Christopher J. FeldmanPartner
Chris Feldman focuses his practice on providing technical and practical solutions to challenging cross-border international tax issues. Whether in the context of international tax planning, transfer pricing, cross-border mergers and acquisitions, international fund formation and investments, and legal implementation and integration projects, Chris has consistently applied business-oriented and multi-disciplinary strategies to provide holistic approaches to a complex area of law.
Chris counsels a wide variety of clients, ranging from industry start-ups initially expanding their operations abroad to large U.S. multinationals focused on acquisitions, restructurings and/or overall tax-efficiency initiatives. In addition, Chris is experienced with international tax aspects of fund formation and strategic investments.
Chris' cross-border experience coupled with DLA's vast global capabilities provide his clients opportunities to optimize their legal spend, with the assurances that as his client grows, Chris' practice is there to meet its immediate needs.
Chris is a staunch advocate for diversity and inclusivity initiatives. He serves as the DLA Seattle office's Diversity, Equity and Inclusion Chair. In this capacity, he shares the firm's commitment to diverse representation and topical programming.
- Implementing a complex temporary onshoring of a large U.S. multinational's intellectual property into the U.S., including assessing tax implications in multiple jurisdictions and ensuring minimal operational changes.
- Assisting a U.S. multinational with a global legal entity rationalization. The U.S. multinational had grown organically through mergers and acquisitions, resulting in duplicative and redundant operations and entities in various jurisdictions. This restructuring involved a cross-section of legal, employment and tax issues in the local jurisdictions, requiring a comprehensive plan to leverage various tax-efficient mechanisms and regimes.
- Assisting a U.S. multinational with the integration of a multi-billion dollar global acquisition. This included designing and defending complex worldwide IP and operational integration initiatives, including C-Suite and audit committee discussions and auditor review.
- Representing a client in front of the U.S. and Ireland tax authorities related to mutual agreement procedures under the U.S.-Ireland Income Tax Treaty, to mitigate double taxation stemming from a dual-registered subsidiary.
- Representing a U.S. multinational in front of the German tax authorities related to withholding taxes due on intercompany license transactions involving novel issues of jurisdictional nexus.
- Assisting an international shipping company with its U.S. and international operating footprint and tax structure, including assessing the availability of beneficial worldwide tax regimes available for international shipping companies operating worldwide.
- Assisting global investors with the tax structuring of a U.S.-based private equity investment into a Mexican fintech company, including shareholder-level on-going and divestment tax considerations, as well as worldwide tax-efficient operational structuring for the Fintech company.
- LL.M., Taxation, New York University
- J.D., University of San Diego School of Law
- B.S., Finance and Accounting, Tulane University
Chris is a frequent speaker on international tax matters.
- Author, "GOING GLOBAL: EMPLOYMENT AND TAX CONSIDERATIONS," (2013)
- Co-author, "Tax Considerations Related to Cross-Border Franchise Transactions, in FUNDAMENTALS OF INTERNATIONAL FRANCHISING 59," (Will K. Woods ed., 2013)
- "Convergence of Technical and Practical," Effective International Tax Planning & Structuring Conference, held by the Tax Executive Institute (TEI) (January 2012)
Before attending law school, Christopher was an accountant for one of the major accounting firms.
Chris is a licensed Certified Public Accountant.
Memberships And Affiliations
- Co-Regional Vice President, Pacific Northwest Chapter of International Fiscal Association (IFA) USA Branch
My latest insights
US GILTI and Pillar 2: a closer look at the Administrative Guidance
23 February 2023 .8 minute read