Dirk Suringa is a partner in the firm's Washington, DC office, practicing in the areas of international tax planning and controversies. Mr. Suringa advises clients regarding the Federal income tax aspects of domestic and international transactions and structures and represents clients before the Internal Revenue Service, the Treasury Department, and in the Federal courts.
Mr. Suringa served as Attorney-Advisor in the Department of the Treasury's Office of International Tax Counsel from 2000 to 2003. While at Treasury, Mr. Suringa participated in the negotiation of the US-UK Income Tax Convention and advised the International Tax Counsel and the Assistant Secretary for Tax Policy regarding regulatory guidance projects and tax legislation. From 1996 to 1997, Mr. Suringa clerked for the Honorable Gerald B. Tjoflat, Chief Judge of the United States Court of Appeals for the Eleventh Circuit.
He is the author of numerous articles on international tax matters, including the BNA Tax Management Portfolio on the Foreign Tax Credit Limitation, and is a regular contributor to the Leading Practitioner Commentary Section of the Tax Management International Journal.
Previous Experience
· Department of the Treasury, Office of International Tax Counsel, Attorney-Advisor (2000-2003)
Honors and Rankings
· Best Lawyers in America, Tax (2012)
· Chambers USA - America's Leading Business Lawyers, Tax (2011)
Memberships and Affiliations
· Vice Chair, Foreign Lawyers Forum, ABA Tax Section
· Vice-President, Secretary of IFA USA Executive Committee
· Branch Reporter, IFA USA, 2011 Paris Congress
· Member, Tax Management Advisory Board, U.S. International
Publications
· "What's New in the Technical Taxpayer and §909 Guidance," Tax Management International Journal (5/11/2012), Co-Author
· "IRS and Treasury Release Proposed FATCA Regulations," Covington E-Alert (2/13/2012), Co-Author
· "FBAR Filing Deadline Extended for Certain US Persons," Covington E-Alert (6/7/2011), Co-Author
· "FBAR Final Regulations Expand Reporting Requirements," Covington E-Alert (3/29/2011), Co-Author
· "On the Need for More §901(l) Comment Letters," 39 Tax Mgmt. Intl. J. 537 (9/10/2010), Author
· "The Long History of the 2011 Green Book Proposal on Dual Capacity Taxpayers," 39 Tax Mgmt. Intl. J. 337 (6/11/2010), Author
· "The American Jobs and Closing Tax Loopholes Act of 2010 - Expected and Unexpected International Proposals," Covington E-Alert (5/20/2010), Co-Author
· "Double Taxing Sandwiches," 39 Tax Mgmt. Intl. J. 273 (5/14/2010), Author
· "Government Incentives For Renewable Energy - An Update," Covington Advisory (3/16/2010), Co-Author
· "Recent Treasury Guidance On Foreign Bank Account Reports," Covington E-Alert (3/8/2010), Co-Author
· "The Foreign Tax Credit Limitation Under Section 904," BNA Tax Management Portfolio 904-2nd. (2008), Author
Judicial Clerkship
· Hon. Gerald B. Tjoflat, U.S. Court of Appeals, Eleventh Circuit, 1996-1997