Mr. Sprague was one of five business representatives selected by the OECD to participate in the OECD Technical Advisory Group ("TAG") on Tax Treaty Characterisation Issues Arising from E-Commerce, and was elected chair of the business representatives on the TAG. He also was appointed by the OECD to serve as the business co-chair on the Technical Advisory Group on Monitoring the Application of Existing Treaty Norms for the Taxation of Business Profits. He was the Co-General Reporter for the subject Taxation of Income Derived from Electronic Commerce for the International Fiscal Association 2001 Congress, and is a co-author of BNA Tax Management Portfolio No. 555, Federal Taxation of Software and E-Commerce. He is the General Reporter for the subject Big Data and Tax – domestic and international taxation of data driven business for the International Fiscal Association 2021 Congress. He also is a regular contributor to the Tax Management International Journal's Leading Practitioner Commentary.
Gary focuses his practice on international corporate tax planning and advice, tax controversies and tax issues affecting software, high technology and digital enterprise companies.
Professional Associations and Memberships
- American Bar Association - Section on Taxation
- State Bar of California
- International Fiscal Association - USA Branch
- California~United States (1981)
- Harvard Law School (J.D., cum laude) (1981)
- Stanford University (B.A., Honors) (1977)
- Trinity College, Dublin
- San Francisco
- Author, "OECD Secretariat Analysis of Tax Treaties and COVID-19: Useful Guidance in an Unusual Format," Tax Management International Journal, Bloomberg Tax, May 8, 2020
- Author, "Application of the Computer Program Classification Regulations to Software and Digital Goods Transactions Through Online Platforms," Tax Management International Journal, Bloomberg Tax, July 10, 2020
- Author, "Final FDII Regulations Clean Up Classification Issues Relating to Software and Digital Content Deliveries," Tax Management International Journal, Bloomberg Tax, September 11, 2020
- Author, "Proposed Regulations Rationalize Source of Income Rules for Digital Deliveries of Software and Content," Tax Management International Journal, Bloomberg Tax, 2019
- Author, "If Metternich and Talleyrand Had Talked Tax," Tax Management International Journal, Bloomberg Tax, 2019
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