Ethan Atticks is an International Tax Services Managing Director in the Washington National Tax Services office of PwC where he specializes in outbound international tax issues with a focus on the U.S. anti-deferral regimes of subpart F and PFIC. Before joining PwC, Mr. Atticks was an attorney and a Senior Technical Reviewer in Branch 2 of the Associate Chief Counsel (International) ("ACCI"), which has subject matter jurisdiction over the subpart F and PFIC regimes. While serving as Senior Technical Reviewer of Branch 2, Mr. Atticks was the primary subject matter specialist and reviewer in ACCI on PFIC matters as well as the principal drafter or reviewer of a number of significant subpart F guidance projects.
During his tenure in Branch 2, Mr. Atticks participated in the issuance of a number of pieces of PFIC guidance, such as TAM 200733024 (applying section 1298(b)(5) to trust beneficiaries); PLRs 200604020, 200813036, and 200943004 (addressing look-through issues under sections 1297(c) and 1298(b)(3)); PLR 200838003 (addressing the application of the PFIC rules to a multi-tiered structure); and PLR 200943004 (applying section 1297(d) CFC/PFIC overlap to partners in a domestic partnership).
In addition, Mr. Atticks served as the principal drafter of significant pieces of subpart F guidance including final, temporary, and proposed regulations addressing foreign base company sales income ("FBCSI"); Notice 2007-13 addressing foreign base company services income; and proposed regulations addressing previously taxed income under sections 959 and 961. He also participated in the issuance of the three FBCSI tax rate disparity PLRs (PLRs 200942034, 200945036, and 201002024).
Prior to joining ACCI, Mr. Atticks was 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.