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 Chairman and chief editorBuchanan Ingersoll & Rooney PC, Washington DC
Mr. Silverstein is the co-founder of Silverstein and Mullens, which later became part of Buchanan Ingersoll & Rooney PC. He concentrates his practice in estate planning, non-profit organisations, charitable contributions, and representation before the Internal Revenue Service and Treasury Department.
Mr. Silverstein serves as founder and chief editor 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 sophisticated analysis, application, and interpretation of the Internal Revenue Code.
Before he founded his own firm with Richard A. Mullens in 1960, Mr. Silverstein 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, executive director of the “Filer” Commission on Private Philanthropy and Public Needs, member of President-elect Nixon’s Task Force on Taxes, member of President Reagan’s Committee on the Arts and Humanities, and member of the IRS Commissioner’s (Lawrence Gibbs) Exempt Organisations Advisory Group.
Manuel Benites, 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 recognised 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).
Howard M. Liebman, Jones Day, Brussels
Howard M. Liebman is a partner of the Brussels office of Jones Day. He has practised 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).
Jacques Malherbe, 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 the Brussels Tax School and at EDHEC (Ecole des Hautes Etudes Commerciales) in France, as well as in the graduate programmes of the Universities of Bologna, Vienna, Hamburg and Tilburg.
Henrique de Freitas Munia e Erbolato, CFA Advogados, São Paulo
Henrique Munia e Erbolato is a senior associate at the tax department of CFA Advogados 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 honours 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 senior associate at the tax department of Ulhôa Canto, Rezende e Guerra Advogados, Rio de Janeiro, Brazil, and concentrates his practice on corporate and international 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) — Fundação Getúlio Vargas, Rio de Janeiro, and graduated from the Pontifícia Universidade Católica do Rio de Janeiro (2000). Pedro speaks Portuguese and English.
Jay Niederhoffer *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. Brian M. Schneiderman, Borden Ladner Gervais, LLP, Montréal
Brian M. Schneiderman is senior counsel at the Montréal office of Borden Ladner Gervais LLP, a member of the Québec and Ontario Bars, a graduate of the University of Montréal law school and holds a Bachelor of Arts degree from McGill University. Prior to joining Borden Ladner Gervais, he served as a tax litigator with the Canadian Department of Justice. He is a governor of the Québec Bar Foundation, a past president and current member of Council of the Canadian branch of IFA, a former member of the Canada Revenue Agency’s Appeals Advisory Committee, and a member of the Transfer Pricing Committee of the American Bar Association Section of Taxation. He focuses his practice on international taxation, transfer pricing and corporate reorganisations.
PEOPLE’S REPUBLIC OF CHINA
Stephen Nelson, DLA Piper Hong Kong
Stephen Nelson is a partner in DLA Piper’s Asia Tax team. He is a leading tax practitioner with more than 25 years’ experience in China, with a practice covering foreign investments, mergers and acquisitions and other broad corporate matters. Over the past several years his practice has focused on advising multinational clients on the tax-effective establishment and restructuring of operations in China. He is a well respected PRC tax practitioner specialising in tax planning from both a PRC and home country tax perspective. He also has significant experience in foreign investment and M&A in China, with an industry focus in the TMT sector. He has been named as a leading lawyer in the fields of PRC taxation, corporate and projects in the Asia Pacific Legal 500, Chambers Global, Chambers Asia and the International Tax Review. He has published numerous articles and contributed towards many books on PRC tax and investment, and regularly speaks at major international conferences on PRC tax and investment. He is admitted to the bar in California, USA and Hong Kong. He speaks English and Chinese (Mandarin).Peng Tao, 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.
Nikolaj Bjørnholm Hannes Snellman, Copenhagen
Nikolaj Bjørnholm is a Copenhagen-based equity partner of pan-Nordic law firm Hannes Snellman. He concentrates his practice in the area of corporate taxation, focusing on mergers, acquisitions, restructurings and international / EU taxation. He represents US, 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 10 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.Christian Emmeluth CPH LEX 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 practised Danish law in London for a period of four years, he is now based in Copenhagen.
Stéphane Gelin, CMS Bureau Francis Lefebvre, Paris
Stéphane Gelin is an attorney, tax partner with CMS Bureau Francis Lefebvre, member of the CMS Alliance. He specialises in international tax and transfer pricing.Thierry Pons, FIDAL, Paris
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, Bruhl
Dr. Jörg-Dietrich Kramer studied law in Freiburg (Breisgau), Aix-en-Provence, Gottingen, 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.Dr. Rosemarie Portner, Deloitte & Touche GmbH Wirtschaftsprüfungsgesellschaft, Düsseldorf
Before joining private practice as a lawyer and tax adviser in 1993, Dr. Rosemarie Portner, LLM, worked as a civil servant for several State and Federal tax authorities, including in the Tax Counsel International's office of the Federal Ministry of Finance. Her areas of practice are employee benefits and pensions with a focus on cross-border transactions, and international taxation (at the time she worked as a civil servant she was member of the German delegation which negotiated the German/US Treaty of 1989). She is member of the Practice Counsel of New York University’s International Tax Programme and a frequent writer and lecturer in her practice area.
