Lewis J. Greenwald

Representative Client Work

• Tax efficient, multi-jurisdictional acquisitions, dispositions and reorganizations
• Migration of intellectual property to tax-favored jurisdictions
• Leveraging operations; creating double deductions
• Foreign source income generation
• Transfer pricing

Bar Admissions

• New York, 1995
• Massachusetts, 2003

Publications

• The Fabulous New Substantial Contribution Test Is Made Even More Fabulous, Journal of International Taxation (December 2009)
• Reconciling the "Irreconcilable" - 1(b)(1)-7(d)(1) Conflict; Understanding the "All Costs" Requirements to Mean "All Costs Shared by Arm's-Length Parties": Xilinx v. Comr. Revisited, Tax Management Memorandum (November 9, 2009)
• Obama Seeks to Tax Outbound Transfers of Workforce in Place, Journal of International Taxation (September 2009)
• Code Section 457A Requires Immediate Attention by Certain Sponsors of Nonqualified Deferred Compensation Arrangements, Practical U.S./International Tax Strategies (June 2009)
• Through the Glass [Even More] Darkly: Revisions to the Not-So-Fabulous Branch Rule, Journal of International Taxation (May 2009)
• The Remarkable Taxpayer-Friendly Evolution of the DCL Regime, Tax Notes International (April 14, 2009)
• 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)
• Inversions 'Lite': Finding 'Substantial Business Activity' Under the New U.S. Regs, Tax Notes International (August 7, 2006)
• Proposed U.S. Regulations Regarding Dual Consolidated Losses, Tax Notes International (August 15, 2005)
• New Final Regs. on Trigger Events for Recapture of Dual Consolidated Losses, Journal of International Taxation (December 22, 2003)
• New U.S. Guidance on Tax-Free Spin-Offs, Tax Notes International (August 2003)
• Final Piece to 894(c) Reg. Puzzle: Treaty Benefits for Payments by Domestic Reverse Hybrids, Journal of International Taxation, 894(c) Regs. (January 15, 2003)
• "Structuring Israeli/U.S. Intercompany Relationships to Minimize (Eliminate) U.S. Taxes," ACC Israel Newsletter (September 2008)
• "The New U.K.-U.S. Agreement on Dual Consolidated Losses," Tax Notes International (November 2006)
• "Proposed Regulations Would Shut Down Guardian and Reverse Hybrid Structures," Derivatives Financial Products Report (October 2006)
• "Temporary Regulations Provide Rules for Allocating a Partnership’s Foreign Taxes," Journal of International Taxation (September 2004)
• "Foreign Tax Credit Limitation Final Regs. Under Sections 864(c) and 904(d), Proposed Regs. Under Sections 902 and 904," Journal of International Taxation (October 2001)
• "Section 894(c) Final Regs. Simplify Treaty-Benefit Rules for Income Paid to 'Fiscally Transparent Entities'," Journal of International Taxation (December 2000)
• "New Section 367(e)(1) Regulations: Major Policy Shift For IRS, Planning Opportunities for Distributing Corporations," Journal of International Taxation (October 1999)
• "Analytical Framework for Electronic Commerce Helps to Determine Tax Implications in Multiple Jurisdictions," Journal of High-Tech (September/October 1998)
• "U.S. Record Companies Face Withholding Tax Problems," Journal of International Taxation (November 1995)

Client Advisories

• Code Section 457A Requires Immediate Attention by Certain Sponsors of Nonqualified Deferred Compensation Arrangements
• IRS Enhances Opportunity for U.S. Multinationals to Access Cash from Controlled Foreign Corporations
• The Section 1441 Compliance Program
• Final Regulations Issued on Source of Compensation for Services Performed Partly Within and Partly Without the United States
• Congress Passes Sweeping International Tax Reform
• Temporary Regulations Provide Rules for Allocating a Partnership's Foreign Taxes
• Check-the-Box Elections and Worthless Securities Deductions (Revenue Ruling 2003-125); New Reporting for U.S.-Owned Foreign Disregarded Entities (Announcement 2004-4)

Speaking Engagements

• "U.S./European Tax Update," Sullivan & Worcester LLP, New York (September 2009)
• Frequent lecturer for ATLAS, TEI, IFA, NFTC, etc.

Professional & Civic Activities

• Board of Advisors, Journal of International Taxation
• International Tax Section, Boston Bar Association
• Vice President, International Fiscal Association (New England Region)

Education

• J.D., Fordham University School of Law, 1994
• M.B.A., Rutgers University Graduate School of Management, 1987
• B.A., New York University, 1980