Chris has extensive experience working with companies with domestic and international income tax planning. This work includes inbound and outbound mergers and acquisitions and other transactional tax matters. As a former tax professor, Chris has a strong background in subchapter C and S corporate taxation and partnership taxation and uses this knowledge to develop tax strategies for clients. Chris represents companies, private equity funds, hedge funds, joint ventures, real estate funds, and family offices.

Chris represents clients in tax audits and controversies and has experience resolving complex tax disputes.

Chris represents clients with domestic and international private wealth planning. He provides comprehensive estate planning for individuals, couples, and family businesses. Chris has extensive experience in advising clients with dual or multiple nationalities, especially those living outside the US, and their families with their unique estate planning challenges. This also includes representation of clients on the unique tax considerations and opportunities for individuals and families immigrating to the US.

Chris has presented on US inbound/outbound taxation, US informational filings, taxation of US persons, and estate planning to accountants and other professionals. Chris is the author of a number of published articles on international taxation.

Previously, Chris was a partner at an international, middle-market law firm, where he was the managing partner of the D.C. office.

Notable Representations:

• Represented foreign private equity fund in tax efficient structuring and negotiation of terms of numerous real estate investments in Chicago, as well as their acquisition of companies in the health, entertainment, and various other industries in the U.S.
• Represent Chinese company in development of a geothermal power plant in California and advise on the US federal tax aspects of formation and operation, US-Chinese income tax treaty considerations, privacy considerations, and tax efficient repatriation of the profits.
• Represent US company developing $500,000,000+ credit facility in Mexico and advise on US tax efficient structuring including Controlled Foreign Corporation (“CFC”) implications, subpart F income, planning for the Global Intangible Low-Taxed Income (“GILTI”), and tax implications of exiting the investment and repatriation planning.
• Represent US company’s acquisition of a Spanish company and advise on US tax aspects of the acquisition and coordinate with Spanish tax professionals regarding the Spanish implications of the acquisition and other Spanish tax issues.
• Represented the private wealth department of a Japanese bank moving high net worth investment portfolios to the U.S. and advise on the U.S.taxation of nonresident aliens, tax planning opportunities, and withholding tax and compliance requirements.

Publications:

• Controlled Foreign Corporations and Subpart F Income, Global Tax Weekly (Wolters Kluwer, CCH)
• Foreign Corporations and Form 5471 Compliance, Global Tax Weekly (Wolters Kluwer, CCH)
• Foreign Disregarded Entities, Foreign Partnerships, and Check-the-Box Planning Opportunities, Global Tax Weekly (Wolters Kluwer, CCH)
• Foreign Tax Credits, Global Tax Weekly (Wolters Kluwer, CCH)
• Report of Foreign Bank and Financial Accounts (FBAR), Global Tax Weekly (Wolters Kluwer, CCH)
• The Foreign Earned Income Exclusion, Global Tax Weekly (Wolters Kluwer, CCH)
• The Passive Foreign Investment Company (PFIC) – Tax Neutrality Gone Wild, Global Tax Weekly (Wolters Kluwer, CCH)
• The US Foreign Account Tax Compliance Act (FATCA), Global Tax Weekly (Wolters Kluwer, CCH)
• United States Tax Compliance and Tax Planning for US Executives or Investors Residing Outside the US, Global Tax Weekly (Wolters Kluwer, CCH)

Education

Georgetown University Law Center	– LL.M. (in Taxation) – 2009
Michigan State University College of Law	– J.D., with a Concentration in Corporate Law – 2007
Michigan State University	– B.A., General Business Administration – Prelaw – 2004

Bar Admissions

• Illinois
• Maryland
• Michigan
• New York
• Washington, D.C.
• Virginia