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

• 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)
• "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)

Speaking Engagements

• Frequent speaker on U.S. international tax issues

Professional & Civic Activities

• Board of Advisors, Journal of International Taxation
• International Tax Section, Boston Bar Association
• 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