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John M. Staples International Tax, Structured Finance, Tax Withholding and
Reporting, Transfer Pricing
Washington, DC
Tel – +1 (202) 783-1500
Fax – +1 (202) 783-1523
jstaples@bsmlegal.com
John Staples is the managing partner of the U.S. office of Burt,
Staples & Maner, LLP. Mr. Staples splits his time between the firm’s
Washington D.C. and London offices and specializes in all aspects of
in-bound and out-bound U.S. international taxation, including
international tax planning, advice and audit defense. Mr. Staples’
clients include major financial institutions, multinational
corporations headquartered in the United States and Europe, banking
and business associations, foreign governments, and high net worth
individuals.
Prior to joining Burt, Staples & Maner, LLP in April 2003, Mr.
Staples served as the Associate Chief Counsel International of the
US Internal Revenue Service, the highest international tax position
in the I.R.S. Mr. Staples directed a staff of more than 120
attorneys, tax law specialists, program analysts and support
employees, including the staff of the Advance Pricing Agreement (“APA”)
program. The Office of Associate Chief Counsel International (“ACCI”)
provides advice to the IRS and US Treasury Department on
internationally related litigation, technical guidance such as
regulations and rulings, advice to IRS field operations, private
letter rulings, advice on US tax treaties, US positions in
multinational fora, and legislative proposals. While Associate Chief
Counsel (International), Mr. Staples personally oversaw the U.S.
government’s implementation of the section 1441 withholding tax
regime. Mr. Staples currently represents a large number of financial
institutions and multinationals with respect to both domestic and
non-resident alien withholding and reporting compliance and audit
defense.
Before his appointment as Associate Chief Counsel (International) in
January 2001, Mr. Staples served as the Acting Deputy Associate
Chief Counsel (International-Technical) and as the Assistant Chief
Counsel (International-Technical). In both positions, Mr. Staples
had primary responsibility for managing the technical international
tax program for the office. From June 1995 to February 1998, Mr.
Staples served as Assistant to IRS Commissioner Richardson where he
advised the Commissioner on a wide array of issues, particularly
international, financial products and financial institutions tax
issues.
Prior to joining the IRS, Mr. Staples specialized in international
taxation at Burt, Maner & Miller and the Washington D.C. office of
Sutherland, Asbill & Brennan.
Mr. Staples has extensively lectured and published on a wide array
of international tax topics as part of both his government service
and his private practice. Typical audiences include Bar groups,
trade and banking associations, and industry groups. Mr. Staples has
also presented private international tax training seminars for his
clients.
Mr. Staples is frequently contacted by the tax press for his views
on international tax developments.
Education & Credentials
BA – Georgetown University School of Foreign Service (1982)
JD – Georgetown University Law Center (1989) (Magna Cum Laude, Order
of the Coif)
Bar Admissions
DC
Pennsylvania (inactive)
Speeches
The following only lists speeches given during or after 2003, as Mr.
Staples gave many other speeches during his government service.
- Overview of FATCA. BBH Tax Symposium (March 7, 2011)
- Preparing the MNC for FATCA Compliance. International Fiscal Association (February 25, 2011)
- FATCA: Overview of Sec 1471 and 1472. Wall Street Tax Association (July 14, 2010)
- Dividend Equivalents: Equity Swaps; Securities Lending and Repos. International Institute of Bankers (June 21, 2010)
- FATCA: Overview of Sec 1471 and 1472. Executive Enterprise Institute (June 17, 2010)
- FATCA: Overview of Sections 1471 and 1472, EEI NRA Conference (June 17, 2010)
- The Regulatory Update – What Next?, Securities Finance Forum
(May 26, 2010)
- Understanding and Planning for FATCA, Academy Finance Conference (Luxembourg, Geneva and Zurich) (May 19-21, 2010)
- Hot Topics in U.S. Withholding Tax and Reporting Rules: The FATCA Provisions of the HIRE Act, American Bar Association (May 7, 2010)
- U.S. Withholding Tax Issues, Tax Executives Institute Carolinas Conference (April 27, 2010)
- FATCA: The New U.S. Withholding Tax System: Regulatory Challenges, Osney Media Withholding Tax on U.S. Sourced Income Conference (April 21, 2010)
- Key Features of FATCA, British Bankers Association (March 4, 2010)
- FATCA: The Dawn of a New U.S. Withholding Tax System, International Fiscal Association (February 25, 2010)
- Complying with FATCA: What the IRS’ New FATCA Requirements Mean to You Webinar, Executive Enterprise Institute (February 23, 2010)
- Ask the US Tax Experts, Joint Session of the India and USA Branches
of the International Fiscal Association (May 27-29, 2009).
