i empowered ambition when i navigated the irs to help my client obtain a groundbreaking national settlement.
The IRS had made the same determination against other taxpayers, and we discovered that all the other taxpayers dealing with the issue “settled” the matter by paying 75% of the alleged tax. We advised the taxpayer that the prevailing settlement wasn’t a good deal, and we set a meeting with the IRS attorneys who drafted the technical law to argue the merits. After the meeting, the IRS agreed to settle our client’s case for 50% of the alleged tax – resulting in a $4.5M tax savings to our client that it would not have received if it settled on the same grounds as the other taxpayers. Also, after hearing our arguments on the merits, the IRS attorneys who drafted the technical law amended it to make it more clear, which promised to eliminate the drafting defect giving rise to the tax for all future stock option plans.
My Practice Area is:
I have worked with:
- Foreign multinational companies in the energy-consulting, craft brewing, software, distribution, and other industries that are looking for U.S. tax advice regarding their U.S. and cross-border operations.
- U.S. software and consulting companies looking for U.S. tax advice to help structure their international expansions or investments.
- Cross-border families looking for U.S. income and estate planning advice related to their foreign assets or family members.
- U.S. taxpayers with foreign assets abroad that haven’t been disclosed to the IRS.
- Privately held, U.S. companies that need to defend against current federal tax controversy matters with the IRS.
MY GREATEST STRENGTHS ARE:
- Tailoring tax planning for a client’s resources and tax priorities, so that we don’t exhaust the limited resources of a client who has minor tax risks and appetite for complexity, but we can implement more exotic planning for a client that prioritizes tax efficiency.
- Communicating tax advice in layperson’s terms to business people and lawyers who do not have the interest to talk technical tax.
- Building and managing the right team of advisors (including accountants and foreign tax lawyers) to deliver a client’s tax planning needs on time and efficiently.
I WANT YOU TO KNOW:
- I serve as a volunteer with the ABA Tax Section’s Adopt-A-Base program (where we teach armed-service personnel to prepare tax returns for their colleagues).
- As a fourth year associate, I argued and won summary judgment in an $18 million tax case. Colorcon, Inc. v. United States, 110 Fed. Cl. 650 (2013).
- I serve as a member of the Philadelphia Bar Association Tax Council (governing board for the local bar association’s tax division).
- I negotiated payments for clients from several Swiss banks, which had encouraged clients not to disclose foreign assets to the IRS, causing the clients substantial tax problems.
WHAT MAKES ME UNIQUELY ME IS:
- I enjoy leveraging frequent-flyer mile programs to travel the world in first class.
- While working full time to build my tax practice, I earned my LLM part time from NYU in only two years.
MY PROFESSIONAL & COMMUNITY ACTIVITIES ARE:
- Volunteer, ABA Tax Section Adopt-a-Base Program
- Member, Philadelphia Bar Association Tax Council
- Manufacturing & Distribution
- Investment Funds
- Family Offices
- Transactional Tax
- Tax Controversy & Litigation
- Tax Planning
- International Tax