Michael C Durney
Tax - Civil and Criminal Tax Compliance
Moore & Bruce, LLP advises and represents clients in all phases of U.S. civil and criminal tax compliance, both at the administrative and judicial levels. This part of its practice is post-transactional, beginning with an analysis of completed events, advice as to proper income tax reporting and representation in response to examinations or investigations by the Internal Revenue Service or the Department of Justice. We also advise as to whether tax returns should be filed or amended, both for U.S. and non-U.S. clients.
The Firm’s practice includes providing counsel to clients with respect to money laundering, bank secrecy and other “white-collar†compliance issues.
Moore & Bruce, LLP’s representation before the Internal Revenue Service includes the Examination, Collection and Criminal Investigation Divisions, the Office of Appeals, as well as the Office of the Inspector General of the Treasury Department. Representation before the Department of Justice includes the Tax and Criminal Divisions and the offices of the U.S. Attorneys throughout the country.
The Firm's tax compliance practice in U.S. courts includes the United States Tax Court, the District Courts, the Court of Federal Claims, the Federal Courts of Appeal, and the United States Supreme Court.
Our litigation practice includes serving as sole or lead counsel, or in providing outside expert litigation counsel to in-house counsel or outside general counsel.
We attorneys also serve as expert witnesses, mediators and arbitrators in tax compliance matters. We often render "second opinions".
Tax - Domestic U.S. and International
Moore & Bruce, LLP is highly regarded for its domestic and international tax expertise. With respect to international tax issues, it advises on all aspects. These include, for example, corporate taxation, individual taxation, the rules applicable to trusts and beneficiaries, gift and estate taxes, and withholding taxes.
The Firm advises as to many types of so-called “in-coming†transactions. These include investments in and acquisitions of U.S. property.
For example, we advised a non-U.S. group with respect to a series of U.S. real estate investments and later the disposition of those investments.
The Firm advises U.S. taxpayers on business and personal investments abroad.
We advised U.S. companies on the development of properties, including a spa, in the Middle East.
A common engagement involves clients from several jurisdictions, with transactions that touch down in two or more jurisdictions.
We recently advised European clients with respect to acquisitions and privatizations in southeast Europe. On another occasion we advised Bermudan and U.K. principals as to the start-up of a business in Mexico.
Areas of special concentration have been the taxation of export transactions and foreign subsidiaries of U.S. groups. The latter entails the controlled foreign corporation rules found in Subpart F of the Internal Revenue Code.
The Firm often advises U.S.-based or foreign-based multinational enterprises on the structuring of international business transactions.
We engage in tax planning for clients. This work often calls for a significant degree of creativity.
The Firm sometimes obtains Internal Revenue Service rulings for clients. More frequently, clients and their investors and lenders rely upon our opinions.
In addition, we deal with compliance and tax litigation. We help clients "catch up" with their filings of tax returns and foreign bank account reports.
Our attorneys monitor tax developments in the U.S., the United Kingdom, Canada, major European countries, Singapore, and significant low-tax jurisdictions, such as, Bermuda and Barbados, on a daily basis.
Michael C Durney
Moore & Bruce, LLP
1072 Thomas Jefferson St NW
Washington DC 20007
Tel: 202 965-7744
Fax: 202 965-7745
E-mail: mdurney@mooreandbruce.com
Practice Areas: Civil and criminal tax compliance; general civil litigation in Federal, State and local courts.
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