Gary P. Tober Principal

Transcription

1 Principal Second & Seneca Building 1191 Second Avenue 18th Floor Seattle, WA T F gtober@gsblaw.com Gary P. Tober has been practicing law for over thirty-five years. His practice encompasses business, transaction and international tax advice. Gary advises U.S. and foreign corporations, partnerships and individuals in tax and business planning matters. He regularly consults with clients on the potential tax implications for cross-border operations and investment transactions for a variety of companies ranging from fruit growers, durable goods manufacturers to foreign-based technology companies. In addition to counseling clients on the tax implications of business and investment transactions, Gary also consults and renders U.S. tax opinions to foreign governments and foreign pension funds investing in U.S. corporations, start-up enterprises and real estate located in the United States. Prior to joining Garvey Schubert Barer, Gary was chair of the Tax Practice Group and Canada Practice Group at Lane Powell. Practice Focus Accounting Firms Family-Owned and Closely Held Businesses International Tax Federal Tax Mergers and Acquisitions Canada Practice China Practice International Tax Admissions Washington, 1983 Ohio, 1976 (inactive) He serves as an adjunct professor for the University of Washington School of Law Graduate Program in Taxation and Golden Gate University School of Taxation, and his opinion is frequently sought on important tax issues. For example, Gary provided testimony before the Ways and Means Committee of the House of Representatives on taxation of electric commerce. Education Washington University School of Law, LL.M., Taxation, 1982

2 University of Toledo Law School, J.D., 1976 Denison University, B.A., 1973 Honors Recognitions Named Best Lawyers "Lawyer of the Year, in the area of International Trade and Finance Law, 2015, 2017, Seattle, WA Named as one of the Top Attorneys in Washington by Seattle Metropolitan magazine, July 2014 Named by peers as one of The Best Lawyers in America in the areas of International Trade and Finance Law; and Tax Law, Recommended by Chambers USA: America s Leading Lawyers for Business, Corporate/ Commercial: Tax, Named as a "Best Lawyers in the Business," Tax and International Trade and Finance Law, Seattle Business magazine, 2012 Named as a "Top Business Lawyer" in Seattle Business magazine, 2008 Named as a Washington "Super Lawyer" in Super Lawyers Magazine, Tax, 2003, Named as a "Super Lawyer" in Super Lawyers Business Edition, 2014 Named in Best Lawyers survey published by Seattle Metropolitan, Stouder Award from the Taxation Section of the Washington State Bar Association in recognition of dedication to the tax community, exceptional skills in the field of taxation law and display of professionalism, Peer Review Rated AV/5.0 in Martindale-Hubbell Professional Activities American Bar Association Washington State Bar Association Seattle-King County Bar Association International Bar Association

3 Inter Pacific Bar Association Vice President, International Fiscal Association, USA Branch Seattle Tax Group World Trade Club World Affairs Council Washington Council on International Trade Community Activities Japan America Society Experience Provided legal and tax advice on the establishment of international joint ventures in the People s Republic of China Provided legal and tax advice on the establishment of international joint ventures in the People s Republic of China for the production of pencils, ice cream, and shoes, respectively. Advised U.S. trading company on sourcing electric power tools in Asia Advised U.S. trading company on sourcing electric power tools in Asia, manufacturing such products under license agreements and the importation into the United States. Counseled U.S. company on sourcing consumer technology products and electronic components Counseled U.S. company on sourcing consumer technology products and electronic components in Asia and sale to U.S. wholesalers. Regularly renders U.S. tax opinions to foreign governments Regularly renders U.S. tax opinions to foreign governments investing pension funds in U.S. corporations, start-up enterprises and real estate located in the United States. Restructured business operations of U.S. company Restructured business operations of U.S. company in furtherance of a public offering of stock. Represented New Zealand fruit growers in contract discussions Represented New Zealand fruit growers in contract discussions with U.S. parties for the growing of new varietals and horticultural products. Acted as general counsel to U.S. technology company Acted as general counsel to U.S. technology company that raised pre-ipo financing in United Kingdom.