- Current Inbound/Outbound International Taxation Issues, 21st
Annual Institute on Current Issues in International Taxation (GW Law
School) (December 9, 2008).
- Proposed Regulations Regarding 1441 Withholding on Redemptions,
Bank Depository User Group 2008 Annual Meeting (September 15, 2008)
- Key Note: What to Expect From The IRS, Tax Information Reporting & AP
Leadership Conference by Balance Consulting, (July 15, 2008)
- Self-Review of Tax Compliance, Tax Information Reporting & AP Leadership
Conference by Balance Consulting, (July 14, 2008)
- Total Return SWAPS/GAO Report On QIs, Seminar on Taxation of
International Banks by Institute of International Banks, (June 24, 2008)
- Special Withholding and Reporting Challenges--What You Need to Know
Beyond Portfolio Interest and Treaty Dividend Claims, 20th Annual
International Tax Withholding and Information Reporting Conference by
Executive Enterprise Institute, (June 20, 2008)
- Technical Issues for Hedge Funds in the Withholding and Reporting Rules,
Wall Street Tax Association US Withholding Tax Seminar, (September 19,
2007)
- Keynote: How to Survive the New IRS Withholding Tax Audit Environment:
Handling IRS Controversies and Potential Issues in Dispute, 4th Annual
Financial Industry Tax Reporting Conference by Balance Consulting (July
17, 2007)
- Post Audit--How Bad Can it Get, and How Can You Keep it From Getting
That Way, 19th Annual Forum on International Tax Withholding and
Information Reporting, (June 6, 2007)
- Current Developments – Outbound and Inbound: IRS Audit
Developments, The George Washington University/IRS 19th Annual
Institute on Current Issues in International Taxation (December
15, 2006)
- Withholding Related Hot Topics, Institute of International
Bankers (June 22, 2006)
- From Withholding Tax Carrot to Withholding Tax Stick,
Executive Enterprise Institute (June 2, 2006)
- Inbound Update, 18th Annual Institute of Current Issues in
International Taxation (December 9, 2005)
- Withholding and Non-Withholding Foreign Partnerships and
Trusts: Overview and Key Audit Issues, Qualified Intermediary
IRS Conference (June 2005)
- New Developments in Information Reporting and Withholding,
Seminar on U.S. Taxation of International Banks by the Institute
of International Bankers (June 23, 2005)
- Internal Controls, SARBOX 404 and Maintaining Tax Privilege,
International Tax Forum (June 9, 2005)
- Treatment of Special Income Types: The Good The Bad, The
Ugly, Executive Enterprise Institute (June 3, 2005)
- Selection of Recent U.S. Developments Related to Tax
Shelters and General Anti-Avoidance Efforts, International
Fiscal Association (April 28, 2005)
- Trends in Recent U.S. Income Tax Treaties, American Bar
Association (September 1, 2004)
- Withholding Foreign Partnerships and Trusts, 16th Annual
Forum on International Withholding Information and Reporting
(June 17, 2004)
- Cross Border Arbitrage: Assessing the Risk of Government
Attack, International Fiscal Association (May 2004)
- Current and Proposed Earnings Stripping Rules, Institute of
International Bankers (June 2003)
Publications, Public Comments & Press References
The following only lists items published during or after 2003, as
there are hundreds of other references prior to that period during
Mr. Staples’ government service.
