Domestic and multinational companies seeking sophisticated international tax planning advice for both outbound and inbound transactions rely upon David Newman to provide strategic and tactical counsel. David brings over 30 years of experience, and has worked on transactions in more than thirty foreign jurisdictions. His focus in particular is in the following discrete areas:
· Branch profits tax issues
· Debt/equity and funding issues
· Foreign currency transactions, losses and utilization of losses
· Foreign planning to maximize Section 1248 dividend income
· Foreign tax credit planning and tax systems
· Hedging, straddles, and cross-border leasing
· Joint venture structures
· Mergers, acquisitions, and dispositions of foreign entities
· Multinational corporations
· Structuring of foreign operations
· Transfer pricing issues
· Transfers of property to foreign vehicles
· Treaty issues
Prior to becoming affiliated with Waller, David was an attorney in the front office of the Office of Associate Chief Counsel (International) of the Internal Revenue Service in Washington, D.C., where he reported directly to the Deputy Associate Chief Counsel (International)-Technical.
He is a co-editor of Taxation of Financial Instruments and has written numerous articles, including a detailed work on foreign currency taxation, which was cited by the United States Congress and was recommended reading for graduate tax students at New York University Law School.
Professional
· Member, New York State Bar Association
· Member, New York City Bar Association
· Member, International Fiscal Association
· Guest Lecturer- Harvard Law School, Cornell Law School and various tax forums
Prior Affiliations
· Internal Revenue Service, Office of Associate Chief Counsel (International), 2009-2010
· Bank of America, Managing Director, Capital Markets Strategies, 1999-2009
· Bankers Trust Company (now Deutsche Bank), Managing Director, Corporate Tax Department, 1976-1999