Representative Client Work:

-- Structured numerous tax efficient international mergers, acquisitions, dispositions and reorganizations for public and private clients in the financial services, life sciences, manufacturing, private equity, technology and venture capital industries

-- Designed cross border financing strategies, including hybrid debt structures, for multiple domestic and foreign acquisitions and restructurings and assisted clients in the recapitalization of foreign operations to reduce foreign tax burdens and enhance foreign earnings repatriation efficiency

-- Advised clients on capital loss planning, foreign tax credit utilization, foreign holding company structures, treasury and cash flow management, transfer pricing, and migration of intellectual property to tax-favored jurisdictions

-- Led a worldwide team of attorneys and other advisors in a 20 country restructuring of the foreign operations of a $2.0 billion public manufacturing company

-- Advised U.S. and non-U.S. clients on structuring cross-border real estate investments ranging from $10 million to $600 million

-- Represented public and private clients in matters before the U.S. Internal Revenue Service, including controversies, voluntary disclosures related to offshore activities, and private letter rulings

-- Advised a developer of telephone-based applications on various income and indirect tax issues related to its overseas expansion

-- Represented one of the world’s largest mobile operators and several other telecommunications providers with various tax issues related to expansion into the U.S. and into several foreign markets

-- Counseled nonresident families on pre-immigration U.S. tax and estate planning matters

I teach two classes in the Graduate Tax Program:

INTRODUCTION TO CORPORATE TAX
This course examines the U.S. federal income tax considerations relating to transfers of assets and liabilities to a corporation (during incorporation and otherwise), non-liquidating distributions, stock redemptions, related party stock purchases and corporate liquidations. The course includes an overview of the treatment of a corporate shareholder versus other shareholders.

INBOUND INTERNATIONAL TAXATION
This course covers the U.S. federal tax rules applicable to taxation of income from U.S. (and sometimes foreign) sources received by corporations and individuals that are non-residents of the United States. In some cases, such income will be derived from passive investments and be in the form of dividends, interest, rents, or royalties. In other cases, the income will arise from active business activities. The course addresses the concept of residence and entity classification, the U.S. source of income rules, the U.S. withholding tax rules (including the obligations of withholding agents) with respect to non-business income, the types of activities that can generate a "trade or business" (tax nexus) in the U.S., the U.S. rules for determining income effectively connected with a U.S. trade or business and thus taxable in the U.S., the branch profits tax, FIRPTA (foreign investment in U.S. real property) and the U.S. rules applicable to financing U.S. operations owned by non-U.S. taxpayers. Finally, we address the impact of tax treaties on the taxation of income of non-residents.

-- Advised a broad range of clients from S&P 100 multinational companies to mid-sized privately held businesses in the areas of international mergers and acquisitions, capital loss planning, transfer pricing issues, and foreign holding company structures.

-- Assisted numerous publicly traded and privately held clients throughout the U.S. as a member of the National U.S. Outbound Solutions Team in developing and implementing international tax solutions to enhance foreign earnings repatriation efficiency, increase foreign tax credit utilization, improve foreign treasury and cash flow management and reduce foreign tax burdens.