David is a US qualified tax attorney who advises a broad range of clients in connection with the US tax implications of cross-border transactions, and the associated US tax compliance implications. David regularly advises sovereign wealth funds, private equity firms and other foreign investors on tax implications of acquisitions of US targets and their post transaction restructurings. In addition, David often works with high-net-worth individuals with respect to US tax issues arising from cross-border investments.
Over the course of his career David has worked with top tier international law firms and accounting firms including Baker McKenzie, Deloitte, KPMG and PWC, as well as with the IRS, where he was the principal author of the interest allocation regulations for the US foreign tax credit.
- Tax Law
- Transfer Pricing
- Cross-Border Transactions
David’s experience includes advising:
- US multi-nationals in connection with the remittance of foreign earnings and foreign tax credit utilization
- A UK corporation on the technical aspects of financing company structures, debt / equity classification, and earnings stripping issues
- An international investment fund with US investors on the acquisition and disposition of portfolio companies, and the availability of US tax benefits under section 338
- A US multi-national on technical analysis of foreign tax credit attributes including E&P deficit planning
- A US multi-national insurance company on the restructuring of its foreign insurance operations
- A private equity firm on the impact of restructuring transactions in connection with devalued assets, including the accrual of market discount on debt instruments, the accrual of interest income on contingent debt instruments, and the impact of loss deferral rules under sections 1502 and 267
- Foreign pension fund investors in accessing zero rate benefits on dividends derived through European holding structures
- JD, George Washington University School of Law, USA
- BA, George Washington University, USA
- District of Columbia, USA