프로필
경력
김·장 법률사무소 (2021-현재)
Caplin & Drysdale, Chartered 워싱턴 D.C. (2014-2021)
주요 실적펼치기
- Advised ultra high-net-worth individuals regarding reduction of IRS penalties relating to undisclosed offshore trusts and other assets.
- Advised numerous US and foreign trustees on the formation, operation, decanting and termination of trusts under US tax law.
- Advised on federal gift and estate tax issues of high net worth individuals.
- Assisted a multinational electrical distribution and services company in defending its transfer pricing practices before the Canadian Competent Authority regarding the pricing of intercompany loans.
- Advised a global financial services company in its negotiation of a BAPA and a multi-year MAP resolution with the Indian Competent Authority regarding its financial derivatives business.
주요 활동펼치기
수상
- Rising Star, The Legal 500 United States: US Taxes - Contentious (Legalease, 2019-2020)
저서 및 외부활동
- IRS Weapons Against Aggressive Tax Planning (공저, Trusts and Trustees, 2019)
- The Ethical Limits of Tax Planning (공저, Trusts and Trustees, 2016)
- Surprise! Your Foreign Tax Credit Is Not Allowed Under Section 901(I) (공저, Tax Notes International, 2014)
학력
Georgetown University Law Center (J.D., 2014)
서울대학교 (경제학사, 2011)
자격
외국변호사, 워싱턴 D.C. (2014)
언어
한국어, 영어




