Martin B. Tittle - Attorney Profile
I am a tax lawyer with a practice centered on international aspects of U.S. tax. I graduated magna cum laude from the University of Michigan in 2001, and I currently practice in Washington, D.C. and Ann Arbor, Michigan.
Usually, the projects in which I am involved concern the application of U.S. tax treaties, U.S. taxation of international insurance activities (including state taxation issues), or legislative tracking. Outside those subject areas, projects usually fall into two broad classes: transactional analysis and pure research.
Transactional analysis always involves a proposed or pending transaction, and frequently what I am asked to provide is a "counterpoint" memorandum. A counterpoint memorandum is an analysis that makes the best arguments against the legality of the transaction or the conformity of the transaction with those statutes and rules that appear applicable to it. If a less comprehensive review is requested, what I look for are aspects of the transaction that are either not anticipated or not adequately disclosed in the documents or description I receive. Examples of unanticipated aspects include the danger of conduit characterization in the establishment of a foreign finance corporation if the finco's parent has external debt, and the existence of treaty-related anti-abuse provisions that are not included or referenced in the tax treaty they affect.
Pure research is usually associated with the development of a legislative position. Examples range from developing the concept of foreign tax credit for value-added taxes to researching possible definitions for a word that is not defined in a statute (e.g., the word "purchased" in I.R.C. Sec. 956(c)(2)(B)). The results of pure research can be presented in various ways, including a memorandum report, a scholarly article, a position paper, a speech, prepared testimony, or an op-ed.
My web site contains links to my published articles.
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Undergraduate:
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University of Michigan School of Music
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Law School:
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University of Michigan
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Admitted to Bar:
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Practice Areas:
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Business > Tax-Business
Business > International Law
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Personal
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Gender:
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Male
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In a Relationship
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Children:
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2 Children
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About Me:
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Account
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Member Since:
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09-07-2007
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Last Update:
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09-07-2007
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