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Jonathan Jackel Tax Reporting and Withholding, International Tax, Audit
and Appellate Controversy, Litigation
Washington, DC
Tel – +1 (202) 783-1500
Fax – +1 (202) 783-1523
jjackel@bsmlegal.com
Jonathan Jackel brings a wide range of experience to his
practice. Mr. Jackel has been an advocate for both the
government and private clients, and has both litigated
tax cases and engaged in sophisticated planning work,
including international financial structures. He has
also covered the House of Representatives for Tax Notes
Magazine and financial markets for other news
publications.
Mr. Jackel’s practice includes a
full range of tax withholding and information reporting
issues. He has provided extensive advice on the
implementation of cost basis reporting issues, including
such topics as wash sales, short sales, and securities
lending. Mr. Jackel also advises both domestic and
foreign clients with respect to the Foreign Account Tax
Compliance Act (“FATCA”), and he has been a major
contributor to the development of FATCA compliance
tools.
Mr. Jackel advises domestic and non-U.S.
financial institutions on their U.S. tax reporting and
withholding obligations, guides clients through IRS
audits on these issues, and persuades the IRS to issue
favorable rulings and regulations in this area. Mr.
Jackel represents clients in tax controversies at both
the federal and state levels, where his cases have
involved tax credit, inventory, bankruptcy, procedural
and international issues. Mr. Jackel has also negotiated
offers in compromise with the IRS.
After
graduating from Georgetown University Law Center, Mr.
Jackel began his career as a law clerk to the Honorable
Renato Beghe of the U.S. Tax Court. He followed that
with four years at the U.S. Department of Justice as an
“honors program” trial attorney in the Tax Division,
where he was named Outstanding Attorney in 1995. He
joined the firm in 1996.
Education & Credentials
BS – Boston University (1986) (Magna Cum Laude)
JD – Georgetown University Law Center (1991) (Cum Laude)
Bar Admissions
Maryland
District of Columbia
Publications and Speeches
- Foreign Account Tax Compliance Act (FATCA) Provisions and Compliance With Report of Foreign Bank And Financial Accounts (FBAR) Requirements, Institute of Institutional Bankers (June 21, 2010).
- Against the clock: US regulation could land a big tax bill on foreign firms, The Markit Magazine (Summer 2010).
- "Applying the Presumption Rules", 20th Annual Tax Reporting & Withholding Seminar (April 24, 2007)
- Song and Dance Continues Over Capital Gains Cut, 44 Tax
Notes 621
- Japanese Retirement Policy Trends May Help U.S.
Policymakers, 44 Tax Notes 610
- Section 936 in Jeopardy, 44 Tax Notes 487
- Section 89 Coalition Says Combining House and Senate
Proposals Would Be Best Medicine for Reform, 44 Tax
Notes 845
- Underground Economy No Cash Cow, 44 Tax Notes 633
- Repeal of Catastrophic Care Act Not Likely, 44 Tax Notes
464
- Rich Folks Cheat More on Taxes, New Study Charges, 44
Tax Notes 495
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