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Frank Dworak is a tax associate in the firm’s Washington DC office. His practice focuses on domestic and international tax issues in the planning and controversy contexts.
Prior to joining the firm, Mr. Dworak was a senior attorney with the IRS Office of Chief Counsel, where he represented the Large Business & International Division of the Internal Revenue Service in a variety of matters involving issues relating to, among other things, subpart F, transfer pricing, foreign tax credits, corporate reorganizations, consolidated returns, partnerships, and transferee liability, and his work spanned all levels of the controversy process, including examination, IRS Appeals, and litigation in the Tax Court.
Prior to his time with the IRS, Mr. Dworak was an associate attorney at a large international law firm, practicing tax law in both Los Angeles and Chicago.
Representative Matters
- Advising corporations on controversy matters relating to, among other things, subpart F income, partnership allocations, transfer pricing, captive insurance, and the deductibility of research and experimentation expenditures.
- Assisting corporation in obtaining private letter ruling for internal spinoff.
- Advising corporation regarding conforming adjustments and related foreign currency tax issues in connection with adjustments under section 482.
- Advising companies on FICA refund matters.
Previous Experience
- IRS Office of Chief Counsel, Senior Attorney (LB&I) (2009-2012)
- Associate Attorney at International Law Firm (2004-2009)
Pro Bono
- Assisting individual taxpayers in IRS collection matters, including obtaining installment agreements and offers in compromise.
- Assisting individual taxpayer in responding to IRS notice asserting unreported income.
- Advising not-for-profit mental health agency regarding tax matters arising in probate proceedings.
Publications and Speeches
- "Flow-Through Taxation of Business Entities: An Introduction," The John Marshall Law School (10/17/2012)
- "Transferee Liability in Intermediary Transaction Cases," The John Marshall Law School (9/28/2011)
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