Toronto and a Bachelor of Arts (Honours) from Trent University. Rick practices in the area of income tax planning with an emphasis on corporate reorganizations, mergers and acquisitions, and international taxation.
PEOPLE’S REPUBLIC OF CHINA
DLA Piper, Hong Kong
Peng Tao is Of Counsel in DLA Piper’s Hong Kong office. He focuses his practice on PRC tax and transfer pricing, mergers and acquisitions, foreign direct investment, and general corporate and commercial issues in China and cross-border transactions. Before entering private practice, he worked for the Bureau of Legislative Affairs of the State Council of the People’s Republic of China from 1992 to 1997. His main responsibilities were to draft and review tax and banking laws and regulations that were applicable nationwide. He graduated from New York University with an LLM in Tax.
Bjørnholm Law, Copenhagen
Nikolaj Bjørnholm concentrates his practice in the area of corporate taxation, focusing on mergers, acquisitions, restructurings and international/EU taxation. He represents U.S., Danish and other multinational groups and high net worth individuals investing or conducting business in Denmark and abroad. He is an experienced tax litigator and has appeared before the Supreme Court more than 15 times since 2000. He is ranked as a leading tax lawyer in Chambers, Legal 500, Who’s Who Legal, Which Lawyer and Tax Directors Handbook among others. He is a member of the International Bar Association and was an officer of the Taxation Committee in 2009 and 2010, the American Bar Association, IFA, the Danish Bar Association and the Danish Tax Lawyers’; Association. He is the author of several tax articles and publications. He graduated from the University of Copenhagen in 1991 (LLM) and the Copenhagen Business School in 1996 (Diploma in Economics) and spent six months with the EU Commission (Directorate General IV (competition)) in 1991–1992. He was with Bech-Bruun from 1992–2010, with Hannes Snellman from 2011–2013 and with Plesner from 2014–2016.
EMBOLEX Advokater, Copenhagen
Christian Emmeluth obtained an LLBM from Copenhagen University in 1977 and became a member of the Danish Bar Association in 1980. During 1980-81, he studied at the New York University Institute of Comparative Law and obtained the degree of Master of Comparative Jurisprudence. Having practiced Danish law in London for a period of four years, he is now based in Copenhagen.
CMS Bureau Francis Lefebvre, Paris
Stéphane Gelin is an attorney, tax partner with CMS Bureau Francis Lefebvre. He specializes in international tax and transfer pricing. He heads the CMS Tax Practice Group.
Thierry Pons is a partner with FIDAL in Paris. He is an expert in French and international taxation. Thierry covers all tax issues mainly in the banking, finance and capital market industries, concerning both corporate and indirect taxes. He has wide experience in advising corporate clients on international tax issues.
Dr. Jörg-Dietrich Kramer,
Dr. Jörg-Dietrich Kramer studied law in Freiburg (Breisgau), Aix-en-Provence, Göttingen, and Cambridge (Massachusetts). He passed his two legal state examinations in 1963 and 1969 in Lower Saxony and took his L.L.M. Degree (Harvard) in 1965 and his Dr.Jur. Degree (Göttingen) in 1967. He was an attorney in Stuttgart in 1970-71 and during 1972-77 he was with the Berlin tax administration. From 1997 until his retirement in 2003 he was on the staff of the Federal Academy of Finance, where he became vice-president in 1986. He has continued to lecture at the academy since his retirement. He was also a lecturer in tax law at the University of Giessen from 1984 to 1991. He is the commentator of the Foreign Relations Tax Act (Außensteuergesetz) in Lippross, BasiskommentarSteuerrecht, and of the German tax treaties with France, Morocco and Tunisia in Debatin/Wassermeyer, DBA. He maintains a small private practice as a legal counsel.
P+P Pöllath + Partners, Frankfurt
Pia Dorfmueller is a partner at P+P Pöllath + Partners in Frankfurt. Her practice focuses on corporate taxation, international tax structuring, M&A, finance structures, European holding companies, German inbound, in particular, from the United States, and German outbound structures.
For her PhD thesis “Tax Planning for US MNCs with EU Holding Companies: Goals—Tools—Barriers”, Pia received the Award “International Tax Law” from the German Tax Advisor Bar in 2003. Moreover, Pia is a frequent speaker on Corporate / International Tax Law and has authored over 80 publications on tax law. She is a current co-chair of the International Tax Committee of the International Law Section of ABA.
PricewaterhouseCoopers Pvt. Ltd., Mumbai
Kanwal Gupta works as Senior Tax Advisor in the PwC Mumbai office. He is a Member of the Institute of Chartered Accountants of India. He has experience on cross-border tax issues and investment structuring including mergers and acquisitions. He is engaged in the Centre of Excellence and Knowledge Management practice of the firm and advises clients on various tax and regulatory matters.
