BRINGING YOU INNOVATIVE LEGAL SOLUTIONS. Attorney Advertising

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1 BRINGING YOU INNOVATIVE LEGAL SOLUTIONS Attorney Advertising

2 WE CAN ENHANCE YOUR International Business Practice

3 Our Attorneys Mortimer M. Caplin Mortimer Caplin is the founder of Caplin & Drysdale, one of the Served on the President s Task Force on Taxation following President John F. Kennedy s election Appointed U.S. Commissioner of Internal Revenue from The National Trial Advocacy College of the University of Virginia presented him the Thomas Jefferson Medal in Law, the university s highest honor Named a Chevalier of the Legion of Honor by the President of the French Republic for his contributions to the United States decisive role in the liberation of France during World War II Presented with the Medal of the Jubilee of Liberty authorized by the Governor of the Normandy Region On leaving the U.S. government, he received the Alexander Hamilton Award, the highest award conferred by the Secretary of the Treasury for his distinguished leadership Patricia G. Lewis Has represented U.S. subsidiaries of major Japanese corporations, Sweden, Germany, and other foreign countries of APAs from unwarranted disclosure Chambers ranked, District of Columbia, Band 3, Tax Michael G. Pfeifer Former international tax partner in the National Tax Department private client practice Special Assistant to the Associate Chief Counsel (International) at the Internal Revenue Service from , where he directed the legislative project that culminated in the 1996 foreign trust tax changes and the Clinton administration s 1995 expatriation tax proposal H. David Rosenbloom Special Assistant and then International Tax Counsel and Director Department from Former Tax Policy Advisor for the U.S. Treasury, the OECD, US AID, the International Monetary Fund, and the World Bank in Eastern Europe and the Baltic countries, the former Soviet Union, Senegal, Malawi, and South Africa Director, International Tax Program at New York University School of Law Chambers ranked, District of Columbia, Band 1, Tax President, Harvard Law Review BRINGING YOU INNOVATIVE IVE LEGAL SOLUTIONS To reach our International Tax Team please contact us: International@capdale.com

4 Richard W. Skillman Deputy Chief Counsel and Acting Chief Counsel of the Internal Revenue Service from management responsibility for approximately 2500 Chief Counsel Chambers ranked, District of Columbia, Band 3, Tax Richard E. Timbie Has more than 30 years of experience in resolving Internal Revenue Service audits and administrative appeals and in advising foreign investors and financial institutions on the U.S. income tax withholding, information reporting, and qualified intermediary rules Employed as a part-time consultant for international taxation issues by Tax Assistance and by the Harvard Institute for International Development from Participated as an instructor in international tax training programs sponsored by the Organization for Economic Cooperation and Development from Seth Green Former Attorney Advisor and Associate Tax Legislative Counsel of Primary representative of the Treasury Department in connection with the 1997 amendment of section 355 of the Internal Revenue Code, and he participated in drafting substantial revisions to the regulations governing intercompany transactions, as well as mergers and other tax-free reorganizations Chambers ranked, District of Columbia, Band 4, Tax Rebecca I. Rosenberg Former Attorney Advisor and Assistant to the Branch Chief at the Heavily involved in Notice 98-5 (relating to disallowance of certain foreign tax credits) and the IRS s Tax Court litigation of Compaq Computer Corp. v. Commissioner, 113 T.C. 214 (1999), rev d 277 F.3d 788 (5th Cir. 2001) of the U.S. House of Representatives, where she drafted tax legislation covering all areas of the Code Beth Shapiro Kaufman Former Attorney Advisor and Associate Tax Legislative Counsel in Had principal responsibility at the Treasury for all tax policy matters affecting trusts and estates, including estate, gift, and generation-skipping transfer taxes, as well as income taxation of trusts and estates Practice includes estate planning as well as estate and gift tax controversies with the IRS Recipient of the inaugural Top Trusts and Estates Lawyer in Washington award, presented by the Washington Business Journal in 2008 Chambers ranked, Nationwide, Band 4, Wealth Management: Eastern Region

5 FOREIGN COUNSEL RELATIONSHIPS Beyond Mainstream Corporate and International Tax Matters WE HAVE EXTENSIVE EXPERIENCE IN: Tax-exempt organizations (public and private charities) Defense of tax fraud and white-collar criminal investigations Internal tax-related investigations in sensitive cases Financial institutions and products Insurance companies and products Pensions and executive compensation Tax accounting and tax computation issues IRS Whistleblower applications AND BEYOND TAX: U.S. political activity law Commercial litigation, including class action advice U.S. and cross-border bankruptcy reorganization proceedings

6 Complex Litigation Corporate Law Corporate Tax Creditors' Rights Employee Benefits Exempt Organizations General Tax Partnership Tax Political Activity Law Private Client Tax Controversies Tax Crimes Tax Litigation White Collar Defense International Tax One Thomas Circle, N.W. Suite 1100 Washington, DC % Cert no. BV-COC Caplin & Drysdale, Chartered