James E. Salles is a Member in Caplin & Drysdale's Washington, D.C., office. He joined the firm in 1989 and has been a Member since 1995.
Mr. Salles' practice extends to both planning and controversy work. He has handled numerous large audits, appeals, and ruling requests for individual and corporate clients, many featuring complex issues involving the taxation of financial products, cross-border operations, foreign tax credits, DISCs, and similar matters. He also has extensive experience with procedural and computational issues that arise in settling complex tax disputes, including reviewing IRS transcripts and interest calculations. Mr. Salles also works on business taxation issues, income tax issues relating to the ownership and transfer of assets, structuring cross-border (inbound and outbound) investments for individuals and closely held businesses and related reporting requirements, and a variety of general tax issues that arise in the private client practice.
- Law360 Comments on Incoming Timing Rules Letter from Caplin & Drysdale Attorneys, Law360 Tax Authority, December 16, 2019
- Wall Street Journal Quotes James Salles and Richard Skillman on AT&T Corporate Tax Savings, The Wall Street Journal, December 21, 2017
- Law360 Quotes James Salles: Tax Bill's Legal Fee Provision May Burden Attorneys, Law360, November 16, 2017
- Caplin & Drysdale Recognized for Tax Credit Guide for Employers Who Hire Veterans, October 28, 2014
Click here for a full list of media coverage.
Mr. Salles has written for numerous publications, principally on topics relating to tax accounting (the rules governing the timing of items of income and deduction) and procedural issues. He is a member of the Advisory Board of Tax Management and co-author of the Tax Management portfolio entitled Tax Accounting - General Principles in 1990. For some years he wrote a monthly column on tax accounting issues for Corporate Business Taxation Monthly (Aspen Publishers).
Mr. Salles' publications also include:
- "The Adams Challenge Tax Court Decision Reinforces the Benefits of Foreign Taxpayers Filing Protective U.S. Returns,"
with J. Clark Armitage, Dianne C. Mehany, and H. David Rosenbloom, Caplin & Drysdale Client Alert, January 26, 2021
- "Partnership Filing Relief,"
with Mark D. Allison, Christopher S. Rizek, Charles M. Ruchelman, and Jonathan R. Black, Caplin & Drysdale Client Alert, April 13, 2020
- "CARES Act Offers Income Tax Relief for Business,"
with J. Clark Armitage, Jonathan S. Brenner, Kirsten Burmester, and H. David Rosenbloom, Caplin & Drysdale Client Alert, March 27, 2020
- "Tax Reform May Make Payment of Nonbusiness Tax Advice Fees Non-Deductible,"
with Beth Shapiro Kaufman and Amanda M. Leon, Caplin & Drysdale Client Alert, December 12, 2017
- "Paradise Papers: U.S. Citizens and Residents Required to Report on Offshore Assets,"
with Mark D. Allison, J. Clark Armitage, Peter A. Barnes, and Kirsten Burmester, Caplin & Drysdale Client Alert, November 6, 2017
- "IRS Launches Issue-Based Corporate Compliance Campaigns,"
with Mark D. Allison, J. Clark Armitage, and Rachel L. Partain, International Law Office, February 24, 2017
- "IRS Launches Issue Based Corporate Compliance Campaigns,"
with Mark D. Allison, J. Clark Armitage, Kirsten Burmester, and Niles A. Elber, Global Tax Weekly, February 16, 2017
- "IRS Launches 13 Issue-Based Corporate Compliance Campaigns,"
with Mark D. Allison, J. Clark Armitage, Kirsten Burmester, and Niles A. Elber, Caplin & Drysdale Client Alert, February 3, 2017
- "2013 Federal Tax Benefits for Hiring Qualified Veterans, National Guard Members and Reservists" (Book),
with Beth Shapiro Kaufman, Caplin & Drysdale, Chartered, June 3, 2013
- "Global Netting: Potential Opportunities for Corporate Taxpayers,"
with Charles M. Ruchelman, WTE Practical International Tax Strategies, Volume 17, Number 8, April 30, 2013
- "Global Netting: Potential Opportunities for Corporate Taxpayers,"
with Charles M. Ruchelman, Caplin & Drysdale Client Alert, April 10, 2013
- "Fiscal Cliff Averted: Tax Consequences for High-Net-Worth Individuals,"
with Beth Shapiro Kaufman and Kirsten Burmester, Caplin & Drysdale Client Alert, January 7, 2013
- "More Foreign Financial Account Reporting,"
with Richard W. Skillman and Scott D. Michel, Caplin & Drysdale Client Alert, March 26, 2010
- "Tax Accounting Monthly Column,"
Corporate Business Taxation Monthly, January 1, 2005
- "Tax Accounting Monthly Column,"
Corporate Business Taxation Monthly, December 1, 2004
- "Tax Accounting Monthly Column,"
Corporate Business Taxation Monthly, September 1, 2004
- "Tax Accounting Monthly Column,"
Corporate Business Taxation Monthly, August 1, 2004
- "Tax Accounting Monthly Column,"
Corporate Business Taxation Monthly, November 30, 2003
