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Practice Areas: International tax planning and controversy resolution, focusing on foreign tax credit and deferral issues. Advises on structural and transactional tax planning; handles IRS audits, appeals, and rulings; represents clients in regulatory and legislative processes.

Career: 30 years international tax experience, 13 with government and 17 in private practice. 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 rewrite of transfer pricing regulations and OECD guidelines. Congressional tax staffer during 1986 Tax Reform Act.

Personal: Graduate of Yale University and Harvard Law School.