Recent Works

 

  • Won a full abatement of $1,500,000 payroll tax with refunds, wrongfully assessed against a former officer of the company, after the statute of limitations had expired to appeal the case.
  • Won breach of contract case related to a project in Libya, and recovered a full award of $700,000, with attorney fees and costs for the client.
  • Reorganized international structure for global packaging company
  • Represented client in negotiating long term contracts for services and sales
  • Drafted global requirements contracts for multinational packaging company
  • Helped medical wholesaler design an international structure and implement an IC DISC
  • Implemented and supported foreign owned IC DISC for $6B global manufacturer
  • Implemented and supported foreign owned IC DISC for $8B global wire company
  • Streamlined, simplified and documented intercompany value chain for global learning institution
  • Won transfer pricing case on all 8 counts in Tanzania, whereby the matter in controversy is now the gold standard to be used by Tanzanian manufacturers who export
  • Won transfer pricing case, related to the sale of business, in Germany’s highest fiscal court (Bundesfinanzhof)
  • Represented clients in Foreign Bank Account Reporting matters and handled many OVDP claims
  • Developed and supported position to generate $20m deduction for intercompany matters between US and Brazil.
  • Represented client in whistleblower case related to a $30m claim under 7623(b).