LinkedInSamuel J. Lee, J.D., LL.M.

Samuel J. Lee, J.D., LL.M.

Associate Tax Counsel at GoldenTree Asset Management LP

Location
New York, New York
Industry
Financial Services
Previous
  1. PwC
Education
  1. Boston University School of Law
500+connections

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500+connections
Boston University School of Law

Boston University School of Law

Taxation

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Background

Summary

Specialties: International and domestic tax planning and structuring for corporations, private equity funds, and hedge funds

Skills

  • International Tax
  • Corporate Tax
  • Restructuring
  • Due Diligence
  • Mergers & Acquisitions
  • Private Equity Funds
  • Hedge Funds
  • Tax Models
  • Tax Opinions
  • Tax Research
  • Tax Advisory
  • Cross-border...
  • Financial Structuring
  • Accounting
  • Private Equity
  • Corporate Finance
  • See 1+  See less

Certifications

Licensed Attorney

New York, New Jersey

Experience

Associate Tax Counsel

GoldenTree Asset Management LP
– Present (1 year 2 months)greater new york city area

Assist with tax planning/structuring, reviewing debt modifications, investments, workouts, and restructurings involving various global funds and accounts. Monitor and research issues relating to withholding tax, tax treaties, foreign tax mitigation, effectively connected income, FIRPTA, PFIC, CFC, market discount, OID, partnership, and corporation tax considerations.

Senior Associate, International M&A Tax

PwC
(1 year 2 months)greater new york city area

Associate, International Tax

PwC
(2 years 2 months)greater new york city area

Publications

A Recommendation, in Light of the Current Economy, for Revising the Way § 304 Applies to International Transactions

38 Tax Management International Journal 500
August 2009

The article provides a comprehensive analysis of the mechanics of the rules under section 304 governing redemptions through the use of related corporations within the domestic and international context. The article acknowledges the validity of the anti-abuse provisions within the domestic context, but argues for a relaxation of such provisions within the international context. In particular, the article appeals to other IRC sections (e.g., 108 regarding tax attribute reduction, 884 regarding branch profits tax, 965 regarding dividends received deduction) as models that could assist in revising the way section 304 applies within the international context.

Education

Boston University School of Law

Master of Laws (LL.M.), Taxation

Westminster Theological Seminary

Master of Arts (M.A.), Religion

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