Majmudar & Partners, International Lawyers, Mumbai, India
Mr. Ravishankar Raghavan, Principal of the Tax Group at Majmudar & Partners, International Lawyers, has more than 18 years of experience in corporate tax advisory work, international taxation (investment and fund structuring, repatriation techniques, treaty analysis, advance rulings, exchange control regulations, FII taxation, etc.), and tax litigation services. Mr. Raghavan has a postgraduate degree in law and has also completed his management studies from Mumbai University. Prior to joining the firm, Mr. Raghavan was associated with Ernst & Young and PWC in their respective tax practice groups in India. He has advised Deutsche Bank, Axis Bank, Future Group, Bank Muscat, State Street Funds, Engelhard Corporation, AT&T, Adecco N.A., Varian Medical Systems, Ion Exchange India Limited, Dun & Bradstreet, Barber Ship Management, Dalton Capital UK, Ward Ferry, Gerifonds, Instanex Capital, Congest Funds, Lloyd George Funds and several others on diverse tax matters. Mr. Raghavan is a frequent speaker on tax matters.
A&L Goodbody, Dublin
Peter Maher is a partner with A&L Goodbody and is head of the firm’s tax department. He qualified as an Irish solicitor in 1990 and became a partner with the firm in 1998. He represents clients in every aspect of tax work, with particular emphasis on inbound investment, cross-border financings and structuring, capital market transactions and US multinational tax planning and business restructurings. He is regularly listed as a leading adviser in Euromoney’s Guide to the World’s Leading Tax Lawyers, The Legal 500, Who’s Who of International Tax Lawyers, Chambers Global and PLC Which Lawyer. He is a former co-chair of the Taxes Committee of the International Bar Association and of the Irish Chapter of IFA. He is currently a member of the Tax Committee of the American Chamber of Commerce in Ireland.
Louise Kelly is a corporate and international tax director with Deloitte in Dublin. She joined Deloitte in 2001. She is an honours graduate of University College Cork, where she obtained an accounting degree. She is a Chartered Accountant and IATI Chartered Tax Adviser, having been placed in the final exams for both qualifications. Louise advises Irish and multinational companies over a wide variety of tax matters, with a particular focus on tax aligned structures for both inbound and outbound transactions. She has extensive experience on advising on tax efficient financing and intellectual property planning structures. She has advised on many M&A transactions and structured finance transactions. She led Deloitte’s Irish desk in New York during 2011 and 2012, where she advised multinationals on investing into Ireland. Louise is a regular author and speaker on international tax matters.
Dr. Carlo Galli,
Clifford Chance, Milan
Carlo Galli is a partner at Clifford Chance in Milan. He specializes in Italian tax law, including M&A, structured finance and capital markets.
WTS R&A Studio Tributario Associato, Member of WTS Alliance, Turin – Milan
Giovanni Rolle is a partner of R&A Studio Tributario Associato, a member of WTS Alliance. He is a chartered accountant who has long focused exclusively on international and EU tax, corporate reorganisation and transfer pricing, and thus has significant experience in international tax planning, cross-border restructuring, and supply chain projects for both Italian and foreign multinationals. He is a member of IFA, of the Executive Committee of the Chartered Institute of Taxation – European Branch, and of the International Tax Technical Committee of Bocconi University, Milan. A regular contributor to Italian and foreign tax law journals, he is also a frequent lecturer in the field of international, comparative, and European Community tax law.
Nagashima Ohno and Tsunematsu, Tokyo
Yuko Miyazaki is a partner of Nagashima Ohno & Tsunematsu, a law firm in Tokyo, Japan. She holds an LLB degree from the University of Tokyo and an LLM degree from Harvard Law School. She was admitted to the Japanese Bar in 1979, and is a member of the Dai-ichi Tokyo Bar Association and IFA.
Anderson Mōri & Tomotsune, Tokyo
Eiichiro Nakatani is a partner of Anderson Mōri & Tomotsune, a law firm in Tokyo. He holds an LLB degree from the University of Tokyo and was admitted to the Japanese Bar in 1984. He is a member of the Dai-ichi Tokyo Bar Association and IFA.
