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Allen J. Littman

Allen Littman’s practice focuses on international tax planning for both domestic and foreign-based businesses. 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.

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 list of presentations and publications follows.

Presentations:

• “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)
• “Latin America Tax Issues: A U.S. International Tax Director’s Perspective,” Taxation Issues Affecting Business in Latin America, Council of the Americas, New York, NY (April 24, 2002) and 2001 Latin American Tax Summit, Washington, DC (November 7-9, 2001)
• “Classifications of Intangibles and Contractual Ventures,” panel discussion of Structuring Intellectual Property Rights in International Transactions, 30th Annual Conference of the USA Branch of the International Fiscal Association, Washington, DC (March 7-8, 2002)
• “Taxation of E-Commerce in Latin America,” 2001 Latin American Tax Summit, Washington, DC (November 7-9, 2001)
• “International Joint Ventures—Organization, Operation and Disposition,” Second Annual Institute on International Taxation, Georgetown University Law Center, Washington, DC (April 19-20, 2001)
• “eCommerce Implications for Subpart F, Income Sourcing Rules and Transfer Pricing,” IRS-GWU Thirteenth Institute on International Taxation, Washington, DC (December 7-8, 2000)
• “Taxation of Electronic Commerce Transactions in Latin America: Permanent Establishment and Consumption Tax Issues,” Fourth Annual Latin America Tax Forum, Insight Information, Washington, DC (October 30-November 1, 2000)
• Co-Chairman of Taxation of Electronic Commerce—Tax Efficient Strategies for E-Commerce, Insight Information, Chicago, IL (June 27-28, 2000)
• “Taxation of Electronic Commerce in Latin America,” Third Annual Forum on Tax Aspects of Structuring Business Operations in Latin America, Insight Information, Washington, DC (November 17-19, 1999)
• “Re-Engineering Transfer Prices Following a Change in Organizational Control,” Transfer Pricing for Telecoms, Vision in Business, Amsterdam (April 26-27, 1999)
• “Structuring and Operating Latin American Joint Ventures,” Tax Aspects of Doing Business in Latin America, Insight Information, New York, NY (December 2-4, 1998)
• “Tax Issues for Structuring Joint Ventures,” Tax Strategies for Telecom Operators, Vision in Business, London (September 28-29, 1998)

Publications:

• 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)
• “The Proposed Regulations Under Section 863 (Inventory),” Tax Management International Journal 219 (1996)
• “IRS Issues Final Regulations on Conduit Financing Arrangements,” 43 Canadian Tax Journal 2243 (1995)
• “IRS Issues Proposed Regulations on Conduit Financing Arrangements,” 43 Canadian Tax Journal 515 (1995)
• Co-author, “Brown Group Revisited: Aggregate Aggiornamento or Entity Encroachment?” 24 Tax Management International Journal 186 (1995)
• Co-author, “Aggregate Arrogance or Entity Error? Brown Group v. Commissioner,” 23 Tax Management International Journal 336 (1994)
• Co-author, “The Use of Middlemen in Importation of Goods: Inconsistencies Between Tax and Customs Valuation Rules,” 23 Tax Management International Journal 233 (1994)
• Co-author, “Are Customs and Tax Authorities Building an Information Superhighway?” State Tax Notes (1994)
• Co-author, “Caution Urged in Providing Tax Data to Customs in Light of Agency’s Sharing Statistics with States,” National Customs Brokers & Forwarders Association of America Bulletin No. 93-9 (1993)
• Co-author, “Contracting Out, Not Branching Out: Manufacturing Revisited,” 22 Tax Management International Journal 343 (1993)
• “Economic Performance Regulations and Related Developments,” Tax Notes Today 92 TNT 199-102 (1992)
• Co-author, “The Final Regulations on Exchanges of Personal Property, Multiple-Asset Exchanges and Deferred Exchanges Under Section 1031,” 19 J. Real Estate Taxation 91 (1992)
• Co-author, “Tax-Free Real Estate Transactions,” 19 J. Real Estate Taxation 53 (1991)
• “Ordinary Losses on Sales of Stock: Is Circle K an Unwarranted Expansion of Arkansas Best?” 32 Tax Management Memorandum 343 (1991)
• Co-author, “Tax-Free Real Estate Transactions,” 18 J. Real Estate Taxation 373 (1991)
• Co-author, “Recent Developments Affecting Possessions Corporations,” 19 Tax Management International Journal 29 (1991)
• “Payments of Trust Fund Liabilities In and Before Bankruptcy,” 42 Florida L. Rev. 711 (1990)