- IRS Planning Comprehensive Approach To Withholding Tax
Compliance, Ng Says, 237 Daily Tax Report (BNA) G-14 (Dec. 10,
2008).
- IRS Plans Two More Sets of Guidance Tightening QI Program,
IRS Official Says, 209 Daily Tax Report (BNA) G-7 (Oct. 29,
2008).
- Co-Author, Small Carrots: Partial Postponement of the New
U.S. Services and Intangibles Regulations, 15 Transfer Pricing
Report (BNA) 668 (Jan. 3, 2007)
- Co-Author, New U.S. Regulations for Intercompany Service and
Intangibles: Are You Ready, Tax Planning International: Transfer Pricing
(BNA International) 3 (Dec. 2006)
- Co-author, Internal Controls for Withholding Agents on Income from REITs,
Tax Notes Today 108-35 (June 5, 2006)
- New IRS Guidance Allows More Flexibility For Simplified
Foreign Withholding Rules, 229 Daily Tax Report G-1 (November
30, 2005)
- Tax Treaties Treasury Not Concerned by Dutch Decree
Disregarding Hybrid Entities Treaty Provision, 136 Daily Tax
Report G-5 (July 18, 2005)
- Bulgarian Tax Treaty Negotiators To Address Range of Issues,
Worldwide Tax Daily 80-10 (April 27, 2005)
- Withholding Interest Not Imposed in Some Cases Under
Voluntary Compliance Program, 37 Daily Tax Report G-7 (February
25, 2005)
- U.S. IRS Looking to Expand Prefiling Agreement Program,
Worldwide Tax Daily 122-10 (June 23, 2004)
- LMSB Audits Pulling in Tax Shelters, U.S. IRS Official Says,
Worldwide Tax Daily 122-11 (June 23, 2004)
- Former IRS Official Staples Asks U.S. Treasury to 'Clarify'
U.K. Treaty, Worldwide Tax Daily 84-8 (April 29, 2004)
- Staples Recommends Changes to U.S. Foreign Partnership Withholding
Income, Reporting Rules, Worldwide Tax Daily 43-21 (March 4, 2004).
- Transfer Pricing Proposed Rules Not Intended to Emphasize
Residual Profit Split Method, Official Says, 39 Daily Tax Report
G-6 (March 1, 2004)
- Lead Tax Report Tax Shelters Bush Administration Withdraws
Notice 98-5, Vows to Pursue Foreign Tax Credit Abuses, 31 Daily
Tax Report GG-1 (February 18, 2004)
- Taxation, Pensions, Budget, And Accounting Outlook 2004
International Taxes, 09 Daily Tax Report S-14 (January 15, 2004)
- Author, The U.S. Treasury’s Proposed Section 482 Services
Regulations, BNA International’s Tax Planning International
Transfer Pricing (January 2004)
- Attorney Expands on Swiss Suggestion Regarding U.S. on
Foreign Withholding, Worldwide Tax Daily 243-30 (December 18,
2003)
- Swiss Banking Group Comments on Foreign Partnership
Withholding and Income Reporting Rules, Tax Notes Today 242-25
(December 17, 2003)
- Transfer Pricing: Practitioners Say New Proposed Method Poor
Substitute For Existing Cost Safe Harbor Tax, Budget &
Accounting, 174 Daily Tax Report G-7 (September 9, 2003)
- Interview Langdon, Staples Discuss Domestic, International
Challenges in Exit Interviews, 143 Daily Tax Report J-1 (July
25, 2003)
- Service Issues Final Agreements for Foreign Trusts and
Partnerships, 133 Daily Tax Report GG-1 (July 11, 2003)
- ABA Tax Section Meeting: Observers Wait to See How Earnings
Stripping Situation is Resolved, Worldwide Tax Daily 91-2 (May
9, 2003)
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