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 Incomeby Michael J. Miller, Ellen Seiler Brody, Mark David Rozen
Published: R&H Letter to Clients and Friends, July 24, 2017
A Sea Change in the Valuation Discount Rules: Proposed Regulations under the Special Valuation Rulesby Stuart J. Gross, Mark David Rozen, Quincy Cotton
Published: Estate & Gift Tax Planning Newsletter, August, 2016