William Sharp

Practice Areas

Taxation, Offshore Tax Compliance, Tax Controversy and Litigation and International Private Client Group

Career

William M. Sharp, Sr. is a tax partner with Holland & Knight and maintains offices in Atlanta, Tampa and San Francisco, where he serves a wide variety of international tax planning and tax controversy cases. With more than 40-plus years of experience, Mr. Sharp provides international and domestic tax advice to a variety of U.S.-based and foreign-based clients, including publicly traded and closely held entities. A significant portion of his practice also focuses on globally oriented high-net-worth clients, with a focus on non-U.S.-based family offices as well as several U.S.-based family offices.

As co-leader of the Holland & Knight Tax Controversy practice, Mr. Sharp has served and continues to serve in a multiplicity of cases before the U.S. Tax Court, the Internal Revenue Service (IRS) Appeals division, and also IRS examination cases. Mr. Sharp has also served as lead counsel or co-counsel to now approaching to well over 1,000 IRS voluntary disclosure cases.

From August 2013 until the end of 2018 Mr. Sharp represented 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 based on Swiss clientele and market share, and also one of the major Cantonal (state) banks, both of which cases were resolved under Category 3 of the program – 0 penalties and a non-prosecution agreement.

Mr. Sharp also has extensive experience in handling matters related to a number of cross-border compliance and disclosure initiatives, including the Foreign Account Tax Compliance Act (FATCA). Mr. Sharp also served as the lead partner in one of the largest FBAR cases litigated today with the case now on appeal to the 11th Circuit Court of Appeals for the second time in the past many years.

Professional Memberships

Mr. Sharp is a member of the American Bar Association, the Florida Bar Association, and a nonresident member of the State Bar of Texas. Mr. Sharp is also active in the Tax Executives Institute, the International Bar Association, the San Francisco Foreign Tax Club, and several other tax-related professional organizations. Mr. Sharp has also been a member of the 1,400-Member of Society of International Business Fellows and served as the chairman of this global business organization and also has served on the board for over 20 years.

Publications

Mr. Sharp has authored and co-authored tax-related articles in Tax Notes International and over a dozen major publications and law reviews over the years, and has published chapters (and spoken) 38 of the past 40+ years at the largest international tax conference in the U.S. (the Florida Bar Tax Section and FICPA Annual International tax Conference.

Personal

Mr. Sharp actively participates in supporting non-profit organizations, including the Society of Business Fellows (see above), as well as serving as a member of the Board of Councilors of the Atlanta-based Carter Center. Mr. Sharp has also supported a number of other non-profit organizations, particularly in developing countries, where he has been an active participant in a full scholarship Dominican Republic-based kindergarten through high school and now having a Nursing college outside of Santiago. Mr. Sharp also is the global legal advisor to a Harari-based, Zimbabwe highly diversified and low tuition cost school for kindergarten through high school, for the past 6 years.

Education