Mark P. Thomas, PC, advises clients on all aspects of taxation, including complex civil tax controversies and litigation, transfer pricing, and domestic and international tax planning.
Mark has extensive experience in resolving a broad spectrum of domestic and international tax matters at all stages of a dispute, including US Internal Revenue Service (IRS) examinations, administrative appeals and litigation. Where appropriate, he has utilized collaborative dispute resolution tools such as advance pricing and pre-filing agreements, and the Compliance Assurance Program. He has significant experience with foreign tax authorities as well as a deep understanding of Organization for Economic Co-operation and Development (OECD) principles and treaty interpretation issues.
On the transactional side, Mark has extensive experience in the structuring of domestic and international mergers and acquisitions as well as corporate reorganizations and divestitures. He also advises clients on captive insurance arrangements.
Articles in the National Law Review database by Mark P. Thomas