Thomas O’Donnell has been practicing in the area of multinational tax law for over two decades. He regularly advises major multinational businesses on tax minimization and tax efficient planning. Mr. O’Donnell is fluent in US anti-deferral rules — particularly the Passive Foreign Investment Company (PFIC) rules — transfer pricing and tax advice for private equity and cross-border investments, as well as US withholding tax and qualified intermediary rules. He has authored a book on PFICs and written a chapter in a book on structuring acquisitions of US businesses. Mr. O'Donnell has also contributed several articles on various international taxation matters.

Practice Focus

Mr. O’Donnell routinely works on international tax planning, with a focus on corporate restructuring, commercial transactions and international investments. He has represented clients before the US Congress, Treasury Department and the IRS in connection with legislative and regulatory proposals in international tax law. Mr. O’ Donnell also advises on US withholding tax rules, subpart F rules, foreign tax credit rules, branch profits tax, tax treaties and taxation of international electronic commerce.

Professional Associations and Memberships

• District of Columbia Bar
• American Bar Association - Section on Taxation

Admission

U.S. Supreme Court~United States (1989)
U.S. Tax Court~United States (1984)
District of Columbia~United States (1983)

Education

University of Cincinnati  (J.D.) (1983)
Rutgers University  (Ph.D.) (1979)
Swarthmore College  (B.A.) (1969)