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Overview

Once admitted to practice in Washington, Paul will advise individuals, entrepreneurs, private equity investors, private and public companies, and financial institutions on tax planning, estate planning and tax disputes, particularly those involving international tax issues.

Paul will focus his practice on international tax, cross‐border investments and reorganizations, trusts, estate planning, expatriations, and IRS disputes. He will help clients evaluate and implement tax‐related structures for U.S. domestic and international mergers and acquisitions for various purposes, including optimizing effective tax rates, protecting against the estate tax, lowering U.S. tax compliance burdens, implementing estate and repatriation plans, and addressing FIRPTA issues. He will also advise clients on international tax planning matters.

Experience

Experience

  • Advised U.S.-based cannabis business on the U.S. tax consequences of using a Canadian corporation to obtain additional capital from Canadian investors and banks, including the applicable reorganization, anti-inversion, and GILTI rules.
  • Advised a Canadian‐based private equity group on its U.S. real estate investments to lower U.S. tax compliance burdens, effectively address FIRPTA issues, and protect against the estate tax.
  • Advised a Silicon Valley‐based company on the applicability of the anti‐inversion rules, I.R.C. § 367, and subpart F.
  • Represented a Canadian company in an acquisition by a publicly‐traded U.S. corporation.
  • Advised U.S. citizens and green card holders on the exit tax.
  • Represented U.S. citizens and green card holders in IRS voluntary disclosures and tax disputes.
  • Planned and implemented transactions for privately‐held foreign corporations and partnerships to reduce the net‐effective tax on income earned and distributed to their U.S.‐citizen owners.
  • Advised and implemented pre‐immigration planning for future U.S. residents to address estate tax exposure, increase tax efficiencies, and reorganize foreign legal structures to reduce administrative burdens.
  • Advised on U.S.‐inbound investment for foreign investors, including the use of foreign trusts, grantor trusts, U.S. partnerships and LLCs, and U.S. corporations.
  • Draft cross‐border trusts for owning U.S. real estate for foreign investors.

News & Insights

Publications

  • Comments on the IRS Proposed Regulations Under § 2801
    2015 WTD 247-43, 12.25.15
  • Updated IRS Streamlined Filing Program: Snowbirds Beware
    2014 TNT 204-28, 10.21.14
  • FATCA in Canada: Analyzing the Canadian Implementing Legislation’s Restriction on the Class of Entities Subject to FATCA
    62:3 Canadian Tax Journal 587 (2014), 2014
  • Leaked and Buried – Canada Puts FATCA Deal at Risk
    2014 WTD 63-3, 4.2.14

Admissions

  • New York

Education

  • L.L.M. in Taxation, New York University School of Law, 2012
  • J.D., Boston University School of Law, 2011
  • B.S. in Business Administration, high honors, University of Montana, 2008
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