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Lewis J. Greenwald is a partner in the Tax Department of our Boston office. Prior to joining Sullivan & Worcester, Mr. Greenwald was an International Tax Services Partner in PricewaterhouseCoopers' Boston office. His practice is focused on providing international tax planning for multinational clients. Mr. Greenwald has over 17 years of tax law experience. He has written numerous articles and continues to regularly contribute to international tax journals; he is on the Board of Advisers for the Journal of International Taxation. Representative Client Work Tax efficient, multi-jurisdictional acquisitions, dispositions and reorganizations Migration of intellectual property to tax-favored jurisdictions Leveraging operations; creating double deductions Foreign source income generation Transfer pricing Bar Admissions New York, 1995 Massachusetts, 2003 Publications Inversions 'Lite': Finding 'Substantial Business Activity' Under the New U.S. Regs, Tax Notes International (August 7, 2006) Proposed U.S. Regulations Regarding Dual Consolidated Losses, Tax Notes International (August 15, 2005) New Final Regs. on Trigger Events for Recapture of Dual Consolidated Losses, Journal of International Taxation (December 22, 2003) New U.S. Guidance on Tax-Free Spin-Offs, Tax Notes International (August 2003) Final Piece to 894(c) Reg. Puzzle: Treaty Benefits for Payments by Domestic Reverse Hybrids, Journal of International Taxation, 894(c) Regs. (January 15, 2003) "Temporary Regulations Provide Rules for Allocating a Partnership s Foreign Taxes," Journal of International Taxation (September 2004) "Foreign Tax Credit Limitation Final Regs. Under Sections 864(c) and 904(d), Proposed Regs. Under Sections 902 and 904," Journal of International Taxation (October 2001) "Section 894(c) Final Regs. Simplify Treaty-Benefit Rules for Income Paid to 'Fiscally Transparent Entities'," Journal of International Taxation (December 2000) "New Section 367(e)(1) Regulations: Major Policy Shift For IRS, Planning Opportunities for Distributing Corporations," Journal of International Taxation (October 1999) "Analytical Framework for Electronic Commerce Helps to Determine Tax Implications in Multiple Jurisdictions," Journal of High-Tech (September/October 1998) "U.S. Record Companies Face Withholding Tax Problems," Journal of International Taxation (November 1995) Speaking Engagements Frequent speaker on U.S. international tax issues Professional & Civic Activities Board of Advisors, Journal of International Taxation International Tax Section, Boston Bar Association International Fiscal Association (New England Region) Education J.D., Fordham University School of Law, 1994 M.B.A., Rutgers University Graduate School of Management, 1987 B.A., New York University, 1980 | 