매닝, 폴 스티븐 (Paul Stephen MANNING) - Kim & Chang

프로필

경력

김·장 법률사무소 (2020-현재)

공동의장, 조세 분과위원회, 주한미국상공회의소 (2023)

미국 국세청 본청, Office of Associate Chief Counsel(International), 워싱턴 D.C. (2013-2020)

KPMG LLP Washington National Tax, 워싱턴 D.C. (2007-2013)

Ernst & Young LLP National Tax Department, 워싱턴 D.C. (1998-2007)

미국 국세청 본청, Office of Associate Chief Counsel(International), 워싱턴 D.C. (1989-1998)

주요 활동펼치기

저서 및 외부활동

[활동]

패널리스트, US Federal Tax Ethical Considerations, George Washington University-I.R.S. Annual International Tax Conference (2018-2019)
패널리스트, I.R.S. Office of Chief Counsel CCTV Nationwide Ethics Training (2018-2019)
패널리스트, I.R.S. Office of Chief Counsel, International Tax Controversy Update (2016, 2018)

[저서]

Another Chance to Cure Prior-Year Information Reporting Failures, What’s News in Tax (공저, 2012.7.)
How to Compute and Utilize WHBAA Election Year Alternative Tax Net Operating Losses, What’s News in Tax (공저, 2012.6.)
New IRS Appeals Ex Parte Rules Appear to Be Business as Usual, What’s News in Tax (공저, 2012.5.)
New Opportunity Until August 31, 2011, for Entities and Individuals Having Properly Reported Income to Cure Prior Year Information Reporting Failures, What’s News in Tax (공저, 2011.2.)
U.S. Withholding Agent Examinations on the Rise, Tax Notes International (공저, 2010.8.)
HIRE Act Dramatically Changes Potential for Indefinite Statute of Limitations, BNA Daily Tax Report (공저, 2010.6.)
Retroactive Treasury Regulations Create Six-Year Statute of Limitations for Substantial Omission of Income Due to Overstatement of Basis, CCH Journal of Passthrough Entities 3/4월호 (공저, 2010)
U.S. International Tax Enforcement Update, Tax Analysts Tax Notes International (공저, 2010.1.)
New Law Provides Five-Year Carryback for 2008 or 2009 NOLs, Tax Analysts Tax Notes (공저, 2010.1.)
Highly Anticipated Decision in Textron Leaves Many Unresolved Matters, CCH Journal of Passthrough Entities 11/12월호 (공저, 2010)
Difficulties in Tax Reporting for a Partnership and its Partners, CCH Journal of Passthrough Entities 11/12월호 (공저, 2008)
'Textron’ Highlights Exceptions to IRS Policy of Restraint for Document Requests, BNA Daily Tax Report 8/9월호 (공저, 2008)
What Constitutes Preparation of a Substantial Portion of a Return or Claim for Refund?, CCH Journal of Tax Practice & Procedure 4/5월호 (2008)
When ‘Currency’ and ‘Transparency’ Meet, Journal of Taxation of Corporate Transactions 8/9월호 (2004)
Recent Tax Controversy Trends Related to International Financing Transactions, Journal of Taxation of Financial Institutions 9/10월호 (공저, 2001)
Update: IRS Summons Seeking Software Computers & Taxation Journal (공저, 1999)