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Allen J. Littman

Allen Littman’s practice focuses on international and cross-border tax planning for both domestic and foreign-based businesses, as well as a broad range of domestic and international tax controversy matters. Mr. Littman has had significant experience in a broad range of international and corporate tax issues from the perspectives of outside adviser; corporate tax executive responsible for the design, implementation and defense of company tax plans; and Congressional tax staff responsible for the formulation and implementation of effective tax legislation and treaty policy.

Before joining the firm, Mr. Littman served for over five years as Legislation Counsel to the Joint Committee on Taxation of the United States Congress, where he focused primarily on issues involving international and corporate taxation. Mr. Littman’s responsibilities at the Joint Committee on Taxation included developing and drafting legislation and legislative history, reviewing and analyzing proposed tax treaties for consideration by the U.S. Senate, reviewing IRS settlements of large tax refund claims, analyzing the President’s budget proposals and preparing reports in connection with various Congressional hearings. While at the Joint Committee on Taxation, Mr. Littman worked on the international tax provisions of the American Jobs Creation Act of 2004, and more recently enacted international tax legislation and proposals, including proposals relating to the anti-deferral provisions of subpart F, the deferral of deductions allocable to foreign-source income, the shipping and oil and gas industries, intangibles and transfer pricing, offshore tax compliance, individual and corporate expatriation, earnings stripping and limitation-on-benefits. He also organized the Joint Committee’s work on tax treaties and protocols, including the 2007 U.S.-Canada protocol, the 2006 U.S.-Germany protocol and the 2007 U.S.-Belgium treaty.

Before joining the Joint Committee on Taxation, Mr. Littman was the Director of International Tax at MCI, a large multinational telecommunications and internet corporation, where he was responsible for planning, implementation and compliance with regard to U.S. taxes attributable to cross-border activities and all foreign taxes, including the structuring of international acquisitions, divestitures, joint ventures and financings. While at MCI, he supervised the design and implementation of a global transfer-pricing plan and managed in-country audits; designed and implemented a European entity reduction and recapitalization plan and a tax-effective holding company structure; and standardized the policies for global customer and procurement contracts.

Prior to joining MCI, Mr. Littman practiced law in the Washington, D.C., office of Roberts and Holland LLP, where he was responsible for advising both domestic and foreign-based businesses on a wide range of international tax matters, including subpart F, permanent establishment, financing, audits, appeals and litigation, as well as corporate and tax-free exchange matters.

Representative Experience:

• Structuring of foreign investments by U.S. businesses, including acquisitions and joint ventures involving manufacturing and/or the exploitation of intangible assets in multiple jurisdictions.
• Structuring of U.S. investments by international businesses, including investments in U.S. real property.
• Utilization of tax treaty benefits in cross-border transactions.
• Tax audits, appeals, competent authority, voluntary disclosure, private letter rulings and other procedural matters for individuals and business entities. 
• Legislative policy tax matters involving advice and advocacy of reasoned interpretations of existing law and proposals for change.

Representative Industries:

• Technology, data processing, hosting, computer systems design, software and telecommunications.
• Foreign financial institutions, including issues arising under the Foreign Account Tax Compliance Act (FATCA).

Mr. Littman is a Certified Public Accountant and formerly practiced law in the areas of bankruptcy and commercial litigation.

Mr. Littman has been a frequent speaker in the areas of tax-effective structuring for international operations, the international taxation of e-business and tax legislation matters. A partial list of presentations and publications follows.

Presentations:

• Instructor: “Overview of Section 482,” Tax Executives Institute International Tax Course (July 2011, 2010 and 2009)
• Panelist: “Should Section 956 be Repealed?” Tax Management (May 2011)
• Panelist: “International Tax Administrative and Legislative Outlook,” Federal Bar Association Section of Taxation 35th Annual Tax Law Conference (February 25, 2011)
• Sole Presenter: “The Tax Relief, Unemployment Insurance Reauthorization, and Job Creation Act of 2010,” ExecSense Webinars (February 15, 2011)
• Panelist: “Selected International Tax Provisions of The Education Jobs and Medicaid Assistance Act, H.R. 1586,” Strafford Publications (October 7, 2010)
• “The Recently Enacted Expatriation Tax Provision and the International Tax Legislative Outlook,” BNA Tax Management International Luncheon, Washington, DC (July 22, 2008)
• “Telecom Taxation: View from Capitol Hill,” Telecom Taxation 2005, Telestrategies, Tysons Corner, VA (June 15, 2005)

Publications:

• Co-Author: “The IRS Approach to Retroactive Relief for Voluntary Disclosure Tapayers,” Tax Notes (March 7, 2011)
• “Energy Provisions in President Obama’s First Budget,” ABA Energy Committee Newsletter (July 10, 2009)
• Co-author: “The Proposed Regulations Regarding the Taxation of Space, Ocean and Communications Activity: How the Failure to Follow Relevant Policy Guidelines Leads to Quixotic Taxation,” 80 Taxes No. 3, p.185 (2002)
• “Space, Ocean and Communications Income—The Final Frontier?” 30 Tax Management International Journal 195 (2001)