Rulings and Regulatory Lobbying
Our lawyers have worked for all of the Federal agencies concerned
with income taxes. They know how I.R.S. and Treasury develop rulings
and regulations and rely on this experience to assist clients in
trying to obtain favorable regulations and rulings.
Dan Burt, our London managing partner, was Attorney-Advisor
to the International Tax Counsel to the US Treasury (1970-71), and
then to the Under Secretary of the Treasury for International Tax
(1971-73). In these roles he supervised the development of
legislation, regulations and IRS revenue rulings, negotiated on
behalf of the Treasury with members of Congress and Congressional
tax staffs, and on behalf of the US with foreign tax authorities.
His Treasury experience negotiating with foreign tax authorities led
to an active practice working with various European tax authorities,
both for clients and as a pro-bono advisor on international tax
matters affecting European counties and the US. He has carried on
this practice from London since 1994.
John Staples, our Washington managing partner, was Associate
Chief Counsel (International) and has wide-ranging knowledge of the
ruling and regulatory process and how key decisions are made. The
Office of Associate Chief Counsel International (“ACCI”) provides
advice to the IRS and US Treasury Department on internationally
related litigation, technical guidance such as regulations and
rulings, advice to IRS field operations, private letter rulings,
advice on US tax treaties, US positions in multinational for a, and
legislative proposals. Mr. Staples directed a staff of more than 120
attorneys, tax law specialists, program analysts and support
employees, including the staff of the Advance Pricing Agreement (“APA”)
program. After leaving the government, Mr. Staples was instrumental
in bringing about the Section 1441 Voluntary Compliance Program.
Philip L. Garlett served as the IRS’s international tax
shelter coordinator and the National Office contact for
international tax matters arising out of the U.S. west coast region.
He advised both National Office attorneys, IRS field attorneys, and
attorneys in the Department of Justice on a broad range of
international issues including foreign tax credits, foreign currency
issues, subpart F and passive foreign investment companies, dual
resident companies, hybrid financial instruments, partnership
allocation issues and many other matters. He also worked on a number
of issues arising out of the Joint International Tax Shelter
Information Centre (JITSIC) and was active in training Chief Counsel
attorneys and IRS examiners in tax shelter strategies. Mr. Garlett
headed the Harmful Tax Practices Unit at the Organization for
Economic Cooperation and Development from 2001 to 2005.
Jonathan Jackel and
Susan Segar each have substantial
private practice experience in seeking rulings and regulatory
changes on behalf of clients.
When the legislative matters affecting clients arise arise, we work
with well-known Washington lobbyists.