Mark David Rozen

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.

• Harvard Law School, J.D., cum laude
• Brooklyn College, summa cum laude

• New York