The former Associate Chief Counsel (International) for the Internal Revenue Service (IRS) has more than 25 years of international taxation experience, comprising both the private and public sectors. Most recently, Mr. Culbertson represented some of the largest US- and non-US- based multinationals in connection with their structural and transactional tax planning, including advice concerning cross-border acquisitions, restructurings, and financings. He also represented clients before the IRS, the U.S. Treasury, and Congress, regarding audit controversies, rulings, regulations, and legislative issues.
Previously, Mr. Culbertson served 13 years in the government, including a four-year stint as the Associate Chief Counsel (International) at the IRS from 1991 to 1995. During his tenure as Associate Chief Counsel, Mr. Culbertson participated in many significant developments in US international taxation, including the revision of the US transfer pricing regulations, the parallel development of new OECD guidelines, and the development of regulations relating to foreign tax credits, subpart F rules, outbound transfers, conduits, and other international tax issues.
Earlier in Mr. Culbertson’s career as an IRS lawyer in the Legislation and Regulations Division, he was the principal author of regulations under FIRPTA and Section 367. He also served on the staff of the Joint Committee on Taxation during the development of the Tax Reform Act of 1986.
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