4 News Garvey Schubert Barer Recognized Among Top U.S. Firms in Chambers USA Guide; Fifth Year Running GSB Newsroom, GSB Attorneys Named to the 2018 The Best Lawyers in America List; Three Lawyers Named Lawyer of the Year GSB Newsroom, Garvey Schubert Barer Ranked Among Leading U.S. Firms in Chambers USA 2017 Guide; Four Practices and 12 Lawyers Featured GSB Newsroom, GSB Attorneys Named to the 2017 The Best Lawyers in America List GSB Press Release, Three Garvey Schubert Barer Attorneys Recognized as "Lawyer of the Year" by Best Lawyers for 2017 GSB Press Release, Garvey Schubert Barer Ranked in Chambers USA 2016; 13 Lawyers Featured Chambers USA, Garvey Schubert Barer Attorneys Have Been Recognized in Best Lawyers in America 2016 GSB Press Release, Chambers USA Once Again Ranks Garvey Schubert Barer Among Top Law Firms in United States GSB Press Release, Congratulations to GSB Attorneys Chosen by Best Lawyers as "Lawyer of the Year" for 2015! GSB Press Release, Garvey Schubert Barer Recognized By Chambers USA 2014 GSB Release, Garvey Schubert Barer Attorneys Recognized as Super Lawyers and Rising Stars GSB Press Release, Garvey Schubert Barer Attorneys Recognized in Best Lawyers in America 2014 GSB Press Release, Garvey Schubert Barer Attorneys Recognized in Best Lawyers in America 2013 GSB Press Release,

5 Seventeen Garvey Schubert Barer Attorneys Named Washington "Super Lawyers" and Rising Stars 2012 GSB Press Release, Garvey Schubert Barer Attorneys Recognized in Best Lawyers in America 2012 GSB Press Release, Eighteen Garvey Schubert Barer Attorneys Named Washington "Super Lawyers" and Rising Stars 2011 GSB Press Release, Garvey Schubert Barer Expands, Welcoming Four Tax and Business Attorneys GSB Press Release, s Investing in the West Coast of the United States - The Fifth Largest Economy in the World Investment s in China Beijing / Fuzhou / Shenzhen, China, "FACTA / FBARs," 2014 OSCPA Northwest Federal Tax Conference Hilton Portland & Executive Tower, "Net Investment Income Tax: International Implications" Garvey Schubert Barer, Second and Seneca Building, "Tax Considerations for Foreign Investment in the United States," Hawaii Association of Public Accountants Maui, HI, "FATCA Withholding and Reporting Requirements," Hawaii Association of Public Accountants Maui, HI, "Tax Considerations for Foreign Investment in U.S. Real Property," Hawaii Association of Public Accountants Las Vegas, NV,

6 "FATCA Withholding and Reporting Requirements," Hawaii Association of Public Accountants Las Vegas, NV, "Recent Developments Concerning US Income Tax Treaties," Washington Society of CPAs International Tax Conference Seattle, WA, "Exploring the Canadian/U.S. Tax Implications of Gifting," CAGP-ACPDP Vancouver, B.C., Pacific Tax & Accounting Institute, Washington Society of Certified Public Accountants Seattle, WA, FACTA Regulations Roundtable Garvey Schubert Barer, Second and Seneca Building, FACTA Regulations Roundtable Garvey Schubert Barer, Second and Seneca Building, "Foreign Asset Reporting: FATCA and FBAR" Oregon Tax Institute Portland, OR, "CFCS: Are You Ready for the Make Over?" WSCPA International Tax Conference Seattle, WA, "FATCA for Withholding Agents," WSBA Tax Section Seattle, WA, "Managing Uncertainty in Changing Times: Probate and Trust," Washington State Bar Association CLE WSBA-CLE Conference Center, Seattle, WA and Webcast,

