Washington, DC
Tax Lawyer at Washington, DC
Practice Areas: Tax, Business, Real Estate
OUTCOME: Closing Agreement with the IRS
Represented a highly complex offshore voluntary disclosure (OVDP) case for a taxpayer who has had more than 25 undisclosed accounts of different types, including a foreign pension, foreign mutual funds ... and other financial assets.
OUTCOME: Pennies on the dollar; executed a Closing Agreement with the IRS
Represented a U.S. based producer of commodities before the IRS Office of Appeals in connection with proposed disallowance of certain intracompany charges and the attempted recharacterization of transa ... ctions.
OUTCOME: Executed an APA with the IRS
Secured an APA for a foreign-based financial institution in connection with controlled foreign exchange (FX) spot and FX forward contracts transactions.
OUTCOME: No Change Letter
Represented a publicly traded multinational conglomerate in an IRS audit involving domestic and international tax issues.
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