Bruce N. Davis engages in a general tax practice, with an emphasis on the taxation of global transactions and business structures.

He advises on acquisitions and divestments of foreign businesses by US-based companies and of US businesses by foreign based companies, as well as the establishment of international joint ventures.  In addition, Mr. Davis assists multinational clients in the development and implementation of structures to achieve worldwide tax efficiencies by lawfully redirecting taxable income to tax-favored locations, reducing multiple taxation of cross-border cash flows, deferring taxation of unrepatriated foreign income, and optimizing the use of foreign tax credits.

Mr. Davis is experienced in the use of international tax minimization techniques such as:

• Revision of intercompany transfer pricing policies;
• Use of tax-favored distribution center or service center locations;
• Establishment of leasing and finance structures;
• Rearrangement of parent subsidiary ownership structures (including use of holding companies);
• Implementation of structures for worldwide development and use of intangible property;
• Application of bilateral or multilateral tax treaties and other inter-government conventions; and
• Use of "hybrid" transactions, entities or financial instruments whose treatment for US tax purposes differs from their treatment for foreign tax purposes.

He also has obtained advance tax rulings approving proposed transactions, achieved favorable administrative and judicial resolutions of tax adjustments proposed by the US Internal Revenue Service, obtained refunds of overpaid US tax, successfully contested proposed foreign tax adjustments through tax treaty provisions (so called "competent authority" proceedings), and obtained advance pricing agreements in which two or more governments’ tax authorities approve the client’s methodology for determining intercompany transfer prices.

Mr. Davis was formerly the principal special assistant to the associate chief counsel (International) of the Internal Revenue Service.  He maintains close relationships with senior US Treasury Department and Internal Revenue Service officials and other government personnel, particularly with those individuals who are responsible for development and enforcement of the government’s position on international tax issues.