Experience

IRS, Office of Chief Counsel

• United States
• Law Practice
• 400 - 500 Employee

• Attorney, Office of Chief Counsel, IRS (LB&I)

  • Jul 2022 - Present



Self-employed

• Tax Consultant

  • Jan 2021 - Present



EY

• United Kingdom
• IT Services and IT Consulting
• 700 & Above Employee

• Senior Manager - National Tax - International Tax Services

  • Jun 2003 - Jan 2021

  Ben worked in the EY National Tax in the International Tax and Transactions Services group. Ben worked primarily with multinationals on their cross-border investments. Ben’s day to day practice focused on issues related to subpart F, GILTI inclusions, cross-border restructuring, repatriation and IP planning and treaty analysis. Ben is particularly strong in all matters related to the US foreign tax credit, such as expense apportionment, sourcing and basketing of income and the allocation of taxes to groups of income. In response to globalization and the explosion of cross-border digital commerce, numerous novel taxes have been introduced worldwide that are designed to capture a portion of the revenues generated by cross-border activities. These new taxes have unique features which call into question whether the taxes are creditable in the United States. Ben authored detailed technical memoranda analyzing the substance of several of the new digital taxes, ultimately identifying and distinguishing those foreign taxes are creditable for US income tax purposes from those that are likely not creditable. Ben utilizes his extensive technical knowledge to help his clients efficiently operate in an increasingly challenging international tax environment. Show less



Cadwalader, Wickersham & Taft LLP

• United States
• Law Practice
• 700 & Above Employee

• Associate Attorney, Tax

  • Sep 2001 - Jun 2003

  As part of Cadwalader's tax department, Ben's responsibilities included analyzing structured finance structures, with a strong emphasis on the treatment for US tax purposes of complex financial derivatives. Ben also advised on general corporate transactions, partnership allocations and the tax consequences investment opportunities for US not-for-profit organizations. As part of Cadwalader's tax department, Ben's responsibilities included analyzing structured finance structures, with a strong emphasis on the treatment for US tax purposes of complex financial derivatives. Ben also advised on general corporate transactions, partnership allocations and the tax consequences investment opportunities for US not-for-profit organizations.