Tax Advisers - Deloitte

United States
Edward Tanenbaum
Alston & Bird LLP
90 Park Avenue
New York, NY 10016
US
Tel: (1) 212 210 9425
Fax: (1) 212 210 9444
Email: edward.tanenbaum@alston.com
Website: www.alston.com
Edward Tanenbaum is chair of the firm’s International Tax Group and a member of its
Federal Income Tax Group. His practice is concentrated on domestic and cross-border
mergers and acquisitions and business transactions. Mr Tanenbaum’s practice consists
primarily of planning and structuring for US investments by foreign multinational
corporations and high net worth individuals.
Mr Tanenbaum has worked on numerous international joint ventures and acquisitions
involving cross-border spin-offs and ‘basis’ step-up elections. He has also structured a
cross-border sale/leaseback transaction involving different accounting and tax treatment
in the US and Germany.
Mr Tanenbaum has made significant contributions in the drafting of recently
promulgated tax regulations affecting withholding taxes on payments of US income to
non-resident aliens and foreign corporations and has been instrumental in the creation
of the new IRS Qualified Intermediary regime applicable to foreign financial
institutions. He has also secured a favourable Article 26(7) (treaty shopping) tax ruling
under the former US-Netherlands Income Tax Treaty valued in millions of dollars.
Mr Tanenbaum is a frequent lecturer on a variety of international tax issues and is the
author of a number of publications. He has spoken on the topics of international tax
withholding, treaty eligibility, limited liability companies and hybrid entities, business
organizations used in cross-border transactions, branch level taxes and foreign controlled
US corporations. Also, he has spoken before numerous professional organizations,
including the International Fiscal Association, Bank Tax Institute, International Tax
Institute, American Bar Association, and New York State Bar Association. He has written
numerous publications relating to international tax matters on topics such as withholding
taxes, transfer pricing and effectively connected income of foreign corporations.
Mr Tanenbaum is on the National Council of the International Fiscal Association and is
the vice-chair of the committee on US activities of Foreign Taxpayers and Tax Treaties
of the Tax Section of the American Bar Association. He is a director and past president
of the International Tax Institute and is a member of the Tax Section of the American
Bar Association, the New York State Bar Association and the Association of the Bar of
the City of New York.
Mr Tanenbaum received his LLM degree in Taxation from New York University School
of Law in 1980, and his JD degree from Fordham University School of Law in 1974 and
his BA degree, magna cum laude, from Queens College and the City University of New
York in 1971. He is admitted to practise in the State of New York and in the US Tax
Court.
312 Guide to the World’s Leading Tax Advisers