Domestic and International Tax Planning & Controversy
- Tax Filings
"HT was referred to me by my corporate attorney when I had to dig out from under an IRS mess created by my naiveté and a sloppy bookkeeper. He got results that my new accountant and I could not get. He is a true professional. He has a combination of skills and characteristics that you might not expect to find in an attorney. He advised me, worked with my accountant, and dealt with the IRS on my behalf. He dealt with the paper work and agents, but understood that I had a budget. He helped me set a budget and prioritize what he needed to do and what I could do. He has a sharp legal mind, was aware of CA and Federal issues, and was up to date on the ever changing tax laws and codes. With the IRS agents, he knew when to be aggressive and when to pull back. The IRS agents took his calls, responded to his letters (they NEVER took mine) and in turn, gave him valuable information that helped my case. When it came to working with me, he was firm, incredibly responsive, candid, honest, patient, and he was compassionate. Truly compassionate. He made a stressful, frightening situation manageable by explaining the facts and options in as much detail as I requested (and I requested A LOT o detail) without candy coating. I went from being managed by the situation to managing the situation. I give HT the highest recommendation, without reservation. My various jobs have put he in contact with hundreds of lawyers over the years. HT is easily among the top 2% of lawyers have worked with in my 20+ career."
"Hired HT to detangle some entity structure /tax related questions we had, and he was both insightful, and understanding of the issues we faced as he went about helping us resolve things and put us on a firm footing for the future."
Founder and Principal
Jul 2012 - Present
General practice tax law firm focusing on IRS problem solving, tax advice on corporate restructurings and acting as special tax counsel to review tax aspects of litigation settlements
Senior Tax Counsel
May 2000 - Jun 2012
Advised on a variety of U.S. (domestic and international) and local tax matters in planning, controversy and policy contexts. Substantial work in advising on structuring cross-border operations (e.g., permanent establishment, withholding taxes, transfer pricing). Also, provided tax planning on restructuring transactions (e.g., pre-transaction clean-up, form of sale, balancing local and U.S. tax)
May 1997 - May 2000
Member of national group responsible for developing and implementing corporate tax planning opportunities.
Internal Revenue Service
Oct 1990 - May 1995
Income Tax and Accounting division. Developed IRS policy on tax accounting, inventory (LIFO) and other timing issues. Co-drafter of Section 263A (UNICAP) regulations. In my role, had extensive interaction with IRS Exam, IRS Appeals and Taxpayer's and their representatives.