Douglas S. Stransky

Representative Client Work

• Structured numerous tax efficient international mergers, acquisitions, dispositions and reorganizations for a broad spectrum of public and private clients in the financial services, life sciences, manufacturing, private equity, technology and venture capital industries
• Designed cross-border financing strategies, including hybrid debt structures, for multiple domestic and foreign acquisitions and restructurings and assisted in the recapitalization of foreign operations to reduce foreign tax burdens and enhance foreign earnings repatriation efficiency
• Advised clients on capital loss planning, foreign tax credit utilization, foreign holding company structures, treasury and cash flow management, transfer pricing and migration of intellectual property to tax-favored jurisdictions
• Led a worldwide team of attorneys and other advisors to restructure the foreign operations of a $2 billion public manufacturing company involving twenty countries
• Served as lead counsel for a reorganization of a public manufacturing company involving ten countries
• Advised U.S. and non-U.S. clients on structuring cross-border real estate investments ranging from $10 million to $200 million
• Represented public and private clients in matters before the U.S. Internal Revenue Service, including controversies, voluntary disclosures related to offshore activities and private letter rulings
• Advised a developer of telephone-based applications on various income and indirect tax issues related to its overseas expansion
• Represented one of the world’s largest mobile operators and several other telecommunications providers with various tax issues related to expansion into the United States and into several foreign markets
• Provided international tax and structuring advice to one of the world’s largest asset management firms in connection with its $27 billion bid for the acquisition of a global media and entertainment company
• Counseled nonresident families on pre-immigration U.S. tax and estate planning matters

Bar & Court Admissions

• Massachusetts
• U.S. District Court, District of Massachusetts
• U.S. Tax Court

Publications

• Obama's Budget Drops Check-the-Box Repeal, Adds International Provisions, Worldwide Tax Daily, Quoted (February 2, 2010)
• All Tied Up, INSIGHT Magazine, Quoted (February 2010)
• Textron Wants Supreme Court's View on Work Product Privilege, International Tax Review, Quoted (January 2010)
• Textron, Inc. Petitions Supreme Court to Review the First Circuit’s Evisceration of the Work Product Privilege, Practical U.S./Domestic Tax Strategies (December 2009)
• The Fabulous New Substantial Contribution Test Is Made Even More Fabulous, Journal of International Taxation (December 2009)
• The Future for Tax Services: Why Regulation Threatens Non-Audit Work, International Tax Review, Quoted (November 2009)
• Joint Committee Produces Report on Obama Budget Proposals, International Tax Review, Quoted (October 2009)
• Obama Seeks to Tax Outbound Transfers of Workforce in Place, Journal of International Taxation (September 2009)
• Attorneys Predicting 'Upheaval' in Wake of Work-Product Ruling, Massachusetts Lawyers Weekly, Quoted (August 24, 2009)
• United States v. Textron, Inc.: The First Circuit En Banc Eviscerates the Work Product Doctrine and Creates a New 'Prepared For' Test, Practical U.S./Domestic Tax Strategies (July 2009)
• Getting Personal: New K-1 Deadline Will Mean Time Crunch, Dow Jones Newswires, Quoted (June 17, 2009)
• Getting Personal: A Tax Break for Unsold GM Shares, Dow Jones Newswires, Quoted (June 5, 2009)
• Getting Personal: Stressing Over Offshore Tax Filing, Dow Jones Newswires, Quoted (June 3, 2009)
• Code Section 457A Requires Immediate Attention by Certain Sponsors of Nonqualified Deferred Compensation Arrangements, Practical U.S./International Tax Strategies (June 2009)
• Obama Proposals Could Have Drastic Impact on Leveraged Companies, Practitioner Says, Daily Tax Report, Quoted (May 21, 2009)
• Getting Personal: Obama Goes After Secret Offshore Accounts, Dow Jones Newswires, Quoted (May 5, 2009)
• Obama's Corporate Tax Proposal Panned by Advocacy Group, Investment News, Quoted (May 5, 2009)
• Obama Unveils International Tax Reforms, International Tax Review, Quoted (May 2009)
• Rhetoric Surrounding Obama's International Tax Proposals Detracts From Real Debate, Practitioner Says, Worldwide Tax Daily (May 1, 2009)
• Through the Glass [Even More] Darkly: Revisions to the Not-So-Fabulous Branch Rule, Journal of International Taxation (May 2009)
• An International Tax Wish List for the New President, Boston Business Journal (March 13, 2009)
• First Circuit Vacates Textron Work-Product Privilege Ruling and Grants Petition for Rehearing En Banc, Practical U.S./Domestic Tax Strategies (March 2009)
• Obama Sets Out to Transform Tax System, International Tax Review (February 2009)
• United States v. Textron, Inc.: A Hollow Taxpayer Victory for Privilege in the First Circuit, Practical U.S./Domestic Tax Strategies (January 2009)
• Converting a Disregarded Foreign Entity to a Corporation: More than Just Checking the Box, Practical U.S./International Tax Strategies (October 2008)
• Important Energy-Related Tax Measures Included in Bailout Legislation, Bailout Tax Briefing: A White Paper, at p. 14 (WorldTrade Executive, eds., 2008) (October 2008)
• Important Energy-Related Tax Measures Included in Bailout Legislation, Practical U.S./Domestic Tax Strategies (October 2008)
• IRS Enhances Opportunity for U.S. Multinationals to Access Cash from Controlled Foreign Corporations, Bailout Tax Briefing: A White Paper, at p. 5 (WorldTrade Executive, eds., 2008) (October 2008)
• IRS Enhances Opportunity for U.S. Multinationals to Access Cash from Controlled Foreign Corporations, Practical U.S. /International Tax Strategies (October 2008)
• The Fabulous New "Substantial Contribution" Test, Journal of International Taxation (October 2008)
• Doing Business Overseas Can be Taxing Experience, Mass. High Tech (November 2, 2007)
• Going International Online-General Business Issues and Tax Implications, WC&P (September 2000)
• U.S. Companies Underestimate Euro's Impact, Cincinnati Business Courier (April 1999)

