Partner

Ian Shane

212.885.8838 ishane@bartonesq.com
Partner

Ian Shane

212.885.8838 ishane@bartonesq.com
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Ian Shane is a partner in Barton’s tax practice. He is a skilled and published U.S. and international corporate tax attorney handling tax planning and structuring. Ian is highly experienced in domestic and cross border transactions, including inbound and out bound, mergers and acquisitions, and general problem solving. Ian advises U.S. companies on international tax planning issues arising from investing overseas, mainly in Europe and Asia. He routinely counsels on choice of entity, check-the-box regulations, as well as cross border financings, transfer pricing, and inbound and outbound asset and stock transfers.

Ian has substantial experience in U.S. federal tax planning and in particular planning with tax treaties, foreign tax credit planning, controlled foreign company issues and issues relating to passive foreign investment companies.

Ian also regularly works on U.S. domestic tax issues including mergers and acquisitions, loss carry overs, elections to treat stock acquisitions as asset acquisitions, tax-free reorganizations, spin-offs and stock redemptions. He advises on tax planning for domestic and international intellectual property assets and structuring corporate debt and equity, including thin capitalization issues.

Ian is a solid resource for tax planning for private equity funds including the use of U.S. listed shell companies. He also handles tax planning for individuals in the entertainment, sports, and fashion industries. For corporations and entities taxed as partnerships, Ian has experience in industries including, finance, airlines, music publishing and streaming, social gaming, hotels and resorts, medical devices, and investor relations.

Ian is dual qualified being a New York attorney and qualified to practice in the United Kingdom.

Prior to joining Barton, Ian was a partner at Michelman & Robinson and was also with DLA Piper, Salans, and Evans Dodd (London Office).

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Ian Shane > Matters

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Representative Matters

Represented an Australian company offering social gaming services to US customers and advised on whether their use of tokens (which were exchangeable in certain circumstances for cash) amounted to gambling under the US Tax Code and, if so, whether a gambling excise tax was payable by the company.

Represented a Gibraltar-based social gaming company offering sweepstake games to US customers whereby they could win prizes. Provided advice on structuring this business so that they did not have a taxable presence in the US, advised on whether IRS Form 1099 had to be provided to prize winners, and advised on whether state sales tax was required to be collected from customers.

Provided legal assistance to client in the sale of his 50% interest in a technology business consulting company and the sale of certain intellectual property owned by the client personally and licensed to the company.

Assisted a bank with the completion of IRS form W-8BEN-E so that the bank could sell its investment holdings in a payment card services corporation without the need to pay US withholding tax. Worked with the payment card company's registrars EQ Shareholder Services to satisfy them that the bank met all the requirements of the US/Poland double tax treaty to qualify for a 0% rate of US withholding tax.

Represented a major foreign airline against the New York State Department of Finance and Taxation. The matter was related to access fees paid to other airlines so that the client's first and business class passengers could use other airlines' airport lounges, and whether such access fees were correctly subject to New York state sales tax.

Advised a consultancy company with respect to an employee who was a tax resident in Iraq but was moving to the US to study for a year and wanted to continue working for the client. Provided advice on structuring this situation so that the client was not treated under US law as having a permanent establishment in the US for tax purposes.