Raymond J. Wiacek

Washington,  DC  U.S.A.

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Practice Areas

  • Taxation
  • International Taxation
  • International Finance
  • Transfer Pricing
University Yale University, B.A., 1973
Law SchoolHarvard University, J.D., 1976
Admitted1977, District of Columbia

Phi Beta Kappa.


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Tax Court Overturns IRS Cost-Sharing Regulation
Joseph A. Goldman,Karl L. Kellar,Edward T. Kennedy,Jerry N. Smith,Raymond J. Wiacek, August 6, 2015
On July 27, 2015, in Altera Corporation v. Commissioner, 145 T.C. No. 3 (2015), the Tax Court held Treasury regulation section 1.482-7(d)(2) (the "Regulation") invalid. This decision is significant to taxpayers who are parties to cost-sharing arrangements with foreign affiliates but, if...

U.S. Treasury Department Releases Proposed Model Treaty Provisions
Lodewijk P.W. Berger,Patrick J. Browne,Joseph A. Goldman,Karl L. Kellar,Raymond J. Wiacek, June 8, 2015
On May 20, 2015, the U.S. Treasury Department released for public comment draft updates to the U.S. model income tax convention and its accompanying Technical Explanation (collectively, the "Model Treaty"), which was last updated in 2006. The Model Treaty is the template that Treasury...

Luxembourg Leaks: Potential Risks to Companies Whose Luxembourg Tax Rulings Have Been Released to the Public
Lodewijk P.W. Berger,Thomas Jestaedt,Scott M. Levine,Howard M. Liebman,Raymond J. Wiacek, December 16, 2014
This week, the so-called "International Consortium of Investigative Journalists" ("ICIJ"), on its website, leaked a total of 548 tax rulings that multinational companies obtained in Luxembourg in the period from 2002 to 2010.

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Office Information

Raymond J. Wiacek

51 Louisiana Avenue, N.W.
WashingtonDC 20001-2113


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