Firm / Organisation

Caplin & Drysdale, Chartered

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This content is provided by Caplin & Drysdale, Chartered.

Chairman: J Clark Armitage
Number of partners: 32
Number of lawyers: 65
Languages: Brazilian Portuguese, English, French, German, Hebrew, Italian, Korean, Mandarin, Russian, Spanish

Firm Overview:
Founded by former IRS commissioner Mortimer Caplin, Caplin & Drysdale is headquartered in Washington, DC, with an office in New York City. For more than 50 years, the firm has provided a full range of tax, tax controversy, and related legal services to companies, organizations, and individuals throughout the United States and around the world. The firm also provides counseling on matters relating to bankruptcy, creditors’ rights, exempt organizations, political activity, complex litigation, private clients, corporate law, and white-collar defense.

Practice Overview:
Caplin & Drysdale’s private client group serves as trusted counsel to individuals and families on domestic and cross-border tax and estate planning issues, including the use of trusts, partnerships, corporations, and foundations and other charitable vehicles, the application of tax treaties, and the administration of trusts and estates. The private client group advises clients on all aspects of their estate planning, helping clients to define, develop and implement family values and goals while creating tax-efficient wealth preservation plans. The group also represents domestic and international clients in IRS disputes and DOJ investigations regarding their income, estate, gift, and generation-skipping transfer tax liabilities. Additionally, lawyers within the group advise individuals with respect to their U.S. tax compliance issues, including pre- and post-immigration issues for international clients and expatriation planning for U.S. citizens and residents.

Ranked members Beth Shapiro Kaufman, Anne J. O’Brien, and Megan E. Wernke draw on their considerable experience to advise clients on tax planning and tax controversies. Ms. Kaufman is particularly active in the generation-skipping transfer tax area, having previously served as the associate tax legislative counsel at the Treasury Department, responsible for all estate, gift, and generation-skipping matters. Ms. O’Brien draws on over 30 years of experience representing domestic and international clients, with a focus in counseling clients regarding family business ownership and business succession planning. Ms. Wernke advises clients on their estate plans and also relies on her experience in tax controversies and litigation to advise clients with respect to substantial gift tax, estate tax, generation-skipping tax, and fiduciary income tax issues at all stages of controversy. Other members in the group include: Dianne C. Mehany who utilizes her background in tax controversy to counsel high-net-worth individuals on cross-border taxation and to defend positions in contentious proceedings with the IRS or DOJ, particularly with respect to their interests in foreign trusts and CFCs; Kirsten Burmester who brings significant experience in PFIC and CFC rules, as well as the throwback rules applicable to foreign trusts, and the application of the 2017 repatriation (section 965) tax; Victor A. Jaramillo, who advises clients on international tax planning and controversies, tax treaty issues and competent authority proceedings, tax noncompliance issues, and pre-immigration and expatriation planning; Jonathan S. Brenner, who advises domestic and international clients with respect to the taxation of individuals and closely held businesses, including the application of tax treaties and subpart F; and James E. Salles, who advises with respect to the taxation of individuals and closely held businesses, Federal and State tax audits and ruling requests, and coordinates with clients’ accountants on return preparation issues. Of Counsel Alison F. Egan advises on a wide range of estate planning matters, leveraging her quantitative analytic skills and her knowledge of cross-border tax issues. The group is supported by talented associates Sae Jin Yoon, Amanda M. Leon, and Sarah J. Racicot. The firm’s attorneys are recognized for developing creative solutions and exercising excellent judgement when assisting clients with their complex tax issues.

Main Areas of Practice:
■ Caplin & Drysdale’s private client group engages in sophisticated, tax-sensitive estate planning for clients with domestic or cross-border issues, including expatriation, changes of residence, investments in the U.S. and elsewhere, treatment of foreign corporations and foreign trusts, and tax compliance/controversies.
■ The group tackles difficult technical issues relating to estate and gift taxes, generation-skipping transfer tax, income taxation of individuals, trusts and estates, and immigration or expatriation planning and defense.
■ • Several of the group’s younger members, particularly Dianne C. Mehany, Victor A. Jaramillo, and Kirsten Burmester, have developed a sophisticated and unique expertise advising high-net-worth individuals with cross-border tax issues in contentious proceedings during audit, appeals, and litigation against the IRS or DOJ.
■ The firm’s attorneys help clients seeking private letter rulings, competent authority relief, and other advice from the IRS.
■ • The firm keeps clients up to date on legislative developments and IRS guidance, and guides them through interactions with the IRS. The group has analyzed the often corporation-driven 2017 tax reform laws to apply international new rules such as GILTI, FIDI, and the repatriation (Section 965) tax to high-net-worth individuals.
■ The firm’s attorneys also serve as expert witnesses in various high-profile tax matters.
■ • The group draws upon the considerable know-how of the firm’s exempt organizations group, including Douglas N. Varley, William D. Fournier, Sharon P. Want, Meghan R. Biss (former technical advisor to the IRS Director of Exempt Organizations from 2015 to 2018) and associate Amanda Reed to help clients with philanthropic planning, establishing private foundations, and advising clients on contribution limits.
■ • In estate and gift tax controversy cases, as well as criminal investigations of wealthy individuals, the group collaborates with Charles M. Ruchelman, Christopher S. Rizek, Scott D. Michel, Mark E. Matthews, Niles A. Elber, Mark D. Allison, and Zhanna A. Ziering – members of the firm’s tax controversy group – to bring both substantive and procedural experience to the case.

Contact: Beth Shapiro Kaufman
Tel: +202 862 5062
Email: [email protected]

The firm also has an office in New York at:
600 Lexington Avenue,
21st Floor, NY 10022
Tel: +212 379 6000
Fax: +212 379 6001