Since 1981, Mark David Rozen has provided tax planning to public and privately held companies and wealthy U.S. and foreign family groups. A large part of his practice involves structuring cross-border investments and operations from both an income and estate tax planning perspective and designing ownership vehicles for families with members and assets in diverse jurisdictions. He works extensively with trusts and private charitable foundations to maximize the tax advantages of creating such entities, as well as designing structures that best suit a family's philanthropic objectives.

In addition, he works with a variety of European and Middle Eastern companies -- from foreign funds investing in U.S. real property, to manufacturers of high tech products, software developers, commodities traders and motion picture producers -- to develop structures designed to take advantage of the income tax treaty network and to minimize U.S. and foreign taxes on both corporate activities and investors. He has arranged transactions to take advantage of the U.S. portfolio interest exemption, and has restructured existing operations to deal with issues involving permanent establishment, transfer pricing, intellectual property, earnings stripping, and branch profits and withholding taxes.

He also advises U.S. public and privately held clients on their international operations, from structuring their cross-border activities in manufacturing, sales and financing to minimizing the impact of Subpart F, Section 367, Section 1248, and the PFIC rules.

He is a member of The Society of Trust and Estate Practitioners and the International Fiscal Association.

He graduated summa cum laude from Brooklyn College and received his J.D. cum laude from Harvard.

Tax Court Rejects Revenue Ruling 91-32 -- Holds Greek Corporation's Gain from the Redemption of Its Partnership Interest Not To Be Taxable as Effectively Connected Income

by Michael J. Miller, Ellen Seiler Brody, Mark David Rozen
Published: R&H Letter to Clients and Friends, July 24, 2017
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A Sea Change in the Valuation Discount Rules: Proposed Regulations under the Special Valuation Rules

by Stuart J. Gross, Mark David Rozen, Quincy Cotton
Published: Estate & Gift Tax Planning Newsletter, August, 2016
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Fractional Interests in Art and Other Valuation Challenges

by Quincy Cotton, Stuart J. Gross, Mark David Rozen
Published: Estate & Gift Tax Planning Newsletter, November, 2014
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New York State Estate and Gift Tax -- April 2014 Update

by Quincy Cotton, Stuart J. Gross, Mark David Rozen
Published: Estate & Gift Tax Planning Newsletter, April 28, 2014
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Estate and Gift Planning in 2014 and Beyond

by Quincy Cotton, Stuart J. Gross, Mark David Rozen
Published: Estate & Gift Tax Planning Newsletter, February 27, 2014
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IRS Provides Detailed Guidance on 2012 Offshore Voluntary Disclosure Program and Announces New Alternative Procedure for Certain Taxpayers Living Abroad

by Michael J. Miller, Richard A. Levine, Howard J. Levine, Mark David Rozen, Ellen Seiler Brody
Published: R&H Letter to Clients and Friends, July 3, 2012
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New Proposed Regulations Provide Some Welcome Relief for Foreign Financial Institutions under FATCA

by Mark David Rozen, Ellen Seiler Brody, Libin S. Zhang
Published: BNA Tax Planning International Review, March 01, 2012
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IRS Modifies 2011 Offshore Voluntary Disclosure Initiative to Reduce Penalties for Certain Participants and Permit Extensions

by Michael J. Miller, Howard J. Levine, Richard A. Levine, Mark David Rozen
Published: R&H Letter to Clients and Friends, June 22, 2011
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IRS Further Extends Deadline for 2009 and Prior FBARs Required to be Filed by U.S. Persons With Signature Authority but No Financial Interest in Foreign Accounts

by Michael J. Miller, Richard A. Levine, Howard J. Levine, Mark David Rozen
Published: R&H Letter to Clients and Friends, June 21, 2011
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Highlights of the New FBAR Regulations and Revised FBAR for 2010 Filings Due June 30, 2011

by Michael J. Miller, Richard A. Levine, Howard J. Levine, Mark David Rozen
Published: R&H Letter to Clients and Friends, April 06, 2011
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Certain Taxpayers May Avoid Penalties If They File Delinquent Information Returns Relating to Foreign Accounts, Foreign Entities, and Foreign Gifts

by Michael J. Miller, Howard J. Levine, Richard A. Levine, Mark David Rozen
Published: R&H Letter to Clients and Friends, March 02, 2011
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Estate and Gift Tax Planning in the Whole New World of 2011-2012

by Quincy Cotton, Stuart J. Gross, Mark David Rozen
Published: Estate & Gift Tax Planning Newsletter, March 01, 2011
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IRS Announces 2011 Offshore Voluntary Disclosure Initiative With August 31, 2011 Deadline

by Michael J. Miller, Howard J. Levine, Richard A. Levine, Mark David Rozen
Published: R&H Letter to Clients & Friends, February 09, 2011
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IRS Issues Relief from FBAR Filing Obligations for Three Groups

by Michael J. Miller, Howard J. Levine, Richard A. Levine, Mark David Rozen
Published: R&H Letter to Clients & Friends, March 03, 2010
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IRS Extends Deadline For Voluntary Disclosure Program

by Michael J. Miller, Richard A. Levine, Howard J. Levine, Mark David Rozen
Published: R&H Letter to Clients and Friends, September 24, 2009
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Taxpayers Still Have Time to Resolve Offshore Tax Issues Through the Voluntary Disclosure Program

by Michael J. Miller, Richard A. Levine, Howard J. Levine, Mark David Rozen
Published: R&H Letter to Clients and Friends, July 22, 2009
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Proposed Legislation Affecting Assets Held Overseas

by Mark David Rozen, Ellen Seiler Brody
Published: Rothschild Trust Review, April 01, 2009
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Carpe Diem! Estate Planning Opportunities in Uncertain Times

by Quincy Cotton, Stuart J. Gross, Mark David Rozen
Published: R&H Estate and Gift Tax Planning Newsletter, December 15, 2008
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American Jobs Creation Act of 2004 International Tax Provisions

by Mark David Rozen, Joseph Lipari, Michael J. Miller
Published: R & H Letter to Clients and Friends, November 11, 2004
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Proposed Amendment to FIRPTA Could Make U.S. REITs More Attractive to Canadian Real Estate Investors

by Mark David Rozen, Abraham Leitner
Published: The Canadian Tax Journal, March 01, 2004
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September 15th Due Date for Waiver of Filing Deadline for Foreign Taxpayers

by Mark David Rozen, Michael J. Miller
Published: R&H Letter to Clients and Friends, August 14, 2003
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Now You See It, Now You Don't: The 2001 Estate Tax Legislation

by Quincy Cotton, Stuart J. Gross, Mark David Rozen
Published: Journal of Taxation of Investments, November 15, 2001

Estate Tax Legislation

by Stuart J. Gross, Quincy Cotton, Mark David Rozen
Published: R & H Letter to Clients and Friends, June 07, 2001