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Alan I. Appel

Senior Tax Consultant

, Bryan Cave LLP
New York

Tel

1 212 541 2292

Fax

1 212 261 9865
aiappel@bryancave.com
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Alan I. Appel

Senior Tax Consultant


New York



1290 Avenue of the Americas
New York, New York 10104-3300

Phone:

1 212 541 2292

Fax:

1 212 261 9865

email:

aiappel@bryancave.com

Alan Appel is a professor of law and the director of the International Tax Program at New York Law School. He teaches courses in international tax planning and corporate taxation in addition to the tax transactions clinic. Professor Appel first started teaching at New York Law School in 2009 as an adjunct professor. As a senior tax consultant at Bryan Cave, he specializes in international and domestic tax planning involving taxation of mergers and acquisitions, partnerships, joint ventures, limited liability companies and tax controversy matters.

Professor Appel began his career as a trial attorney in the Office of Chief Counsel, Internal Revenue Service in Washington, D.C., and New York City. On behalf of the American Bar Association Tax Section, he had primary responsibility for drafting and submitting comments to the U.S. Treasury Department and IRS concerning the scope of the guidance provided by the proposed regulations under Section 1446 of the Internal Revenue Code and also was asked by the Office of the Chief Counsel to train its attorneys on this issue. He also published two articles on the Section 1446 regulations in the Journal of International Taxation, a third article in the Tax Management Memorandum and a fourth article in the Tax Management International Journal.

Professor Appel has appeared on both radio and television discussing various income tax issues. He was also recently featured in "Taxpayers Strained by New FATCA Requirements" in AccountingToday.com, a leading provider of online business news for the tax and accounting community, concerning the Foreign Account Tax Compliance Act.

Professor Appel received his J.D. from New York Law School in 1976 and his LL.M. from New York University in 1980. He received his B.B.A. from Baruch College in 1973.

Professional Affiliations

  • American Bar Association Section of Taxation – Council Director, Foreign Activities of U.S. Taxpayers; Foreign Lawyers Forum; Transfer Pricing; and U.S. Activities of Foreigners and Tax Treaties
  • Journal of International Taxation – Board of Advisors
  • Journal of Taxation and Regulation of Financial Institutions – Board of Advisors
  • American Bar Association Section of Taxation – Chair, U.S. Activities of Foreigners and Tax Treaties   Committee
  • New York State Bar Association – Section of Taxation
  • The Association of the Bar of the City of New York
  • The Florida Bar – Section of Taxation
  • The District of Columbia Bar – Section of Taxation

Civic Involvement and Honors

  • Sutton Place Synagogue/The Jewish Center for the United Nations - Board of Trustees and Patron

Alan Appel is a professor of law and the director of the International Tax Program at New York Law School. He teaches courses in international tax planning and corporate taxation in addition to the tax transactions clinic. Professor Appel first started teaching at New York Law School in 2009 as an adjunct professor. As a senior tax consultant at Bryan Cave, he specializes in international and domestic tax planning involving taxation of mergers and acquisitions, partnerships, joint ventures, limited liability companies and tax controversy matters.

Professor Appel began his career as a trial attorney in the Office of Chief Counsel, Internal Revenue Service in Washington, D.C., and New York City. On behalf of the American Bar Association Tax Section, he had primary responsibility for drafting and submitting comments to the U.S. Treasury Department and IRS concerning the scope of the guidance provided by the proposed regulations under Section 1446 of the Internal Revenue Code and also was asked by the Office of the Chief Counsel to train its attorneys on this issue. He also published two articles on the Section 1446 regulations in the Journal of International Taxation, a third article in the Tax Management Memorandum and a fourth article in the Tax Management International Journal.

Professor Appel has appeared on both radio and television discussing various income tax issues. He was also recently featured in "Taxpayers Strained by New FATCA Requirements" in AccountingToday.com, a leading provider of online business news for the tax and accounting community, concerning the Foreign Account Tax Compliance Act.

Professor Appel received his J.D. from New York Law School in 1976 and his LL.M. from New York University in 1980. He received his B.B.A. from Baruch College in 1973.

