Roger Brown has more than 26 years of experience with the international tax issues impacting banks, insurance companies, and asset management complexes. This experience has been with law and accounting firms, the national office of the Internal Revenue Service, and as an adjunct professor of International Tax at the Georgetown University Law Center.
As a member of the international tax division of the IRS (Chief Counsel) national office for almost 10 years, Roger served in a several transfer pricing and technical tax branches before being promoted to the positions of (i) Assistant Branch Chief for the Financial Institutions and Products Branch in the international tax division, and then (ii) Special Counsel to the Associate Chief Counsel (International).
This Associate’s office has jurisdiction over the broad range of international tax issues that the Chief Counsel’s office addresses in published guidance, litigation, audits, and treaty application.
Since leaving the government, Roger’s practice has focused predominantly on:
- Tax planning relating to legislative changes in the United States and abroad (incl. BEPs);
- Operating model, funding, capital raises, and other tax issues relevant to FinTech and Blockchain companies;
- Tax-efficient financing transactions in a post-US tax reform environment for financial institutions and their clients;
- Tax planning & bank regulatory reforms (e.g., Basel III, CCAR, IHC, living wills);
- Application of treaties to reduce gross and net-basis taxation;
- International tax issues arising from investing, trading, and dealing in debt, equity, financial products, and commodities;
- Tax attribute planning for regulatory capital, BEAT, and other purposes;
- Expense allocation and apportionment & transfer pricing (both inter & intracompany);
- Tax issues arising from internal restructurings and branch incorporation; and
- “Traditional” International tax issues affecting US based institutions, such as foreign tax credits, Subpart F management, tax - efficient financing, expense allocation and apportionment, taxation of transactions involving foreign currency, dual consolidated losses, etc.;
Roger has a B.A. in International Relations (emphasis in Economics) from Bucknell University; Juris Doctorate from American University - Washington College of Law; LLM (Taxation) from New York University School of Law.