Lewis J. Greenwald

Lewis J. Greenwald is a U.S. international tax partner in the Tax Department of our Boston officeand head of the firm's International Tax Practice Group. Prior to joining ZAG/S&W, Mr. Greenwald was a partner in the International Tax Services Department in PricewaterhouseCoopers’ Boston office. His practice is focused on providing international tax planning for multinational clients. Mr. Greenwald has approximately 25 years of tax law experience. He has written numerous articles for various international tax journals and he is the Regional Vice President of the New England Region of The International Fiscal Association (IFA). He is on the Board of the National Foreign Trade Council (NFTC) and on the Board of Advisers for the Journal of International Taxation. 

Publications

• The IRS Should Quickly Back Away From Notice 2012-15, Tax Notes Int’l (April 23, 2012)
• Branch Rule Final Regs. Tweak the "Demonstrably" Greater Contribution and Grouping Rules, Journal of International Taxation (April 1, 2012)
• New U.S. Regs Confirm That Basis Is Lost in Some Cash D Reorgs, Tax Notes International (March 26, 2012)
• The Exceptional Importance of Getting U.S. International Tax Compliance Right, Tax Notes International (August 29, 2011)
• Nothing for Something: Avoiding U.S. Withholding Obligations on Phantom Interest, Tax Notes International (June 6, 2011)
• Manna From Heaven: LMSB Provides Important Relief For "Available On Request" GRAs, Journal of International Taxation (January 2011)
• Taxpayers Should Consider the Benefits of Rescission Well Ahead of Year End, Practical U.S./Domestic Tax Strategies (October 8, 2010)
• Securing that Slippery Worthless Stock Deduction, Journal of International Taxation (September 2010)
• Xilinx: Time for a Tweak to Treas. Reg. Section 1.482-1(b)(1)?, Tax Notes International (July 12, 2010)
• Veritas v. Comr.: Tax Court Finds IRS's §482 Allocations To Be "Arbitrary, Capricious, and Unreasonable", Tax Management International Journal (May 14, 2010)
• The Fabulous New Substantial Contribution Test Is Made Even More Fabulous, Journal of International Taxation (December 2009)
• Reconciling the "Irreconcilable" - 1(b)(1)-7(d)(1) Conflict; Understanding the "All Costs" Requirements to Mean "All Costs Shared by Arm's-Length Parties": Xilinx v. Comr. Revisited, Tax Management Memorandum (November 9, 2009)
• Obama Seeks to Tax Outbound Transfers of Workforce in Place, Journal of International Taxation (September 2009)
• Code Section 457A Requires Immediate Attention by Certain Sponsors of Nonqualified Deferred Compensation Arrangements, Practical U.S./International Tax Strategies (June 2009)
• Through the Glass [Even More] Darkly: Revisions to the Not-So-Fabulous Branch Rule, Journal of International Taxation (May 2009)
• The Remarkable Taxpayer-Friendly Evolution of the DCL Regime, Tax Notes International (April 14, 2009)
• IRS Enhances Opportunity for U.S. Multinationals to Access Cash from Controlled Foreign Corporations, Practical U.S. /International Tax Strategies (October 2008)
• The Fabulous New 'Substantial Contribution' Test, Journal of International Taxation (October 2008)
• Inversions 'Lite': Finding 'Substantial Business Activity' Under the New U.S. Regs, Tax Notes International (August 7, 2006)
• Proposed U.S. Regulations Regarding Dual Consolidated Losses, Tax Notes International (August 15, 2005)
• New Final Regs. on Trigger Events for Recapture of Dual Consolidated Losses, Journal of International Taxation (December 22, 2003)
• New U.S. Guidance on Tax-Free Spin-Offs, Tax Notes International (August 2003)
• Final Piece to 894(c) Reg. Puzzle: Treaty Benefits for Payments by Domestic Reverse Hybrids, Journal of International Taxation, 894(c) Regs. (January 15, 2003)
• "Structuring Israeli/U.S. Intercompany Relationships to Minimize (Eliminate) U.S. Taxes," ACC Israel Newsletter (September 2008)
• "The New U.K.-U.S. Agreement on Dual Consolidated Losses," Tax Notes International (November 2006)
• "Proposed Regulations Would Shut Down Guardian and Reverse Hybrid Structures," Derivatives Financial Products Report (October 2006)
• "Temporary Regulations Provide Rules for Allocating a Partnership’s Foreign Taxes," Journal of International Taxation (September 2004)
• "Foreign Tax Credit Limitation Final Regs. Under Sections 864(c) and 904(d), Proposed Regs. Under Sections 902 and 904," Journal of International Taxation (October 2001)
• "Section 894(c) Final Regs. Simplify Treaty-Benefit Rules for Income Paid to 'Fiscally Transparent Entities'," Journal of International Taxation (December 2000)
• "New Section 367(e)(1) Regulations: Major Policy Shift For IRS, Planning Opportunities for Distributing Corporations," Journal of International Taxation (October 1999)
• "Analytical Framework for Electronic Commerce Helps to Determine Tax Implications in Multiple Jurisdictions," Journal of High-Tech (September/October 1998)
• "U.S. Record Companies Face Withholding Tax Problems," Journal of International Taxation (November 1995)

News

• February 20, 2012
  New Regs Confirm that Basis is Lost in Some Cash D Reorgs
  Tax Notes
• June 14, 2011
  Sullivan & Worcester LLP Receives Top Rankings in Six Categories in the 2011 Edition of The Legal 500 United States
  S&W Press Release
• Financial Crisis Timeline
• March 18, 2008
  S&W Announces Formation of Credit Crisis Task Force
  S&W Press Release

Seminars & Speaking Engagements

• May 15 and May 16 (8:30 a.m. - 5:00 p.m.)
  Boston (Sullivan & Worcester) and New York (The Kitano)
  The 5th Annual Worldwide Tax Update
• February 16-18, 2012
  Foreign Activities of U.S. Taxpayers, U.S. Activities of Foreigners and Tax Treaties, Foreign Lawyers Forum and Transfer Pricing
• November 17, 2011
  Embedded Intangibles in the Provision of Services
• May 17 and May 18, 2011 (8:30 a.m. - 5:00 p.m.)
  4th Annual Worldwide Tax Update
• December 3, 2010
  Transfer Pricing: A U.S. International and Massachusetts Update
• November 18, 2010
  New Foreign Tax Credit Rules
• October 19, 2010 (8:00 a.m. - 4:00 p.m.)
  Worldwide Transfer Pricing Update

Client Advisories

• Taxation in Israel
• Taxpayers Should Consider the Benefits of Rescission Well Ahead of Year End
• Taxpayers Should Consider the Benefits of Rescission Well Ahead of Year End
• Code Section 457A Requires Immediate Attention by Certain Sponsors of Nonqualified Deferred Compensation Arrangements

Practices

• Credit Crisis Task Force
• International Tax
• Mergers & Acquisitions Tax
• Tax

Bar Admissions

• New York, 1995
• Massachusetts, 2003

Education

• J.D., Fordham University School of Law, 1994
• M.B.A., Rutgers University Graduate School of Management, 1987
• B.A., New York University, 1980

Awards & Honors

• Best Lawyers in America (2011, 2012)