7 "Foreign Account Tax Compliance Act (FACTA)," The Group Seattle, WA, "What You Need to Know About the Foreign Account Tax Compliance Act (FACTA): New Burdensome Forms and 400 Pages of Proposed Regulations," Global Tax & Offshore Investment, The Group Seattle, WA, International Estate Planning in a Changing Tax Environment Garvey Schubert Barer, Seattle, WA, "U.S. Tax Implications of Foreign Partnerships," Garvey Schubert Barer Tax Roundtable Seattle, WA, "Use of Partnerships in International Joint Ventures," Washington Society of CPAs International Tax Conference Seattle, WA, "Specified Foreign Financial Assets Reporting and Form 8938," Society of Trusts and Estates Practitioners, Seattle Branch Seattle, WA, "United States Taxation of Foreign Corporations and Nonresident Aliens," Sixth Annual International Taxation, Sterling Education Services Inc. Seattle, WA, Beyond the FBAR: Form 8938 and Specified Foreign Financial Assets Reporting Seattle, WA, "Issues, Risks, and Best Practices," Emerging International Relocation Programs, Portland Relocation Council Portland, OR,

8 "Tax and Legal Considerations Associated With Operating a Data Storage and Secured Systems Business," Privacy and Storage: Preventing and Responding to Security Breaches, Association of Corporate Counsel, Washington State Chapter Seattle, WA, Preparing for FATCA Compliance: Parsing IRS Guidance to Date Garvey Schubert Barer, Seattle, WA, "2010 INCOTERMS Important Developments that Businesses and Professionals Should be Aware Of," Exporting: Increasing Opportunities, Reducing Risks World Trade Center, Seattle, WA, "International Transfer Pricing: What the Tax Practitioner Must Know and Should Be Doing," 2011 International Tax Conference, Washington Society of Certified Public Accountants Seattle, WA, "Overview of U.S. Transfer Pricing and Thin Capitalization Rules," Innovative Related Party Tax Issues, Tax Law Committee, Inter-Pacific Bar Association, 21st Annual Meeting and Conference Kyoto, Japan, "International Tax - Taxation of U.S. Persons with Foreign Activities," Washington Society of CPAs Seattle, WA, "Cross-Border Financial, Tax and Estate Planning," Pacifica Partners, Inc., the Canada-America Society, and the Consul General of Canada Seattle, WA, Legal Alerts Cross-Border Estate Planning Considerations for the United States and Canada GSB Client Update, IRS Releases Additional Guidance for Reporting Foreign Financial Assets on Form 8938 GSB Client Update,

9 IRS Announces New FBAR Relief for U.S. Citizens Residing Outside the United States and U.S. Expatriates Holding Foreign Retirement Accounts GSB Client Update, Tax Penalty Relief May Be Available For U.S. Citizens Residing Outside the United States for Late Filed U.S. Federal Income Tax Returns and FBAR Forms GSB Client Update, U.S. Royalties vs. Services Income for Non-U.S. Citizens: A Hole-in-One or a Bogey? GSB Client Update, Preparing for FATCA Compliance GSB Client Update, Publications Guide to Doing Business in the U.S. Installment 3: Taxation Garvey Schubert Barer, Adoption of a Territorial Tax System: The Good, the Bad, and the Indifferent Taxation Law, Tax Penalty Relief May Be Available for U.S. Citizens Residing Outside the Country for Late- Filed Federal Income Tax Returns, FBAR Forms BNA Daily Tax Report, Territorial Tax System - What Should Businesses Be Anticipating Puget Sound Business Journal, Tax and Legal Aspects of Merging LLCs Garvey Schubert Barer, Tips for U.S./Canada Cross-Border Business Garvey Schubert Barer, New Tax Benefits for Investing in Small Business An Uncertain Economic Climate Raises the Need for Effective Legal Counsel