Ethan A. Atticks is an International Tax Services director in the PwC Washington National Tax Services office. Before joining PwC, Mr. Atticks served as an attorney and as a senior technical reviewer in the IRS office of Associate Chief Counsel (International) where he specialized in the U.S. anti-deferral regimes of subpart F and PFIC. While at the IRS, Mr. Atticks participated in the drafting of significant pieces of international tax guidance including final, temporary and proposed regulations addressing foreign base company sales income, Notice 2007-13 addressing foreign base company services income, and proposed regulations addressing previously taxed income under sections 959 and 961 as well as a variety of other pieces of guidance on subpart F and PFIC issues. Prior to joining the IRS, Mr. Attticks served as a tax associate in the Washington D.C. office of Dow, Lohnes & Albertson PLLC. Mr. Atticks received an LL.M. in taxation from Georgetown University Law Center, a J.D. from the University of Virginia School of Law, and a B.A. in philosophy from the College of William and Mary.