Client Advisories

• Code Section 457A Requires Immediate Attention by Certain Sponsors of Nonqualified Deferred Compensation Arrangements
• Bailout Legislation Includes Important Energy-Related Tax Provisions
• IRS Enhances Opportunity for U.S. Multinationals to Access Cash from Controlled Foreign Corporations

Teaching & Speaking Engagements

• "Establishing International Operations," Financial Executives International (March 2010)
• "Cross-Border Acquisition and Sale of Real Estate," Sullivan & Worcester LLP, New York (February 2010)
• "48th Annual Tax Institute," Western New England College, School of Business (November 2009)
• "U.S./European Tax Update," Sullivan & Worcester LLP, New York (September 2009)
• "Structuring Foreign Disregarded or Check-the-Box (CTB) Entities," Council for International Tax Education, New York (July 2009)
• "Intermediate U.S. International Tax Update," Co-Chair, ATLAS Information Group, Boston (June 2009)
• "Introduction to U.S. International Tax," Co-Chair, ATLAS Information Group, Boston (June 2009)
• "2nd Annual Worldwide International Tax Update," Co-Chair, Sullivan & Worcester LLP, Boston (May 2009)
• "International Tax Primer for Non-International Tax Professionals," BNA Tax & Accounting Audio Conference (May and September 2009)
• "Advanced International Tax Primer for Non-International Tax Professionals," BNA Tax & Accounting Audio Conference (May and September 2009)
• "Outbound Asset Transfers to a Foreign Corporation;" "International Mergers & Acquisitions;" and "Dispositions of Controlled Foreign Corporation Stock," ATLAS Information Group, New York (April 2009)
• "How the U.S. Taxes Outbound Transfers of Property," ATLAS Information Group, New York (April 2009)
• "Dramatic Transformations in Corporate Tax Law and the Financial Statement Implications to Your Company," Financial Executives International, Boston (January 2009)
• Guest Lecturer, Advanced International Taxation, Boston University School of Law Graduate Tax Program (February and March 2009, January 2008)
• "Tax and Executive Compensation Issues Related to the Capital Purchase Program (CPP) and the Credit Crisis," Sullivan & Worcester Webinar (November 2008)
• "Tax Careers Panel,” Boston University School of Law Graduate Tax Program, Boston (October 2008 and 2009)
• "Tax Aspects of International Acquisitions & Reorganizations:  Overview of Subchapter C Acquisition and Reorganization Rules and Section 367(a) Stock Transfers," ATLAS Information Group, Chicago (October 2008)
• "U.S. Tax Issues in Structuring Foreign Operations," BNA Tax & Accounting Audio Conference (October 2008)
• "U.S. International Tax Reporting & Compliance Seminar:  Expense Apportionment for Foreign Tax Credit Purposes," Council for International Tax Education, Boston (August 2008)
• "1st Annual Worldwide International Tax Update," Co-Chair, Sullivan & Worcester LLP and ATLAS Information Group, Boston (May 2008) 
• "Intermediate U.S. International Tax Update:  Tax Treaties," ATLAS Information Group, New York (April 2008)
• "Introduction to U.S. International Tax:  Tax Treaties and Permanent Establishment," ATLAS Information Group, New York (April 2008)
• "Tax Aspects of International Acquisitions & Reorganizations:  Current Developments," ATLAS Information Group, New York (December 2007)

Awards & Honors

• "Rising Star," Massachusetts Super Lawyers, 2009

Professional & Civic Activities

• Co-Chair, International Tax Committee, Boston Bar Association
• Advisory Board, Practical U.S./International Tax Strategies
• International Fiscal Association
• Section of Taxation and Committee on Foreign Activities of U.S. Taxpayers (FAUST), American Bar Association
• Taxation Section, Massachusetts Bar Association
• Essex County Bar Association
• Director and Clerk, Boston Cares
• Pro Bono Panel, Children’s Law Center of Massachusetts

Education

• LL.M., Taxation, University of Miami School of Law, 1997
• J.D., cum laude, University of Miami School of Law, 1996; Projects Editor, Miami Law Review
• B.A., cum laude, Harvard University, 1993