Jason G. Sullivan is a Tax Advisory Partner in the Charlotte, North Carolina offices of Dixon Hughes Goodman focusing on U.S. international taxation. Jason has more than 13 years of tax experience in both public accounting firms and industry. Prior to joining Dixon Hughes Goodman, Jason worked for a Big Four accounting firm providing complex international tax consulting services to both inbound and outbound multi-national companies in the manufacturing and financial services sector. Prior to law school, Jason practiced as a CPA for seven years in Columbia, South Carolina where he gained extensive U.S. as well as Canadian tax compliance experience.
Jason advises a broad range of multi-national clients on complex international tax matters. Jason's practice areas include FATCA and U.S. withholding tax, U.S. income tax treaties, dual consolidated losses, foreign tax credits, repatriation planning, subpart F analysis and planning, E&P and foreign tax pools computations, IC-DISC structuring and planning and cross-border mergers, acquisitions and restructurings.
Jason is the author of “Debt-Equity Hybrid Instruments in a Cross-Border Setting: A Focus on the U.S. Foreign Tax Credit”, which was published in the March 2009 Special Report of Tax Notes International.
Examples of Jason's involvement in various engagements include:
Advised on alternatives to combine two foreign subsidiaries of a leading global banking and financial services corporation involving a Type "D" tax-deferred reorganization concurrent with tax-efficient foreign tax credit planning;
Expressed an opinion on the U.S. federal income tax treatment of a $7 billion private equity fund’s investment in contingent legal claims in South America;
Authored a covered opinion for a leading global banking and financial services corporation on whether a hybrid instrument used in a cross-border financing structure should be considered debt or equity for U.S. federal income tax purposes;
Authored a covered opinion for a $3 billion fortune 100 financial services organization on whether a restructuring of its South American subsidiaries would trigger subpart F income;
Managed dual consolidated loss project for global banking leader with over 300 separate units for three consecutive years including a year of a major acquisition;
Designed new holding company structure for tax-efficient movement of capital of a global logistics company involving tax laws of over 20 different countries in anticipation of an IPO;
Assisted $3 billion publicly traded retail corporation in becoming compliant with the U.S. cross-border withholding tax and domestic back-up withholding tax laws and advising on compliance with FATCA;
Advised on structuring foreign acquisitions of U.S. multi-national corporations including U.S. consolidated return issues, implications of elections under IRC §338, foreign tax credit implications. FIRPTA implications and planning, withholding, income tax treaty issues and post-acquisition structuring and planning; and
Prepared and managed earnings and profits and foreign tax pools studies for numerous controlled foreign corporations of a global banking leader including implications of competent authority proceedings, foreign consolidated tax regime, accounting method issues, foreign tax redeterminations, tax-deferred reorganizations and E&P attributable to previously taxed income and U.S. effectively connected income.
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