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  
U.S. Tax Reporting and Withholding

Burt, Staples & Maner is perhaps the leading law firm advising major international financial institutions, companies, and high net worth individuals on U.S. tax withholding and reporting issues. Our work in this area has included:

  • Guiding clients through IRS audits and the Section 1441 Voluntary Compliance Program. (We developed and proposed the VCP program to the IRS on behalf of a large financial institution).
  • Advising domestic and foreign financial institutions, including qualified intermediaries, how to properly set up their withholding and reporting systems.
  • Issuing opinions on the proper application of the withholding and reporting rules and income tax treaties to unusual and/or complex facts.
  • Structuring transactions and financial products to minimize or avoid withholding and reporting.
  • Seeking private letter rulings from the IRS to ensure that clients are not surprised later on audit.
  • Lobbying the IRS for regulations and published guidance consistent with our clients’ goals.

John Staples, our Washington managing partner, was the Associate Chief Counsel (International) when the Qualified Intermediary program was in its infancy. He also was the top government official responsible for implementation of the final withholding regulations. Phil Garlett was front-office reviewer for that project, and subsequently went on to serve as the head of the Harmful Tax Practices Unit at the Organisation for Economic Cooperation and Development, as well as Deputy Associate Chief Counsel (Strategic International Programs) and the Deputy Associate Chief Counsel (International Field Service and Litigation) within the Office of Associate Chief Counsel (International).


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