Statement of Practice
U.S. Taxation of International Transactions investment into the United States by n0n-U.S. persons and investment by U.S. residents and companies into foreign countries.
Cross-Border Tax and Estate Planning tax aspects of immigration and expatriation, asset protection, foreign gifts and estates of U.S. individuals and foreign individuals with U.S. connections and family.
Federal Tax Controversies tax audits and tax litigation in all Federal courts and voluntary disclosures.
Senior Manager, KPMG LLP, International Corporate Services, Dallas and Austin, Texas, and Frankfurt am Main, Germany (1997-2003). Assistant Attorney General (Tax), U.S. Virgin Islands Department of Justice, St. Thomas, U.S. Virgin Islands (1991-1994). Tax Manager with software company, Austin, Texas (1996-1997). Private law practice, Little Rock, Arkansas (1980-1991) and St. Thomas, U.S. Virgin Islands (1994-1996).
Attorney at Law: Texas. U.S. Virgin Islands. Arkansas. U.S. Court of Appeals for the Second, Third, Fifth, Eighth and Ninth Circuits. U.S. District Courts for E.D. Ark., D. Colorado, N.D. Texas, S.D. Texas. [Federal] District Court of the Virgin Islands of the United States. U.S. Court of International Trade. U.S. Tax Court.
Solicitor: England and Wales
Southern Methodist University, Dallas, Texas, J.D. (1979), LL.M. (Taxation)(1980)
University of Arkansas, Fayetteville, Arkansas, B.A. (with honors)(1976)
Tax Management Portfolio 619, Tax Opinions and Other Tax Advice - Preparation, Use and Reliance (Bloomberg BNA 2014)
U.S. Branch Report to the 2013 Copenhagen Congress, International Fiscal Association - Subject 2: Exchange of Information and Cross-Border Cooperation Between Tax Authorities, 98b Cahiers de Droit Fiscal Internationale 779 (IFA 2013) [co-author]
"The Developing Aftermath of the UBS Affair: A New Tax Order," 95 BNA Banking Report 1 (Sept. 21, 2010).
"The UBS Affäre: A Qualified Intermediary and “John Doe” Summons, Steuerbetrug, and Bankgeheimnis,”38 Tax Management International Journal 487 (Aug. 14, 2009)
"The New and Improved FBAR: Broader in Scope with Enhanced Enforcement but not More Clarity," 36 Texas Tax Lawyer 45 (May 2009)
"Recent Chief Counsel Advice on Statute of Limitations for U.S. Virgin Islands Individuals Directly Contradicts Earlier Field Service Advice," 47 Tax Management Memorandum 454 (Oct. 30, 2006)
“Notice 2004-45: IRS Scare Tactics and Tax Enforcement in the U.S. Virgin Islands,” Tax Notes Today, 2004 TNT 130-25 (July 7, 2004), 104 Tax Notes 177 (July 12, 2004)
“The German Organschaft and the U.S. Indirect Foreign Tax Credit,” 33 Tax Management International Journal 358 (June 11, 2004)[co-author]
Tax Management Portfolio 995, Business Operations in the Territories and Possessions of the United States (except Puerto Rico) (Bureau of National Affairs 2004)
“International Legal Developments in Review: 2000 - International Estate Planning,” 35 The International Lawyer 545 (Summer 2001) [co-author]
“International Legal Developments in Review: 1999 - International Estate Planning,” 34 The International Lawyer 591 (Summer 2000) [co-author]
“The U.S. Virgin Islands Mirror Code and ‘S’ Corporations,” 15 Tax Notes International 1635 (Nov. 17, 1997)
“Issues in Using A FSC In The Export of Computer Software,” 86 Journal of Taxation 147 (1997)
“First Annual Survey/Trusts of the World - Virgin Islands (US),” 2 Trusts & Trustees 55 (January 1996) [co-contributor]
"IRS Litigating Position on Inter-Company Loans," 2015 Spring Meeting, International Tax Specialist Group. Madrid, Spain. May 29, 2015
"U.S. Taxation of Foreign Trusts Used in Tax and Estate Planning." Bircham Dyson Bell, London, June 4, 2014.
National Report for 2013 IFA Congress in Copenhagen, Subject 2: Exchange of Information and the Cross-Border Cooperation Between Tax Authorities. 41st Annual Conference of the USA Branch International Fiscal Association, Waldorf-Astoria Hotel, New York City, March 1, 2013.
"How Much Tax Is In That Opinion?" Dallas Bar Association, Section of Taxation. Belo Mansion, Dallas, Texas, Sept. 4, 2012.
FBAR & Section 6038D: Recent Developments in Foreign Bank and Financial Asset Reporting, Webinar, American Bar Association Section of Taxation, April 25, 2012 [panelist].
"International Outbound Reporting," ABA Section of Taxation 2011 Midyear Meeting, Boca Raton, Florida, Jan. 21, 2011 [panelist].
The Developing Aftermath of the UBS Affair: A New Tax Order, Tax Management Advisory Board Meeting, Waldorf-Astoria Hotel, New York, New York, February 18, 2010.
"Globalisation, Regulatory Compliance, and the New Tax Order." Russell Bedford International 26th Annual Conference. Las Vegas, Nevada, October 24, 2009.
"2002 U.S. Tax Reform and Corporate Tax Update." KPMG-Germany. Düsseldorf, May 24, 2002, and Hamburg, June 11, 2002.
American Bar Association: Section of Taxation, Section of International Law, Section of Business Law
Dallas Bar Association: Section of Taxation (Tax Council, 2012 - 2013), Section of International Law
Dallas Committee on Foreign Relations
International Bar Association: Individual Tax and Private Client Committee, Taxes Committee, and War Crimes Committee
International Fiscal Association
Member, Internantional Tax Specialist Group (a network of tax specialists in 30 countries)
U.S. Sailing Association (Certified Club Race Officer, 1999 - present; Race Officer Instructor, 1999-2000)
Society of Trust and Estate Practitioners
100 Crescent Court, Suite 700
Dallas, TX 75201
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