Specializes in international and federal tax matters
Earned a master’s degree in taxation (LL.M.) from Boston University
New York
@alvarezmarsal
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Nicolaus F. McBee is a Senior Director with Alvarez & Marsal Tax, LLC in New York.
With over six years of international and federal tax experience, Mr. McBee provides strategic and practical tax advice to clients. His expertise includes foreign currency issues, global supply chain planning/restructuring, international reorganizations, intangible property planning, holding company planning, international compliance, check-the-box planning and cross-border acquisitions.
Prior to joining A&M, Mr. McBee spent two years with the Internal Revenue Service (IRS) where he assisted taxpayers with domestic and international tax compliance.
Mr. McBee earned a J.D. from Thomas Jefferson School of Law and a master's degree in taxation (LL.M.) from Boston University. He is a licensed attorney in the state of Illinois.
He has contributed to several articles and reports discussing international tax issues including intangible property planning, foreign tax credit utilization, U.S. international issues surrounding technology companies and tax reform.
In FedEx Corp. v. United States, the U.S. District Court for the Western District of Tennessee (the Court) addressed a subtle foreign tax credit issue, bringing into question the validity of regulations concerning the repatriation of controlled foreign corporation (CFC) earnings under the 2017 Tax Cuts and Jobs Act (the TCJA).
In the recent Tax Court case of Farhy v. Commissioner, 160 T.C. 6 (2023), the IRS “went to court and watched,“ only to learn that its long-held position on a procedural rule for certain information reporting penalties was incorrect.
On July 8th, the U.S. Treasury Department gave notice that the 1979 tax treaty between the U.S. and Hungary (the U.S.-H Treaty) was being terminated — period, full stop, without replacing it with a new one.
On April 4th, the United States District Court for the District of Colorado in Liberty Global Inc. v. United States invalidated a U.S. Treasury Department regulation which attempted to backfill certain aspects of the section 245A dividends received deduction enacted in the Tax Cuts and Jobs Act.
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