John works with corporate tax departments on cross-border transactions and restructurings. He relies on his tax planning, controversy, and in-house experience to develop practical solutions that meet his clients’ tax, accounting, and commercial needs.
As part of his practice, John assists clients in vetting and implementing complex cross-border transactions and transfers of IP. He regularly advises clients on Subchapter-C, foreign tax credit, GILTI/Subpart-F, sourcing, and withholding issues related to these transactions. He also makes sure to work with all in-house stakeholders to ensure successful implementation.
In addition, John has substantial experience working with corporate treasury departments to provide practical solutions to tax issues that arise from cross-border treasury activities, including cash pooling, FX hedging programs, and internal debt restructurings. He leverages this experience to assist clients in developing solutions to their interest deduction limitation issues.
John also regularly assists clients with their IRS-audit defense of cross-border and financial transactions at the exam and appeals level.
His clients include companies in the consumer-product, defense, digital, FinTech, pharmaceutical, and software industries.
- District of Columbia~United States (2016)
- New York~United States (2014)
- U.S. Tax Court (2016)
- University of Virginia School of Law (J.D.) (2013)
- College of William and Mary (Bachelor of Business Administration) (2009)