- Advising clients on federal tax issues related to the effect of the coronavirus pandemic on supply chains, including deductibility of expenses, shut-down issues, net operating losses, and the impact on advance pricing agreements (APAs).
- Obtained numerous unilateral and bilateral APAs involving the IRS and other tax authorities.
- Resolved novel transfer-pricing issues such as using foreign parent company segment data as the tested party for an APA, intangible property migration, foreign currency fluctuations, financing transactions and guaranties, tax credits in intercompany transactions, plant startup and shutdown situations, joint ventures, U.S. domestic transfer pricing, and customs implications.
- Secured favorable competent authority agreements to eliminate double taxation in controversies involving, for example, the U.S., Australia, Canada, China, France, Germany, Japan, Mexico, Switzerland, and UK.
- Obtained successful IRS determination letters relating to limitation on benefits article in U.S. tax treaties.
- Sustaining deductibility of Sec. 174 research expenses in a post-Tax Cuts and Jobs Act amortization environment.
- Advising numerous multinational companies in the motor vehicle, aerospace, telecommunications, hospitality, finance, and other industries on tax-efficient supply chain restructurings, including cash pooling systems, involving Europe, Asia, and the Americas.
- Developing intangible property migration strategies and compliance for multinational companies.
- Advising pharmaceutical companies on strategies to address transfer-pricing risks and reduce taxable permanent establishment concerns.
- Advising multinational companies on the tax and customs implications of cross-border transactions.
- Counseled a tax-exempt organization on tax issues associated with transactions involving taxable affiliates.
Partner,
- Phone: +1 202 239 3231
- Email: richard.slowinski@alston.com
Richard’s multinational clients benefit from his extensive experience with tax planning and controversy and trust his guidance to resolve challenging transfer-pricing issues as well as to develop, implement, and defend tax-efficient cross-border structures.
Richard Slowinski is a partner in the Federal & International Tax Group. For more than 25 years, he has advised clients on tax matters, with a focus on transfer pricing. Richard’s international clients span multiple industries, including transportation, finance, hospitality, electronics, food and beverage, aerospace, pharmaceuticals, and retail. His clients trust him to secure IRS and foreign tax authority approval on transfer-pricing methodologies and cross-border structures carefully tailored to their businesses.
Richard has been selected as a “Recommended Lawyer” and “Leading Lawyer” by International Tax Review. He is also recognized by The Best Lawyers in America® in Tax Law and Litigation and Controversy Tax and by Euromoney’s Expert Guide for Transfer Pricing.
Languages
- French
Bar Admissions
- District of Columbia
- Maryland
Education
- Georgetown University (LL.M., 1993)
- The Catholic University of America (J.D., 1991)
- Bucknell University (B.A., 1987)
Memberships
- Maryland State Bar Association
- Bar Association of the District of Columbia
- Catholic University of America, Columbus School of Law, board of visitors
- Bucknell University, Parents Association, board of directors