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IRS Examinations in 2009: Areas of Focus

 

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US Taxation of Foreign Investment in US Real Estate

   
   
   
   
  OUR attorneys
   
  Douglas R. McCullough
 

 

 

SHAREHOLDER:

Mr. McCullough concentrates his practice substantially on  corporate tax planning, corporate transactions, tax controversies, international business transactions, mergers and acquisitions and asset protection. Doug has represented businesses ranging from entrepreneurs to multinational corporations, in industries such as oilfield services, manufacturing, information technology, engineering and plastics.

Doug graduated with distinction from Indiana University in 1995, and cum laude from Texas Tech School of Law in 1998. Doug earned his Masters of Tax Law from Southern Methodist University School of Law in 1999. Doug has been in private practice in Texas since 1998.

AREAS OF PRACTICE:
Tax
Corporate  
Mergers & Acquisitions 
International Business

   

Phone: 713-650-9700
Fax: 713-650-9701
dmccullough@spain-law.com

 

 

EDUCATION:  
Southern Methodist University School of Law, LL.M., Taxation, 1999 
Texas Tech University School of Law, J.D., 1998
Indiana University, B.A., 1995 

ADMITTED TO PRACTICE
State Bar of Texas, 1998

PUBLICATIONS 
"U.S. Taxation of Foreign Investment in U.S. Real Estate" - North American Free Trade & Investment Report, May 30, 2006.
 
PROFESSIONAL ASSOCIATIONS
State Bar of Texas
Association for Corporate Growth 

 
HONORS AND ACTIVITIES:
Phi Beta Kappa 

 

REPRESENTATIVE TRANSACTIONAL EXPERIENCE:

  • Negotiated and drafted all aspects of asset and stock purchase agreements, mergers, and recapitalizations in both domestic and cross-border acquisitions in various industries including: oilfield services, industrial safety devices, manufacturing, healthcare, engineering, plastics, and information technology

  • Negotiated and drafted all aspects of various domestic and cross-border contracts including: sales and distribution, research & development, technology licensing, master services agreements, software development, OEM contracts, employment, consulting, subcontractor agreements, marketing, contract manufacturing, buy-sell agreements, joint-ventures, and partnership agreements

  • Preparation of finance documentation including loan agreements, promissory notes, security agreements, stock pledge agreements and private securities offerings

  • Regularly advise clients about minimizing state, local and foreign tax involving: the choice of business entity, structuring the purchase or sale of businesses, corporate restructuring, and in-bound or out-bound business transactions

  • Assist clients on matters related to corporate governance, corporate finance, corporate restructuring and regulatory compliance

  • Represent clients in state and federal tax inquiries, audits and appeals

  • Develop and implement tax-planning strategies to minimize  worldwide tax liabilities, including analysis and planning for the availability of tax treaty benefits

  • Advise clients about estate planning including preparing estate plans to minimize estate taxes and protect assets

 

 

 

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