Stafford SmileyBorn in 1948, Mr. Smiley graduated from Harvard Law School in 1976 and served as clerk to Judge Arnold Raum of the United States Tax Court from 1976 to 1978. He joined the law firm of Caplin & Drysdale, Chartered, in Washington, DC, in 1978, became a member of the firm in 1982, and practiced at the firm as a full-time tax adviser until August 2008. He remains Senior Tax Counsel to Caplin and Drysdale, where he continues to specialize in US international tax matters. Mr. Smiley has taught in the graduate tax programs of George Washington University and the Georgetown Law Center, at the New York University Institute of Taxation, and at universities in Poland, Russia and elsewhere in Europe and Asia. In September 2008, he joined the faculty of the Graduate Tax Program of Georgetown Law Center on a full-time basis. In August 2014, he became the faculty director of the Graduate Tax Program at Georgetown.
Tax Planning in the US
The course will be a broad-based discussion of US cross-border tax issues, from both an inbound and outbound perspective. Planning considerations will be emphasized. The first day will concentrate on investments by foreign persons into the United States, and will include taxation at source on portfolio income, net income taxation, use of hybrid and reverse hybrid vehicles, and related treaty issues. The second day will concentrate on foreign activities of US taxpayers and will include an overview of major transfer pricing issues from the US perspective.
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