Philip Fried is a principal with PwC’s US International Tax Services Financial Services group. His focuses on advising financial service clients on M&A, foreign tax credit, losses and other attribute management, tax-efficient redeployment of funds, and operational restructurings. He has extensive experience in advising investors, investment managers and funds on the structuring of hedge funds, private equity funds, and publicly-traded partnerships. In addition, he speaks on topics such as the use of check-the-box in the international context, Section 367 and Section 304.
He is a member of the New York Bar.
Education:
LL.M. in Taxation, New York University School of Law (1997)
J.D., Harvard Law School (1990)
B.A., Stanford University (1987)
Tax Management Portfolios™
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CFCs — Investment of Earnings in United States Property (Portfolio 6260)
This portfolio analyzes the U.S. income tax consequences under §956 of the Internal Revenue Code of investment.