My practice features a broad range of international tax issues with a particular focus on treaties, cross-border transactions, transfer pricing, Pillar 2, foreign tax credits, FIRPTA compliance, Subpart F/GILTI (now called the “net CFC tested income regime” or NCTI), PFICs, BEAT and other international tax regimes. I also frequently work on civil and criminal tax controversy matters, especially those with the potential for international issues.