Experience

Paul Dailey, a partner and leader of the firm's federal tax policy team, brings more than 35 years of experience to his engagements as an authority on international tax matters for corporate and individual clients. Paul specializes in tax planning, structuring, consulting, and compliance issues for large foreign-owned corporations. He has significant and extensive experience in structuring inbound entrance into the U.S. tax regime, as well as outbound IP migration.

From an international standpoint, Paul’s scope includes structuring offshore tax transactions, expatriate planning, entry/exit strategies, and offshore holding company structures. Additionally, he has developed and implemented inbound/outbound tax structures utilizing tax-favored holding companies, blocker entities, and transparent entities, including check- the-box elections. His expertise also includes controlled foreign corporations, passive foreign investment companies, IC-DISC structuring and implementation, transfer pricing, earnings stripping, foreign tax credits, treaties, and withholding.

Paul has worked on numerous mergers and acquisitions, providing tax consulting and implementation strategies to his clients. Such transaction advisory services includes tax-efficient asset allocations, Section 338 stock purchase transactions treated as asset acquisitions, optimum tax beneficial treatment for transaction costs, and Sec. 1202 gain exclusion for small business stock.

In the area of business tax, Paul is proficient in handling matters for domestic corporations, closely held corporations, franchisors, and private equity funds. He has expertise in the pharmaceutical industry including significant experience with the Domestic Production Deduction and R&D credits.

Prior to joining Citrin Cooperman, Paul served as a tax principal at a large accounting firm headquartered in New Jersey. Before that role, he was a tax principal at a Big Six accounting firm.