Bar and Court Admissions

New York, 1977

District of Columbia, 1979

Florida, 1976

United States Supreme Court

United States Court of Federal Claims

United States District Courts for the Eastern and Southern Districts of New York

United States Tax Court

Education

New York University, LL.M, 1980

New York Law School, J.D., 1976

Baruch College, B.B.A., 1973

Publications

  • "Preventing End Runs Around the Dividend Withholding Regime: Treasury’s Revised Regulations Under Section 871(m) and the New Delta Test," co-authored with Gregory Galvin, Journal of Taxation and Regulation of Financial Institutions, Vol 27 No 4, April 2014
  • Bloomberg BNA 53 Tax Management Memorandum 43. “Tax Structuring of Foreign Investment in U.S. Real Estate with a N.Y. Twist” by Alan I. Appel, Esq. and Jack Mandel, Esq. January 30, 2012.
  • 70th NYU Tax Institute, Tax Structuring of “Foreign Investment in U.S. Real Estate with a N.Y. Twist.” By Alan I. Appel, John P. Barrie, Michael Hirschfeld and Michael J.A. Karlin. 2012.
  • Journal of Taxation of Financial Institutions 25J’Tax’N F Inst. 5 “Structuring Investments by Foreign Persons in U.S. Real Estate.” 2012.
  • 68th NYU Tax Institute, Chapter 3, “2009 – A year of Increased Focus on International Tax Reporting.” 2010.
  • BNA Tax Management International Journal. February 13, 2009. “Living with the Final Partnership withholding Regulations.” 2009.
  • BNA 47 Tax Management Memorandum 9. May 1, 2006. “Kissing the Blarney Stone: A practical guide to structuring Partnership Agreements and Limited Liability Company Operating Agreements in light of the Section 1446 Regulation.”
  • Journal of International Taxation, “At Long Last …Final Regulation on Foreign Partners Withholding (Prt1) “Uncle Sam meets Uncle Scrooge The temporary Regulations on Foreign Partners Withholding (Prt2). 2005.
  • Journal of Taxation of Financial Instruments, 17 J Tax’n F Inst 63. “Section 1446 Regulation proposed for withholding on effectively connected income allocable to Foreign Partners” 2004.
  • Journal of Taxation of Financial Instruments, 14 J Tax’n F Inst 51. “Due Diligence in International Mergers and Acquisitions.” 2004.
  • 9 Journal of International Taxation 1. “Inbound Tax Planning for Individual Foreign Investors and Entrepreneurs.” January 1998.
  • 21 Westchester Bar Journal 203. “New Limited Liability Company Legislation in New York.” 1998.
  • 39 Tax Management Memorandum 9. “One Step Forward, One Step Back: Recent Changes in the Nonrecognition Treatment of Preferred Stock and Warrants.” 1998.
  • 86 Journal of Taxation 2. “International – Tax Court Ends The “Cascading Royalty” Problem.” February 1997.
  • 5 Journal of International Taxation 3. “U.S. Approves Six Treaties: Canada Reconsiders Regs: Mexico Slows Negotiations.” March 1994.
  • 22 TMIJ 367 “Overview of the United States-Israel Tax Treaty, as Amended by the 1993 Protocol.” 1993.

Speeches and Seminars

  • Panelist, Introduction to FATCA & Intergovernmental Agreements, New York Law School, April 2014
  • Moderator, "Joint Current Developments: FAUST, FLF, Transfer Pricing and USAFTT," ABA Section of Taxation's Midyear Meeting, January 2014 
  • Moderator, "Current Tax Issues in China," New York Law School, October 2013
  • Speaker, "Structuring Cross-Border Real Estate Investments," Bloomberg BNA's Canada-U.S. Cross-Border Tax Update Conference, October 2013
  • Panelist, "Withholding and Information Reporting from 1913 to FATCA," New York Law School's "The 100th Anniversary of the Revenue Act of 1913: Marking a Century of Income Tax Law in the United States" Symposium, October 2013  
  • Speaker, “FATCA,” Habib American Bank’s Executive Seminar 2013, September 2013
  • Speaker, “FATCA, FBARs, and Foreign Assets: Reining in Offshore Tax Evasion,” American Law Institute Continuing Legal Education Group, August 2013
  • Speaker, "FATCA: The Game Has Started," NYSSCPA's Tax Planning for Individuals Conference, August 2013
  • Speaker, "FATCA Compliance for Fiduciaries," CBIT Education Inc.'s 28th Annual Spring Tax Day, June 2013
  • Speaker, "Understanding U.S. Taxation of Foreign Investment in Real Property," Bloomberg LP's Current U.S. Tax Planning for Foreign-Controlled Companies, June 2013
  • Moderator, "Understanding Tax Issues for Foreign Persons Investing in U.S. Real Estate," ABA Section of Taxation's Midyear Meeting, January 2013
  • Speaker, “Structuring Cross-Border Real Estate Investments,” Canada – U.S. Cross-Border Tax Update, October 2012
  • Speaker, “Tax Challenges for Foreign Investors in U.S. Real Estate,” Strafford Webinars and Teleconferences, October 2012 and November 2011
  • Speaker, “Case Studies for Outbound and Inbound Investment” and “Foreign Persons Investing in U.S. Real Estate: Partnership and Other Structures, Opportunities and Traps,” NYU’s Summer Institute in Taxation, July 2012
  • Speaker, “Understanding U.S. Taxation of Foreign Investment in Real Property,” Bloomberg LP’s Current U.S. Tax Planning for Foreign-Controlled Companies, June 2012
  • Speaker, “Tax Structuring Considerations for Foreign Investors in U.S. Real Estate,” Bloomberg BNA Webinar, March 2012
  • Moderator, “Hola, Ni Hao, Shalom – Say Hello to Your Foreign Partner,” ABA Section of Taxation’s Midyear Meeting, February 2012
  • Presenter, Tax Structuring of Foreign Investment in U.S. Real Estate with a N.Y. Twist, BNA Tax Management Advisory Board’s Real Estate Meeting, December 2011
  • Speaker, “Structuring Investments by Foreign Persons in U.S. Real Estate,” NYU’s 70th Fall Tax Institute, October 2011
  • Speaker, “Case Studies for Outbound and Inbound Investment” and “Foreign Persons Investing in U.S. Real Estate: Partnerships and other Structures, Opportunities and Traps,” NYU’s Summer Institute in Taxation, July 2011

Professional Affiliations

  • American Bar Association Section of Taxation – Council Director, Foreign Activities of U.S. Taxpayers; Foreign Lawyers Forum; Transfer Pricing; and U.S. Activities of Foreigners and Tax Treaties
  • Journal of International Taxation – Board of Advisors
  • Journal of Taxation and Regulation of Financial Institutions – Board of Advisors
  • American Bar Association Section of Taxation – Chair, U.S. Activities of Foreigners and Tax Treaties   Committee
  • New York State Bar Association – Section of Taxation
  • The Association of the Bar of the City of New York
  • The Florida Bar – Section of Taxation
  • The District of Columbia Bar – Section of Taxation

Civic Involvement and Honors

  • Sutton Place Synagogue/The Jewish Center for the United Nations - Board of Trustees and Patron