Expertise in repatriation, foreign tax credits and cross-border transactions
New York
@alvarezmarsal
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Brendan Sinnott is a Managing Director with Alvarez & Marsal Tax in New York. He serves with the firm’s International Tax practice. He advises closely held, publicly traded and private-equity portfolio companies, and works closely with Chief Financial Officers and Vice Presidents of tax to develop tax and cash planning strategies.
With more than 10 years of experience in international tax, Mr. Sinnott advises multinational corporations on the U.S. tax implications of global transactions, helping them mitigate risks and identify planning opportunities. He brings expertise in both inbound and outbound international tax issues and has worked with clients across a range of industries, including technology, telecommunications, professional services and manufacturing.
Additionally, Mr. Sinnott advises corporations on repatriation and foreign tax credit analysis, permanent establishment planning, cross-border transactions, Subpart F planning, international compliance, accounting for income taxes and international aspects of the Tax Cuts and Jobs Act of 2017, including GILTI, BEAT, FDII and the Section 965 transition tax.
Mr. Sinnott earned a bachelor’s degree in accounting and a master’s degree in taxation from the University of Miami. He is a licensed CPA in New York.
In an article published in Tax Notes Federal, Kevin M. Jacobs, Brendan Sinnott and Kenneth Brewer analyze the decision's impact on tax law interpretation and advocate for fair treatment of taxpayers.
On June 20, 2024, the U.S. Supreme Court ruled that the TCJA section 965 transition tax imposed on certain U.S. shareholders is constitutional in Moore v. United States. In this alert, we focus on the broader legacy that Moore may leave as businesses and individuals consider the implications of the Court’s analysis and decision.
The U.S. international tax regime is fraught with traps for the unwary for non-U.S. persons doing (or thinking of doing) business in the United States. Complicated rules affect whether non-U.S. persons are subject to tax on their U.S.-sourced income as well as the extent to which their investments in domestic and foreign corporations could affect certain U.S. shareholders.
Treasury recently issued Notice 2023-80 that lays the groundwork for future rulemaking, addressing the interaction between foreign tax credits and Pillar 2 rules.
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