Robert H. Green joined Caplin & Drysdale’s Washington, D.C. office as a member in 2006.
Mr. Green’s experience extends across a broad range of international and corporate tax issues. Prior to joining Caplin & Drysdale, he was the Director, International for the Internal Revenue Service. In that capacity, he served as the U.S. Competent Authority with responsibility for managing negotiations and achieving resolution on tax controversies with treaty partners of the U.S. regarding specific cases involving transfer pricing, permanent establishment, withholding, and treaty interpretation matters. Mr. Green was also involved in the development of U.S. transfer pricing guidelines for international examiners to audit cost-sharing transactions and the development of settlement guidelines to resolve a substantial number of large cases involving cost sharing. In addition, Mr. Green was jointly responsible with the APA Director for initiating the first bilateral APA with China. He also completed MOUs with Canada and Mexico to enhance the resolution of bilateral tax cases with those countries.
Mr. Green's practice involves providing counsel to clients in managing and resolving tax disputes arising from global, regional, and bilateral business transactions, including:
- Restructuring cross-border business operations to minimize tax controversies relating to transfer pricing, permanent establishment, income characterization, withholding, and treaty interpretation issues;
- Structuring the offshore migration of intangibles in a tax effective manner, including cost sharing arrangements;
- Providing counsel to clients in pursuing APAs, competent authority agreements, and other dispute resolution tools to reach agreement on domestic and international tax controversies;
- Assisting clients in managing global tax risks for financial reporting purposes.
- Working with US and foreign tax authorities to resolve cross-border tax disputes;
- Managing tax controversies with the IRS arising from cost sharing arrangements and other transfers of intangibles to foreign locations.
Mr. Green’s professional background includes corporate tax experience with Procter & Gamble as Director of International Tax in the corporate headquarters and then as Director of Taxes, Europe in P&G’s operations in Germany, where he was involved in the design and implementation of a global restructuring project. Previously, he served as Vice President of Tax Policy for the National Foreign Trade Council, which represents U.S. multinational companies on international tax matters. Mr. Green also worked as Tax Counsel to a Member of the House Ways and Means Committee of the U.S. Congress.
Mr. Green is a frequent speaker on transfer pricing and related issues arising in global tax controversies. He has chaired panel discussions on these subjects at the IFA Congress (Kyoto) and an ABA Tax Section Meeting. Mr. Green is the co-founder of the International Taxation Summit held annually in Shanghai, China. Now in its third year, this summit has become “the most vital corporate taxation forum for China and the greater Asian marketplace.”