Subscribe

  • How Can We Help You?

    Global Problem Solving from Covington: Deal with Complex Problems Anywhere in the World

Xueshu (Shae) Qian

Special Counsel

Washington +1 202 662 5020

  • About
  • Representative Matters
  • Credentials
  • About

    Xueshu (“Shae”) Qian is special counsel in the firm’s Tax Practice Group. Her practice centers on tax planning, with particular depth in international tax, including the NCTI (formerly GILTI) and FDDEI (formerly FDII) regimes, foreign tax credit matters, U.S. minimum-tax regimes, and cross-border restructurings for inbound and outbound taxpayers. She helps clients model and optimize outcomes under various U.S. international tax provisions, navigating controversies involving the application of those rules, prepare comment letters on Treasury and IRS regulations, and secure closing agreements with the IRS.

    Areas of Expertise

  • Practices and Industries
  • Representative Matters
    • Counsel clients on the various aspects of foreign tax credits management, including income classification, expenses allocation, deemed-paid credits and BEAT implications.
    • Advise clients on structuring stock compensation to minimize PFIC risks.
    • Assist clients in partnership dissolutions and associated asset distributions.
    • Advise clients on obtaining FDII benefits.
    • Assisted S corporation clients in transitioning into C corporation status post-TCJA.
    • Assisted a multi-national oil and gas client in obtaining treaty benefits.

    Areas of Expertise

  • Credentials
    Education
    • Georgetown University Law Center, LL.M., 2018
        • Tax
        • Thomas Bradbury Chetwood, S.J. Prize
    • Soochow University, Kenneth Wang School of Law, LL.B., 2014
    • Vanderbilt University Law School, J.D., 2017
        • Order of the Coif
    Bar Admissions
    • District of Columbia
    Languages
    • Mandarin

    Areas of Expertise

News and Insights

Events