- ""Hot Interest" for Large Corporate Underpayments,"
Caplin & Drysdale, November 1, 2003
- "Tax Accounting Monthly Column,"
Corporate Business Taxation Monthly, October 1, 2003
- "Tax Accounting Monthly Column,"
Corporate Business Taxation Monthly, September 1, 2003
- "Tax Accounting Monthly Column,"
Corporate Business Taxation Monthly, August 1, 2003
- "Tax Accounting Monthly Column,"
Corporate Business Taxation Monthly, July 1, 2003
- "Tax Accounting Monthly Column,"
Corporate Business Taxation Monthly, May 1, 2003
- "Tax Accounting Monthly Column,"
Corporate Business Taxation Monthly, April 1, 2003
- "Tax Accounting Monthly Column,"
Corporate Business Taxation Monthly, March 1, 2003
- "Tax Accounting Monthly Column,"
Corporate Business Taxation Monthly, February 1, 2003
- "Tax Accounting Monthly Column,"
Corporate Business Taxation Monthly, December 1, 2002
- "Tax Accounting Monthly Column,"
Corporate Business Taxation Monthly, November 1, 2002
- "Tax Accounting Monthly Column,"
Corporate Business Taxation Monthly, October 1, 2002
- "Tax Accounting Monthly Column,"
Corporate Business Taxation Monthly, September 1, 2002
- "Tax Accounting Monthly Column,"
Corporate Business Taxation Monthly, August 1, 2002
- "Tax Accounting Monthly Column,"
Corporate Business Taxation Monthly, July 1, 2002
- "Of Merchandise, Accruals, And Administrative Grace,"
Tax Notes, June 17, 2002
- "Tax Accounting Monthly Column,"
Corporate Business Taxation Monthly, June 1, 2002
- "Tax Accounting Monthly Column,"
Corporate Business Taxation Monthly, May 1, 2002
- "Tax Accounting Monthly Column,"
Corporate Business Taxation Monthly, April 1, 2002
- "Tax Accounting Monthly Column,"
Corporate Business Taxation Monthly, March 1, 2002
- "Tax Accounting Monthly Column,"
Corporate Business Taxation Monthly, February 1, 2002
- "Tax Accounting Monthly Column,"
Corporate Business Taxation Monthly, January 1, 2002
- "Tax Accounting Monthly Column,"
Corporate Business Taxation Monthly, December 1, 2001
- "Tax Accounting Monthly Column,"
Corporate Business Taxation Monthly, November 1, 2001
- "Tax Accounting Montly Column,"
Corporate Business Taxation Monthly, October 1, 2001
- "Tax Accounting Monthly Column,"
Corporate Business Taxation Monthly, September 1, 2001
- "Tax Accounting Monthly Column,"
Corporate Business Taxation Monthly, August 1, 2001
- "Tax Accounting Monthly Column,"
Corporate Business Taxation Monthly, July 1, 2001
- "Tax Accounting Monthly Column,"
Corporate Business Taxation Monthly, June 1, 2001
- "Tax Accounting Monthly Column,"
Corporate Business Taxation Monthly, May 1, 2001
- "Tax Accounting Monthly Column,"
Corporate Business Taxation Monthly, April 1, 2001
- "Tax Accounting Monthly Column,"
Corporate Business Taxation Monthly, March 1, 2001
- "Tax Accounting Monthly Column,"
Corporate Business Taxation Monthly, February 1, 2001
- "Tax Accounting Monthly Column,"
Corporate Business Taxation Monthly, January 1, 2001
- "Tax Accounting Monthly Column,"
Corporate Business Taxation Monthly, December 1, 2000
- "Tax Accounting Monthly Column,"
Corporate Business Taxation Monthly, November 1, 2000
- "Tax Accounting Monthly Column,"
Corporate Business Taxation Monthly, October 1, 2000
- "Tax Accounting Monthly Column,"
Corporate Business Taxation Monthly, September 1, 2000
- "Tax Accounting Monthly Column,"
Corporate Business Taxation Monthly, August 1, 2000
- "Tax Accounting Monthly Column,"
Corporate Business Taxation Monthly, July 1, 2000
- "Tax Accounting Monthly Column,"
Corporate Business Taxation Monthly, June 1, 2000
- "Tax Accounting Monthly Column,"
Corporate Business Taxation Monthly, May 1, 2000
- "Tax Accounting Monthly Column,"
Corporate Business Taxation Monthly, April 1, 2000
- "Tax Accounting Monthly Column,"
Corporate Business Taxation Monthly, March 1, 2000
- "Tax Accounting Monthly Column,"
Corporate Business Taxation Monthly, February 1, 2000
- "Tax Accounting Monthly Column,"
Corporate Business Taxation Monthly, January 1, 2000
- "Tax Accounting Monthly Column: Bank's Loan Origination Costs Emerge As a High-Profile Issue,"
Corporate Business Taxation Monthly, December 1, 1999
- "Tax Accounting Monthly Column: Clear Reflection Principles May Work For Taxpayers Too,"
Corporate Business Taxation Monthly, November 1, 1999
- "Tax Accounting Monthly Column: IRS Wins Before the Tax Court in Norwest,"
Corporate Business Taxation Monthly, October 1, 1999
- "The "Ins" "Outs" "Overs" and "Unders" of the New Global Netting Rules,"
Tax Notes, April 26, 1999
- "Navigating the Global Netting Rules: Uncertainties Abound in Interest Rate Calculation Process Under New Law,"
Practical U.S. /International Tax Strategies, December 10, 1998
Click here for a full list of publications.
