A Period of Great Tax Uncertainty
International tax planners today live in a period of great uncertainty. In the US, in particular, we expect soon to have significant changes made to our international tax rules20/04/2021
Jim has been named 2021 Tax Leaders by the International Tax Review’s Tax Leaders Expert Guide. Euromoney named Jim eight times as one of the world’s top 25 tax advisers, most recently in 2019.
He is the only U.S. tax adviser to receive a Star Performer rating (higher than first tier) in Chambers USA (2019). He also is one of the three “most highly regarded” U.S. tax practitioners according to Who’s Who Legal (Law & Business Research).
Legal 500 has included Jim in its “Halls of Fame” for both Corporate Tax and International Tax. Chambers Global (2019) also has him in the first tier in both of these categories, one of only two U.S. tax advisors to be first tier in both.
Fuller also is one the U.S.’s top 30 transfer-pricing advisors, according to Euromoney (2019).
Fenwick has represented 6 of the Fortune Top 10 companies, over 50 of the Fortune 100 companies, and over 100 of the Fortune 500 companies in federal tax matters. Fuller and the firm have served as counsel in over 150 large corporate IRS Appeals proceedings and over 75 large-corporate federal tax court cases. Some of these have been for Fortune Top 10 companies.
Fenwick is first tier in International Tax Review's World Tax 2020 in Corporate Tax, Tax Controversy and International Tax, the only firm in California to be named first tier in all three categories, and one of only three firms in the U.S. to be so named.
International Tax Review named Fenwick & West "Tax Firm of the Year for the San Francisco Area” 10 times and “U.S. (or Americas) Tax Litigation Firm of the Year” five times. Fenwick also has received a Transfer Pricing Firm of the Year award, been named “Americas M&A Tax Firm of the Year” and received a number of ITR’s M&A and JV Tax Deal of the Year awards.
TCJA one year later
The Tax Cut and Jobs Act (“TCJA”), enacted in late 2017, brought substantial changes to the US tax world20/03/2019
Transfer Pricing: Current issues
The 2017 Tax Reform Act added a new third sentence to § 482 that allows aggregation and the consideration of realistic alternatives if it produces the most reliable means of valuation29/03/2018
Recent US International Tax Developments
The outgoing Obama Administration issued an unusual number of lengthy tax regulations just before and after year end31/03/2017
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