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Band 4
Provided by Robert E Culbertson
International tax planning and controversy resolution, focusing on foreign tax credit, GILTI, and inbound investment issues. Advises on structural and transactional tax planning; handles IRS audits, appeals, and rulings; represents clients in regulatory and legislative processes.
30 plus years international tax experience. Served as IRS Associate Chief Counsel International, where significant projects included regulations on foreign tax credits, subpart F, outbound transfers, and conduits, as well as revision of transfer pricing regulations and OECD guidelines. Joint Committee on Taxation staffer during 1986 Tax Reform Act.
Cum laude graduate of Yale University and Harvard Law School.
Provided by Chambers
