Understanding International Tax Enforcement Issues in 2010-2011

John Harrington is a member of SNR Denton’s Tax practice. 

He advises clients on inbound and outbound transactional and compliance issues, international tax legislative, regulatory, and treaty matters, and a variety of domestic tax issues. 

He has extensive experience in dealing with the foreign tax credit, subpart F, cross-border activities of companies and individuals, and other international tax issues. 

Prior to joining SNR Denton, John served as international tax counsel for the Department of Treasury. At the Treasury Department, he worked closely with the IRS in developing regulations and other administrative guidance. 

He represented the Treasury Department and worked with Congressional committees and staff on tax treaties and international tax aspects of legislation. 

He played an active role in tax treaty negotiations and in drafting technical explanations and revisions to existing treaties. 

John worked closely with tax officials in other countries and he served as the United States representative at meetings of the OECD Committee on Fiscal Affairs and at WTO meetings on tax-related trade disputes. 

Before joining the Treasury Department, John was a tax counsel on the U.S. House Committee on Ways and Means. 

On the committee staff, John was responsible for international, pass-through entities, financial institutions and products, real estate, environment, energy, and other tax issues. 

John is a frequent speaker and panelist at tax conferences.

Nathan Hochman is a partner in Bingham’s Santa Monica and Washington, D.C. offices. He practices complex civil and criminal litigation, with a focus on white collar criminal defense and tax controversy matters. He represents individuals and organizations involved as targets, subjects, or witnesses in international, federal, and state criminal investigations, internal investigations, and related grand jury and pre-trial proceedings, trials, and appeals. He also represents clients in federal and state tax controversy, tax litigation, arbitrations and complex civil matters. Prior to joining Bingham, Nathan was an Assistant United States Attorney for seven years and the Assistant Attorney General for the U.S. Department of Justice’s Tax Division. As head of the Tax Division, Nathan oversaw the nation’s largest tax litigation firm with over 350 lawyers enforcing federal tax laws through criminal, civil and appellate litigation in every federal district in the country. Prior to joining the Justice Department, Nathan was in private practice for 11 years in a boutique litigation firm, where he concentrated on representing individuals and organizations in tax controversy litigation, federal and state white collar criminal investigations and litigation, and complex civil litigation. Before joining the ranks of private practitioners, Nathan served as an assistant United States attorney for the criminal division of the Central District of California. In that role, Nathan prosecuted over 180 cases in the public corruption and government fraud section, ranging from tax violations, bank fraud, loan fraud, money laundering, and bribery to government program fraud, customs fraud, environmental crimes, arson, narcotics trafficking, bank robbery, alien smuggling, and perjury. He spearheaded the Los Angeles Disaster Fraud Task Force, was the environmental crimes coordinator, tried over 20 jury trials, argued over 20 appeals before the Court of Appeals for the Ninth Circuit, and ran over 30 complex grand jury investigations. Nathan clerked for United States District Judge Stephen V. Wilson in Los Angeles. He is a certified specialist in Criminal Law in California and has previously been appointed as federal receiver in several cases.

James Wall, JD, LLM, is a principal at J.H. Cohn and Director of the Firm’s International Tax Services Group. His focus is on U.S. international tax for both inbound and outbound planning, financing, reorganizations, joint ventures, and transfer pricing. 

An attorney, Jim practiced law with several leading New York area law firms, and was an international tax consultant with a Big Four accounting firm before joining J.H. Cohn. He brings a wealth of international tax experience, having practiced in the international tax arena for 25 years, including three years of working in Europe where he coordinated international tax services to European multinationals with investments in the U.S. and to U.S. multinationals with investments in Europe. 

Jim has been actively involved as an international tax consultant for both audit and non audit clients. He has extensive experience implementing tax planning strategies and working with clients through the cycle of reporting the results of such strategies in tax filings and financial statement reporting. 

Jim has written or co-authored many articles in the international tax area, including several articles relating to the Section 883 regulations. He was an adjunct professor at Quinnipiac College School of Law, teaching tax from 1998 through 2000. 

Jim earned a Bachelor of Science degree from Georgetown University, a Juris Doctor degree from the University of San Francisco School of Law, and a Master of Laws degree in Tax from the New York University School of Law. In addition, he is a member of the Bar in California, New York, and Connecticut.