Kanwal Gupta, Deloitte Haskins & Sells, Mumbai
Kanwal Gupta is a director in Deloitte’s Mumbai office. He is a member of the Institute of Chartered Accountants of India and has experience in cross-border tax issues and investment structuring including mergers and acquisitions. He is engaged in the tax knowledge management and litigation practice of the firm and advises clients on various tax and regulatory matters.Jayesh Thakur, B.K. Khare & Co, Chartered Accountants, Mumbai, India
Jayesh Thakur is a Fellow of the Institute of Chartered Accountants of India (ICAI) with post-qualification experience of more than 25 years. He is a partner with B.K. KHARE & Co.
Jayesh was, until recently, with PricewaterhouseCoopers India as an Associate Director and headed the Knowledge Management function at PwC India Tax & Regulatory Services supporting the Tax & Regulatory practice pan-India.
He is a commerce graduate of Mumbai University and holds a Diploma in Information System Audit (DISA) from the ICAI. He is a frequent speaker at seminars in India, has presented several papers on tax-related subjects and authored books on tax subjects for the ICAI, Bombay Chartered Accountants’ Society (BCAS) and the Chamber of Tax Consultants (CTC).
Jayesh regularly contributes the Corporate Law update column reporting on regulatory developments in corporate laws each month for the monthly Journal of the ICAI and for the monthly Newsletter of the WIRC of the ICAI.
IRELANDPeter Maher 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, Deloitte, DublinLouise 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 specialises in Italian tax law, including M&A, structured finance and capital markets.Giovanni Rolle, WTS R&A Studio Tributario Associato, Member of WTS Alliance, Turin – MilanGiovanni 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.
Yuko Miyazaki Nagashima Ohno and Tsunematsu, TokyoYuko 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.Eiichiro Nakatani Anderson Mōri & Tomotsune, TokyoEiichiro 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.
Terri Grosselin Ernst & Young LLP, Miami, FloridaTerri 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’s annual 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 CityJosé 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 has been a member of the faculty at the School of Administration and Finance of the Universidad Panamericana. 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 organisation composed of Mexican experts in international taxation, the Mexican Branch of the International Fiscal Association. He presided over the Mexican Branch from 2002-2006 and has spoken at several IFA Annual Congresses. He is a member of the Nominations Committee of IFA.
Martijn Juddu Loyens & Loeff, AmsterdamMartijn 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., AmsterdamMaarten J. C. Merkus is a tax partner at KPMG 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. Since joining KPMG Meijburg & Co., he has practised in the area of international taxation with a focus on M&A /corporate reorganisations and the real estate sector. He regularly advises on the structuring of cross border real estate investments and the establishment of real estate investment funds. Among his clients are Dutch, Japanese, UK and US (quoted) property investment groups as well as large privately held Spanish and Swedish property investment groups. He also taught commercial law at the University of Leiden.
Luis F. Briones Baker & McKenzie Madrid SLPLuis 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.Eduardo Martínez-Matosas Gómez-Acebo & Pombo SLP, BarcelonaEduardo 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 specialised 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 Poledna Boss Kurer AG, ZürichWalter 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 the law firm Poledna Boss Kurer AG, Zürich, where he is the head of the tax and corporate department.Dr. Silvia Zimmermann Pestalozzi Rechtsanwälte AG, ZürichSilvia 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 chair or 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.
Liesl Fichardt Berwin Leighton Paisner LLP, LondonLiesl Fichardt is a partner in Berwin Leighton Paisner LLP, practising from their London office. She advises on all areas of international tax including the EU treaty, double taxation conventions and EC directives in relation to direct tax and VAT. She has extensive experience in contentious tax matters and tax litigation in the Tribunal, the High Court and the Court of Appeal, the Supreme Court and the European Court of Justice. She advises multinationals, corporates and high net worth individuals on contentious issues relating to corporation tax, income tax and VAT. She is dual qualified as Solicitor and Solicitor-Advocate (England and Wales). She previously acted as a Judge in the High Court of South Africa and is qualified in that country as a Barrister. She is honorary secretary of the British branch of IFA and sits on the International Taxes Committee of the Law Society of England and Wales.James Ross McDermott, Will & Emery UK LLP, LondonJames 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.