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Managing Member, Ruchelman P.L.L.C., New York, USA
Assisting Foreign Financial Institutions and Non-Financial Foreign Entities on implementing systems to meet F.A.T.C.A. compliance rules. This includes portal registration, due diligence and reporting requirements, where appropriate. Tax planning for privately held businesses and high net worth individuals in connection with investments into and out of the U.S.
- Head of the F.A.T.C.A. practice of Ruchelman P.L.L.C.
- Co-author of Financing a U.S. Subsidiary Debt vs. Equity, published in Journal of Taxation and Regulation of Financial Institutions, July/August 2014, Vol 27/No.6.
- Guest Speaker on F.A.T.C.A. for the American German Business Clubs in Munich and in Frankfurt, Germany.
- Master of Laws in Taxation from the Graduate Tax Program at the NYU School of Law.
- Co-author Debt vs. Equity: Comparing HP Appeal Arguments to the PepsiCo Case, Vol. 2 No. 3 Insights (March 2015).
- Co-Author Foreign Tax Credit may not be Available for Gains Derived Outside the U.S., Vol. 4 No. 5 Insights (May 2017)
- Co-Author How not to Borrow a Treaty: Smith v. Commr., Vol. 7 No. 3 Insights (June 2020).
- Member of the New York Bar
- Member (inactive) of the Israel Bar Association