Assisted a U.S. franchisor of business systems to obtain, through the mutual assistance provision of the U.S.-Japanese income tax treaty, a refund of Japanese withholding taxes imposed on franchise payments.
Defended a foreign trust administered in Guernsey, Channel Islands, against a proposed 35 percent IRS penalty for the late filing of a form.
For many clients throughout the United States and internationally, designed solutions to implement business succession planning and individual estate planning goals.
Helped structure the worldwide operations of a group that specialized in the development, manufacturing and licensing of food supplements to minimize U.S. and worldwide tax.
Obtained a favorable private letter ruling from the IRS that reversed long-standing policy, allowing a spin-off of assets from a U.S. pension plan to a Puerto Rican plan with favorable tax consequences.
On behalf of a global pharmaceutical company, secured a Pennsylvania state tax refund after convincing the Board of Finance & Revenue that a tax assessment against the company violated the U.S. Constitution.
On behalf of one of the largest banks in the United States, obtained an abatement of IRS penalties arising from the late filing of a foreign national's federal estate tax return.
Represented several corporations with more than $25 million at issue, contending that the gain they realized from the sale of a limited liability corporation or as the result of an election under Section 338 of the Internal Revenue Code was not subject to Pennsylvania state corporate net income tax.
Structured the U.S. operations of a European-based fabric manufacturer and distributor to minimize U.S., Swiss and French taxes.