Ivins, Phillips & Barker is a recognized national leader in handling U.S. federal income tax issues involving activities of United States taxpayers in foreign countries and of foreign taxpayers in the United States. Our firm serves individuals and corporations throughout the United States and the world.
Our international tax attorneys have mastered all areas of international business taxation, including intercompany transfer pricing (including negotiating advance pricing agreements), income sourcing, foreign tax credits, allocation and apportionment of deductions, dual consolidated losses, subpart F, income tax treaties, competent authority proceedings, and use of hybrid entities.
Our team combines technical mastery with a savvy business sense, regularly helping clients plan foreign and multinational acquisitions, dispositions, restructurings, joint ventures, foreign currency transactions, and development and use of intellectual property, including issues relating to the international licensing of intangibles and international intangible structures. We also work with clients to resolve related tax audits, controversies, and litigation with the Internal Revenue Service.
IPB attorneys are at the forefront of the field, routinely writing and lecturing on the latest developments stemming from recent U.S. tax reform and the OECD’s base erosion and profit shifting (BEPS) project. We already have deep experience advising clients on the foreign-derived intangible income (FDII) deduction, base erosion and anti-abuse tax (BEAT), and global intangible low-taxed income (GILTI) provisions.
We also work with U.S. and non-U.S. high net worth individuals in connection with U.S. cross-border tax issues, including issues relating to business planning for inbound and outbound investment, such as real estate investments and FIRPTA, expatriation, residency and related treaty issues, and compliance with U.S. foreign bank account reporting rules.
In addition to our talented team of attorneys, we have access to an extensive network of leading firms and practitioners around the world. We are able to call upon the expertise of these colleagues at any time to respond quickly to our clients' needs.
News & Events
- Maintaining Treaty Benefits: Time to File? | 01.29.2019
- Mindy Herzfeld Quoted in Wall Street Journal | 04.30.2018
- Pat Smith Quoted in Bloomberg BNA Daily Tax Report | 03.28.2018
- Pat Smith Quoted in Tax Notes | 03.15.2018
- IPB Attorney Patrick Smith Spoke at D.C. Bar | 01.10.2018
- Patrick Smith to Speak at D.C. Bar | 12.14.2017
- Mindy Herzfeld authors "The Case Against BEPS" | 06.19.2017
- Heléna Klumpp Presented at TEI Full-Day Seminar | 05.12.2017
- Doug Andre Quoted re: Expatriation | 05.10.2017
- Hank Gutman Featured in TEI's "Ask the Expert" | November/December 2016
- Taxation of Business Income - Client Alert | 11.18.2016
- Section 385 Regulations-Corporate Client Alert | 11.14.2016
- Douglas Andre Speaks at TEI San Diego Chapter | 02.09.2016
- Douglas Andre Speaks at New Jersey Chapter of TEI | 11.06.2015
- Advanced US Transfer Pricing Conference | 12.05.2013
- TEI Baltimore/Washington Annual Tax Education Day | 12.04.2013
- US Tax Planning for CFCs Under Subpart F | 12.02.2013
- Ivins Attorneys Named Best Lawyers in Washington DC | 12.01.2011
- "The Problem With Wearing Two Hats" | 11.06.2017
- Heléna Klumpp Published in Tax Notes | 06.26.2017
- Why "Rite Aid" Was Right | 04.17.2017
- Marvel and United Dominion's Dangerous Dictum | 10.10.2016
- Interest Netting Between Merging Corporations | 07.08.2014
- BEPS Update: Country-by-Country Reporting | 02.05.2014
- Avoiding Tax Casualties in the Currency War | 02.07.2011
- International Tax Proposals Raise Technical Issues | 08.03.2009
- Leading Lawyers | 07.18.2005
- What Tax Lawyers Should Know About Trade Law | 10.13.2000