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Christopher Brown's practice focuses on taxation, corporate law and partnerships. He represents emerging companies and closely-held businesses in addressing issues involving entity choice, compensation, lending arrangements, tax planning, tax controversy, and business negotiations. He is also experienced in drafting and negotiating partnership and joint venture arrangements. He has served as counsel to investors in reviewing venture fund and private equity fund investments, including cross-border tax issues involving foreign investments.
Experience: Chris began his professional career in Silicon Valley, working in the international tax practice of one of the Big-4 accounting firms. He has assisted many high-tech companies in planning cross-border transactions and setting up tax-efficient operating structures. Chris has particular experience dealing with tax-deferral structures (including Subpart F and PFIC issues), export incentives, international compensation issues, Social Security totalization, tax treaties, withholding, U.S.-inbound investment, and international tax reporting issues.
Chris has also represented many non-technology companies and individuals with tax, corporate law and partnership law matters. In particular, he has assisted in negotiating and setting up LLC and limited partnership arrangements, including in the areas of real estate, health care, maritime, tax-exempts and venture capital. He has also represented taxpayers in front of the IRS and state tax authorities. He has negotiated audit issues and handled numerous tax collection cases. In the area of compensation, Chris represents companies and individuals in analyzing stock option, restricted stock and other deferred compensation arrangements, including Section 409A compliance.
Representative Engagements:
Served as tax counsel for numerous private financing transactions and buy-outs. Significant experience in advising closely held companies and their shareholders regarding all matters of transactional tax issues, including the negotiation of tax representations and warranties, purchase price allocation, character of income questions, Section 338 elections, state and local tax matters, and tax risk assessment.
Advised executives and companies regarding special limitations on executive compensation, including golden parachute rules and nonqualified deferred compensation under Section 409A.
Assisted U.S. medical device manufacturer with foreign spin-off transaction in Switzerland, including drafting of private letter ruling and related Subpart F and reporting issues.
Advised several public companies with foreign tax credit issues, including expense allocation, tax-deferral, and reporting matters.
Served as international tax counsel to maritime joint venture in Uruguay.
Represented numerous non-U.S. residents with pre-immigration and departure-related tax planning.
Worked with many closely-held companies in addressing succession planning. Provided guidance on stock redemption arrangements, shareholder agreements, corporate governance, fiduciary issues, and compensation.
Garvey Schubert Barer, Seattle (Owner, 2005-2007; Associate, 1999-2005)
PricewaterhouseCoopers, San Jose, California (Manager, International Tax, 1998-1999; Associate, 1996-1998)
Prior Experience: Prior to attending law school, Chris worked as a business and technology reporter in Hong Kong and Taiwan for four years. He was a contributor to Computerworld Hong Kong, Far East Economic Review and other business publications.
Professional Activities: Washington State Bar Association (Member since 1999); California Bar Association (Admitted 1995, inactive); WSBA Partnership Committee; WSBA Tax Section (Executive Council member since 2005, Chair of International Tax Committee); American Bar Association (Member, Tax Section).
Speaking Engagements:
Panelist, 2007 International Conference: Emerging International Tax Issues and Predictions for the Future, presented by the Washington Society of Certified Public Accountants, May 4, 2007.
Speaker, Employment Law Essentials: Update Your Practice With Views From the Bench and Leading Practitioners: Emerging Tax Law Issues for Employment Attorneys, presented by the Washington State Bar Association, July 26, 2007.
Education: Cornell University (B.A. 1988, Geology); University of Washington (J.D., 1995), Managing Editor - Production, Pacific Rim Law & Policy Journal. |
