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.
