Taxation, Offshore Tax Compliance, Tax Controversy and Litigation and International Private Client Group
William Sharp represents clients in a wide variety of international tax planning and tax controversy cases. With more than 35 years of experience, Mr. Sharp provides international and domestic tax advice to numerous U.S.-based and foreign-based clients, including publicly traded and closely held entities. His tax practice also focuses on globally oriented high-net-worth clients, including U.S. and foreign-based family offices. Mr. Sharp has served as lead counsel with respect to U.S. Tax Court, Internal Revenue Service (IRS) appeals and examination cases. He also has served as lead counsel or co-counsel to well over 1,000 IRS voluntary disclosure cases.
Mr. Sharp advises financial institutions and their clients on international tax enforcement initiatives. In addition, Mr. Sharp represents several Swiss-based banking institutions in connection with the U.S. Department of Justice Swiss Bank Program, including the largest bank participating in the program and one of the major cantonal banks (both cases were resolved under Category 3 of the program). Mr. Sharp also has extensive experience in handling matters related to the Foreign Account Tax Compliance Act (FATCA) and other cross-border compliance and disclosure initiatives.