Ernst & Young LLP, Miami, Florida
Terri Grosselin is a director in Ernst & Young LLP’s Latin America Business Center in Miami. She transferred to Miami after working for three years in the New York office and five years in the Mexico City office of another Big Four professional services firm. She has been named one of the leading Latin American tax advisors in International Tax Review’sannual survey of Latin American advisors. Since graduating magna cum laude from West Virginia University, she has more than 15 years of advisory services in financial and strategic acquisitions and dispositions, particularly in the Latin America markets. She co-authored Tax Management Portfolio—Doing Business in Mexico, and is a frequent contributor to Tax Notes International and other major tax publications. She is fluent in both English and Spanish.
José Carlos Silva,
Chevez, Ruiz, Zamarripa y Cia., S.C., Mexico City
José Carlos Silva is a partner in Chevez, Ruiz, Zamarripa y Cia., S.C., a tax firm based in Mexico. He is a graduate of the Instituto Tecnológico Autónomo de México (ITAM) where he obtained his degree in Public Accounting in 1990. He has taken graduate Diploma courses at ITAM in business law and international taxation. He is currently part of the faculty at the Instituto Tecnológico Autónomo de México. He is the author of numerous articles on taxation, including the General Report on the IFA’s 2011 Paris Congress “Cross-Border Business Restructuring” published in Cahiers de Droit Fiscal International. He sits on the Board of Directors and is a member of the Executive Committee of IFA, Grupo Mexicano, A.C., an organization composed of Mexican experts in international taxation, the Mexican Branch of the International Fiscal Association (IFA). He presided over the Mexican Branch from 2002-2006 and has spoken at several IFA Annual Congresses. He is the Chairman of the Nominations Committee of IFA.
Loyens & Loeff, Amsterdam
Martijn Juddu is a senior associate at Loyens & Loeff based in their Amsterdam office. He graduated in tax law and notarial law at the University of Leiden and has a postgraduate degree in European tax law from the European Fiscal Studies Institute, Rotterdam. He has been practising Dutch and international tax law since 1996 with Loyens & Loeff, concentrating on corporate and international taxation. He advises domestic businesses and multinationals on setting up and maintaining domestic structures and international inbound and outbound structures, mergers and acquisitions, group reorganisations and joint ventures. He also advises businesses in the structuring of international activities in the oil and gas industry. He is a contributing author to a Dutch weekly professional journal on topical tax matters and teaches tax law for the law firm school.
Maarten J. C. Merkus,
KPMG Meijburg & Co., Amsterdam
Maarten J.C. Merkus is a tax partner at Meijburg & Co Amsterdam. He graduated in civil law and tax law at the University of Leiden, and has a European tax law degree from the European Fiscal Studies Institute, Rotterdam.
Before joining Meijburg & Co, Maarten taught commercial law at the University of Leiden.
Since 1996 Maarten has been practicing Dutch and international tax law at Meijburg & Co. Maarten serves a wide range of clients, from family-owned enterprises to multinationals, on the tax aspects attached to their operational activities as well as matters such as mergers, acquisitions and restructurings, domestically as well as cross-border. His clients are active in the consumer and industrial markets, travel leisure and tourism sector and the real estate sector.
In 2001 and 2002 Maarten worked in Spain. At present Maarten is the chairman of the Latam Tax Desk within Meijburg & Co, with a primary focus on Spain and Brazil.
Luis F. Briones,
Baker & McKenzie Madrid SLP
Luis Briones is a tax partner with Baker & McKenzie, Madrid. He obtained a degree in law from Deusto University, Bilbao, Spain in 1976. He also holds a degree in business sciences from ICAI-ICADE (Madrid, Spain) and has completed the Master of Laws and the International Tax Programme at Harvard University. His previous professional posts in Spain include inspector of finances at the Ministry of Finance, and executive adviser for International Tax Affairs to the Secretary of State. He has been a member of the Taxpayer Defence Council (Ministry of Economy and Finance). A professor since 1981 at several public and private institutions, he has written numerous articles and addressed the subject of taxation at various seminars.
Gómez-Acebo & Pombo SLP, Barcelona
Eduardo Martínez-Matosas is an attorney at Gómez-Acebo & Pombo, Barcelona. He obtained a Law Degree from ESADE and a Master of Business Law (Taxation) from ESADE. He advises multinational, venture capital and private equity entities on their acquisitions, investments, divestitures or restructurings in Spain and abroad. He has wide experience in LBO and MBO transactions, his areas of expertise are international and EU tax, international mergers and acquisitions, cross border investments and M&A, financing and joint ventures, international corporate restructurings, transfer pricing, optimisation of multinationals’ global tax burden, tax controversy and litigation, and private equity. He is a frequent speaker for the IBA and other international forums and conferences, and regularly writes articles in specialized law journals and in major Spanish newspapers. He is a recommended tax lawyer by several international law directories and considered to be one of the key tax lawyers in Spain by Who’s Who Legal. He is also a member of the tax advisory committee of the American Chamber of Commerce in Spain. He has taught international taxation for the LLM in International Law at the Superior Institute of Law and Economy (ISDE).
