U.S. Tax Reporting and Withholding  
  Qualified Intermediary ("QI") Advice  
  Tax Advice and Planning  
  Cross-Border Financial Structures  
  Collective Investment Vehicles ("CIVs")  
  Audit and Appellate Controversies  
  Tax Litigation  
  Rulings and Regulatory Lobbying  
  Alternative Dispute Resolution  
  Expert Witness/Litigation Support Services  
  Advice for Governments  

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.


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