Brian Allen Tschosik

BT

Biography

Brian Tschosik represents multinational clients in international tax planning, joint ventures, corporate restructurings and related financing.

Before joining Eversheds Sutherland, Brian served as an intern for the Office of the Attorney General for the District of Columbia, where he assisted with the discovery process and in trial preparations.

Brian is admitted to the Virginia State Bar. He has submitted his application to The District of Columbia Bar. His work is supervised by District of Columbia Bar members.

Publications

Legal Alerts

Legal Alert: The Last Piece of the Puzzle-the Section 250 Proposed Regulations (March 12, 2019)
Public Law 115-97 (the Tax Cuts and Jobs Act) added a new foreign income inclusion rule for global intangible low-taxed income (GILTI) under section 951A. The Tax Cuts and Jobs Act also added section ...

Legal Alert: GILTI by consolidation (September 25, 2018)
Public Law 115-97 (the Tax Cuts and Jobs Act (TCJA)) added a new foreign income inclusion rule for global intangible low-taxed income (GILTI) under section 951A. On September 13, 2018, the Department ...

Legal Alert: In transition-proposed section 965 regulations incorporate and expand on prior guidance (August 20, 2018)
On August 1, 2018, the Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) issued proposed regulations, which were published in the Federal Register on August 9, 2018 ...

Legal Alert: Results-disoriented-Ninth Circuit withdraws its Altera decision (August 8, 2018)
On August 7, 2018, the US Court of Appeals for the Ninth Circuit withdrew its opinion in Altera Corporation v. Commissioner, just 15 days after the initial release of the opinion. The court in Altera ...

Legal Alert: Share and share alike-the Ninth Circuit upholds regulations on stock-based compensation costs in cost-sharing arrangements (August 1, 2018)
On July 24, 2018, the US Court of Appeals for the Ninth Circuit in Altera Corporation v. Commissioner overturned a unanimous decision by the Tax Court invalidating Treas. Reg. 1.482-7A(d)(2), which ...

Legal Alert: LB&I adds new campaigns on virtual currency and transition tax (July 10, 2018)
On July 2, 2018, the Large Business and International (LB&I) Division of the Internal Revenue Service (IRS) announced five new compliance campaigns, including campaigns relating to virtual currency ...

Legal Alert: Transition tax-enough about how it works; here is what doesn’t work (April 9, 2018)
The Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) released Notice 2018-26 (the Notice) providing additional guidance regarding the transition tax in section 965 of the ...

Legal Alert: Worldwide Territoriality: International Tax Proposals Broaden the Base (November 22, 2017)
On November 16, 2017, the House of Representatives passed a much-anticipated tax reform bill, titled the Tax Cuts and Jobs Act (the House Plan), which was first introduced on November 2, 2017. The ...

Legal Alert: Reconciling the Differences, the Senate Tax Cuts and Jobs Act (November 16, 2017)
On November 9, 2017, the Senate Finance Committee released a Description of the Chairman’s Mark of the “Tax Cuts and Jobs Act” and on November 14, 2017, the Senate Finance Committee released a ...

Legal Alert: Big Six Releases Tax Framework: It’s Time to Get Dynamic (September 28, 2017)
Treasury Secretary Steven Mnuchin, National Economic Council Director Gary Cohn, House Speaker Paul Ryan, Senate Majority Leader Mitch McConnell, House Ways and Means Committee Chairman Kevin Brady ...

Articles

Six highlights of DAC6 - A new European Union information reporting regime (Spring 2019)
Partnering Perspectives
US companies with operations in the EU need to know about a new information reporting regime affecting post-June 25, 2018 transactions in order to track those transactions potentially subject to the ...

Surprise! Now That You’re a CFC, You May Be Subject to Form 1099 Reporting (September 17, 2018)
Tax Notes International
In their article for Tax Notes International, Eversheds Sutherland attorneys Daniel Nicholas, Taylor Kiessig and Brian Tschosik discuss the impact the Tax Cuts and Jobs Act could have on Form 1099 ...

Newsletters

Partnering Perspectives: Insights from Inside and Outside the Corporate Law Department (Spring 2019)
We are pleased to present the Spring 2019 edition of Partnering Perspectives. In this issue, we bring you articles that we believe touch the day-to-day lives of many in-house counsel. Each of our ...

Multimedia

Videocast: The Interest Deduction Limitation under Section 163(j) (February 12, 2018)
The Internal Revenue Code has historically limited the ability of corporations to deduct certain interest paid to related parties. The recent Tax Cuts and Jobs Act modified this limitation and ...

Areas of Practice (2)

  • Tax
  • International Tax

Education & Credentials

Contact Information:
University Attended:
University of North Dakota, B.A., summa cum laude
Law School Attended:
Georgetown University Law Center, J.D., Articles Editor, The Tax Lawyer
Year of First Admission:
2018
Admission:
Virginia
Languages:
German
ISLN:
1000102528

Peer Reviews

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*Peer Reviews provided before April 15, 2008 are not displayed.

Washington, District of Columbia

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