Walter H. Boss,
Bratschi Wiederkehr & Buob AG, Zürich
Walter H. Boss is a graduate of the University of Bern and New York University School of Law with a Master of Laws (Tax) Degree. He was admitted to the bar in 1980. Until 1984 he served in the Federal Tax Administration (International Tax Law Division) as legal counsel; he was also a delegate at the OECD Committee on Fiscal Affairs. He was then an international tax attorney with major firms in Lugano and Zürich. In 1988, he became a partner at Ernst & Young's International Services Office in New York. After having joined a major law firm in Zürich in 1991, he headed the tax and corporate department of another well-known firm in Zürich from 2001 to 2008. On July 1, 2008 he became one of the founding partners of the law firm Poledna Boss Kurer AG, Zürich, where he was managing partner prior to joining Bratschi Wiederkehr & Buob.
Dr. Silvia Zimmermann,
Pestalozzi Rechtsanwälte AG, Zürich
Silvia Zimmermann is a partner and member of Pestalozzi’s Tax and Private Clients group in Zürich. Her practice area is tax law, mainly international taxation; inbound and outbound tax planning for multinationals, as well as for individuals; tax issues relating to reorganisations, mergers and acquisitions, financial structuring and the taxation of financial instruments. She graduated from the University of Zürich in 1976 and was admitted to the bar in Switzerland in 1978. In 1980, she earned a doctorate in law from the University of Zürich. In 1981-82, she held a scholarship at the International Law Institute of Georgetown University Law Center, studying at Georgetown University, where she obtained an LL.M. degree. She is Chair of the tax group of the Zürich Bar Association and Lex Mundi, and a member of other tax groups; a board member of some local companies which are members of foreign multinational groups; a member of the Swiss Bar Association, the International Bar Association, IFA, and the American Bar Association. She is fluent in German, English and French.
Rosetta Tax LLP, London
Charles is a partner with Rosetta Tax LLP, a U.K. law firm which specializes in providing “City” quality, cost-effective tax advice to businesses and professional services firms. Charles has wide experience of advising on a range of corporate and finance transactions. His clients range from multinational blue-chip institutions to private individuals. The transactions on which he has advised include corporate M&A deals, real estate transactions, joint ventures, financing transactions (including Islamic finance, structured finance and leasing), and insolvency and restructuring deals.
McDermott, Will & Emery UK LLP, London
James Ross is a partner in the law firm of McDermott Will & Emery UK LLP, based in its London office. His practice focuses on a broad range of international and domestic corporate/commercial tax issues, including corporate restructuring, transfer pricing and thin capitalisation, double tax treaty issues, corporate and structured finance projects, mergers and acquisitions and management buyouts. He is a graduate of Jesus College, Oxford and the College of Law, London.
Patricia R. Lesser,
Buchanan Ingersoll & Rooney PC, Washington, D.C.
Patricia R. Lesser is associated with the Washington, D.C. office of the law firm Buchanan Ingersoll & Rooney PC. She holds a licence en droit, a maitrise en droit, a DESS in European Community Law from the University of Paris, and an MCL from the George Washington University in Washington, D.C. She is a member of the District of Columbia Bar.
Herman B. Bouma,
Buchanan Ingersoll & Rooney PC, Washington, D.C.
Herman B. Bouma is Senior Tax Counsel with the Washington, D.C. office of Buchanan Ingersoll & Rooney PC. He has over 25 years’ experience in US taxation of income earned in international operations, assisting major US companies and financial institutions with tax planning and analysis and advising on such matters as the structuring of billion-dollar international financial transactions, the creditability of foreign taxes, Subpart F issues, transfer pricing, and foreign acquisitions, reorganisations and restructurings. He was counsel to the taxpayer in Exxon Corporation v. Comr., 113 T.C. 338 (1999) (creditability of the UK Petroleum Revenue Tax under sections 901/903), and in The Coca-Cola Company v. Comr., 106 T.C. 1 (1996) (computation of combined taxable income for a possession product under section 936). He began his legal career as an attorney-advisor in the IRS Office of Chief Counsel, Legislation and Regulations Division (International Branch) in Washington, D.C. He was the principal author of the final foreign tax credit regulations under sections 901/903, and participated in income tax treaty negotiations with Sweden, Denmark, and the Netherlands Antilles. He is a graduate of Calvin College and the University of Texas at Austin School of Law.
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