Greg Texley is an International Tax Law Specialist for the Treaty Assistance and Interpretation Team (“TAIT”), which, along with the Advance Pricing and Mutual Agreement Program (“APMA”), compose the U.S. competent authority office at the IRS.
Greg’s current responsibilities include advising IRS and other U.S. agency personnel in litigation and administrative proceedings, such as cases arising under U.S. income tax treaties; counseling TAIT, APMA, and other IRS management and executives on technical and strategic issues; and working cross-divisionally within the IRS to implement compliance initiatives.
He has participated in treaty negotiations with U.S. treaty partners, and policy deliberations and technical discussions related to the 2016 U.S. model income tax treaty. He has also acted as an expert witness in a federal district court case (D.C. Circuit) concerning a foreign company’s purported eligibility for U.S. treaty benefits.
His current areas of expertise include determining whether U.S. and foreign taxpayers are entitled to U.S. tax treaty benefits by analyzing limitation on benefits, residency questions, and beneficial ownership issues, and determining the effects such determinations have on taxpayer compliance obligations, such as treaty disclosures reported on Forms W-8BEN, 8833, and 1120-F.
In addition to treaty matters, Greg has extensive experience in many other areas of international tax, such as the U.S. foreign tax credit, income derived from U.S. real property, entity classification and fiscal transparency rules, and Subpart F income. He also focuses on select areas of tax practice and procedure, including the filing and review of protective claims and compliance issues related to implementation of U.S. competent authority determinations.
Before joining the government in 2009, Greg worked in public accounting at both Big Four and middle market CPA firms. Greg is a CPA (inactive), and has a Bachelor of Science degree in Accountancy from Oakland University in 2000; a Juris Doctorate degree from University of Detroit Mercy School of Law in 2006; and a Master of Laws in Taxation from Wayne State University Law School in 2008.